Not so sure. We mentioned this before. We don't know about BBID and Protect. If those servers are shut down too, what happens if you need to reload the OS, or maybe even just re-boot, and there's no BBID server to check against? Is the phone locked out?
BlackBerry hasn't clarified, so maybe there is no problem.
Maybe BlackBerry will release an OS update that releases the phone from the servers and keeps all ID stuff internal.
Until BlackBerry says something about it, we are just guess. The BB10 phones actually have a good bit of ties back to the NOC that we realize.