Deep dive: emergency calling

Emergency calling

Every voice-enabled number you sell is a 911 obligation, and the provider carries most of it.

US. For interconnected VoIP (VoIP connected to the public phone network), 47 CFR 9.11 requires the provider to:

• Send every 911 call to the right PSAP with the caller's number and location.
• Deliver a dispatchable location: a validated street address plus suite, apartment or floor (47 CFR 9.3). Automatically for fixed service since January 6, 2021. For nomadic service (a line the customer can move around) since January 6, 2022 where technically feasible; otherwise the Registered Location (the last address the customer gave), other location data or, as a last resort, a national emergency call center.
• Collect a Registered Location before service starts, and let the customer update it.
• Tell every subscriber where 911 may not work, get an affirmative acknowledgment, and supply warning labels.

In practice the platform validates the address through its 911 provider, ties it to the number and deletes it on release or port-out. The customer gives a real address, updates it after a move and, for a multi-line phone system, complies with Kari's Law (direct 911 dialing and on-site notification, since February 16, 2020).

NG911 raises the floor. Under the FCC's 2024 order, originating providers, interconnected VoIP included, must deliver 911 over SIP to NG911 delivery points within six months of a valid request from a 911 authority, and pay for getting it there. A June 2026 order (FCC 26-39) gives IP 911 traffic aggregators reliability duties too, after an 18-month transition that starts with an FCC public notice. If your platform aggregates customers' 911 calls before handing them to a 911 provider, I'd find out now whether you're covered. Text-to-911 follows the same pattern: route texts within six months of a valid PSAP request.

Canada. CRTC Telecom Decision 2005-21 requires enhanced 9-1-1 for fixed VoIP, an interim service comparable to basic 9-1-1 for nomadic VoIP (in practice an outside call center), and customer notice of limitations with express consent. The NG9-1-1 transition deadline is March 31, 2027 (CRTC 2025-67); in November 2025 the CRTC denied a request to change it.

Elsewhere. The EU requires free access to 112 with network and handset location (AML, Advanced Mobile Location, where the phone sends its own position), with accuracy rules in Delegated Regulation 2023/444. The UK requires uninterrupted access to 999 and 112 with accurate caller location. In Latin America: Brazil uses 190 (police), 192 (ambulance), 193 (fire) and 199 (civil defense), all free; Mexico has used 911 nationally since January 2017, with AML location required for calls and SMS; Colombia uses 123.

A staffing agency gives remote recruiters softphone numbers, all registered to head office. A recruiter who dials 911 from home reaches the call center near head office, unless the product asked for a new address when they moved.

On any voice product I check early whether a number can go live without a validated 911 address. If it can, I fix that before launch.