Earlier quoted context omitted.
yes. the sim has direct access to the radio and other modules, by design. it only needs the actual phone cpu/os for use interface. if it wants to take the radio out of silent mode it can.
That seems like it wouldn't comply with FAA regulations. I always presumed "airplane mode" was the specific set of features required by the FAA to enable the phone to do the same thing as a phone that's off, from the perspective of potential interference with a plane's communications. If the SIM can still enable and use the radio despite "airplane mode" being on, then "airplane mode" is not really "a mode for making…
try this: enable airplane mode and then open any app that has system permission to change gps or Bluetooth or wifi settings. it will enable those radio and the ui will still show the little airplane there.