Apparently the lack of emergency calls without SIM is due to pre-existing german practice because of some "misuse" of emergency calls.
I have no words that would not end up in things that might necessity calling 112...
I have no words that would not end up in things that might necessity calling 112...
In the past they handled the call without that information, but after an incident in 2013 the court ruled that the requirements also must be fulfilled without a SIM (0).
So some carriers (notably all German ones) stopped accepting Emergency calls without SIM, first to not be in violation of the law but nowadays apparently due to "misuse" (?) (1).
(0) https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CEL...
(1) https://www.heise.de/en/background/112-Emergency-Call-Day-No...