Yeah, but you can use any SIM to activate it from the original carrier that it was locked to (assuming it's not an unlocked phone; if it is, even easier and literally any SIM will work).
It might even be on a baseband that can be unlocked, although IIRC you'll need a carrier-specific SIM card before doing that if the phone can't be hactivated. I remember on the 3GS you could even 'downgrade' to the iPad's contemporary modem firmware (06.11.00 or something like that) that did allow unlocking hacks, although I think there was then some problem with the GPS not functioning properly.