I just wrote in to IMDA to ask on their position. To me, cutting off cellular service totally upon data exhaustion is not acceptable. Neither was there any transparency in the terms and conditions on this fact. I would consider cellular service a minimum essential service that any telco should maintain.
Just an update on this issue. IMDA responded and below is their response:
We refer to your feedback on 21 February 2026 regarding loss of cellular service while roaming in Japan with GOMO after exhausting your data allowance. Thank you for acknowledging the ADR advisory.
We would like to clarify that service providers have discretion in their daily operations, including making any provision on the functionality of mobile service while overseas. Note that roaming is enabled through commercial and technical arrangements between a home operator and foreign roaming partner(s). IMDA also does not prescribe how service providers should price, package and sell their services.
Neverthesless, we understand your concern about losing access to essential SMS services while roaming in Japan after your data allowance was exhausted, particularly for critical communications like banking OTPs and travel alerts.
We recognize the importance of maintaining connectivity for essential services, especially in the context of the 3G shutdown transition. IMDA will follow up with GOMO on the outcome and request them to contact you directly to address your concern regarding their roaming service implementation and the complete signal termination upon data exhaustion.
GOMO may contact you if more information is required or to update you on their findings and outcome. We appreciate you taking the time to share your experience with us. Thank you.