[lmz]

I suppose this depends on how the law is written, but are roaming users subject to local SIM regulations for network use? I can't imagine asking for ID from tourists using their existing SIMs is going to work.

I believe some travel eSIMs are actually issued from outside the country you're going to.

[morpheuskafka]

Typically not. Because they don't have local phone numbers nor IP addresses, so they cannot be used for scams or fake identities domestically. In China, roaming SIMs also bypass all internet filtering, it's basically a built in VPN back to your home telecom.

And as you said, ones marketed as "China travel SIMs" are typically issued from Hong Kong. Interestingly, Hong Kong also has an ID rule (though it allows self upload of ID anyway), but it exempts these roaming-only cards. If you want the card to work in HK, and it is issued from there, you must scan your passport to activate it.

[ezfe]

Right, but that distinction is not because it's an eSIM - it's just how it's issued. There's no technical distinction, just a practical ease of issuance.