Ah, I guess I forgot about that. Yeah, you either need to intercept the new SIM sent to the original customer, or defeat the identification procedure. That adds quite the hurdle compared to countries that have no such requirements.

At least for now you can still easily anonymously buy (activated) sims from other european countries.

According to the linked [0] report, of the two providers in Germany that were asked, one had 1-10 incidents, and one 11-30. In a year. So I guess those issues exist, it’s just a minority issue. The related German Wikipedia page [1] and almost all articles I can find also mainly talk about the USA. It seems you can usually add another required password for phone changes, but mainly it’s just not an issue. No ridiculously bureaucratic requirements, though.

[0]: https://www.enisa.europa.eu/publications/countering-sim-swap...

[1]: https://de.wikipedia.org/wiki/SIM-Swapping