FCC VoIP E911 Regulations
The Federal Communications Commission (FCC) has established a set of rules and E911 regulations that require interconnected VoIP service providers to deliver E911 services to their subscribers. Interconnected VoIP service providers connect the IP realm and the Public Switched Telephone Network (PSTN), allowing subscribers to benefit from increased efficiency by routing calls over the internet.
The E911 regulations established by the FCC are mandatory for all interconnected VoIP service providers, and are designed to protect the safety of VoIP users who expect that when they dial 911, emergency responders know exactly where they are and will quickly arrive on-scene. Specifically, the FCC requires VoIP service providers to:
- Deliver all 911 calls to the local Public Safety Answering Point (PSAP), along with the subscriber’s call back number and location information (where the PSAP is capable of receiving it).
- Offer subscribers a simple and easy way to update their registered physical location, should it change.
- Inform subscribers of the capabilities and limitations of the E911 service they provide.
To view the FCC Rules and E911 Regulations for VoIP 911, click here (http://www.fcc.gov/cgb/voip911order.pdf).
MLTS E911 LAWS AND Regulations by State
Many states have laws and regulations regarding 911 service as it applies to enterprises. These laws and regulations vary from basic guidelines concerning access to 911 and dialing prefixes, to specific requirements regarding notifications and detailed location delivery to the Public Safety Answering Point (PSAP). Enterprises operating in states that have implemented or are considering 911 regulations should work with their advisors to ensure that they have taken adequate measures to attain compliance with any applicable or pending 911 legislation.
The following are general summaries of applicable E911 laws and regulations by state, as well as links to the 911 legislation or regulations themselves. These summaries should not be taken as official records of state law, but are instead for informational use only. Again, West recommends that organizations work with their regulatory advisors and legal teams to understand how these 911 laws and regulations will impact their operations.
For a downloadable summary please Click Here.
Last updated: August 1, 2019
Existing E911 Legislation
|Alaska||A municipality may require MLTS operators to provide enhanced 911 service. Learn more:
|Arkansas||MLTS operators must deliver to the PSAP the phone number and street address of any telephone used to place a 911 call. Details and exemptions are outlined as well. Learn more: http://www.lexisnexis.com/hottopics/arcode/Default.asp
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|Colorado||MLTS operators shall provide written information to their end-users describing the proper method of dialing 911, when dialing an additional digit prefix is required. MLTS operators that do not give the ANI, the ALI, or both shall disclose this in writing to their end-users and instruct them to provide their telephone number and exact location when calling 911. Learn more
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|Connecticut||A private company, corporation or institution may provide private 911 service to its users, provided it has adequate resources, the approval of the Office of State-Wide Emergency Telecommunications and the municipality in which it is located, and a qualified private safety answering point. Learn more.|
|Florida||All PBX systems installed after January 1, 2004 must be able to provide station-level ALI data to the PSAP. Learn more|
|Illinois||Private residential switch service providers must identify the telephone number, extension number, and the physical location of a 911 caller to the PSAP. Private business switch service providers must provide ANI and ALI data for each 911 call, and must not require the dialing of an additional digit prefix (systems installed after July 1, 2015); the level of detail required for ALI data, exemptions and guidelines to establish a private emergency answering point are outlined as well. Learn more: http://www.ilga.gov/legislation/ilcs/ilcs3.asp?ActID=741&ChapterID=11
|Kentucky||Residential private switch telephone service providers located in E911 capable areas must provide ANI and ALI data for each 911 call, and must provide ALI that includes the street address, plus an apartment number or floor, if applicable. Learn more|
|Louisiana||PBX systems installed after January 1, 2005, must be capable of providing station-level ALI data to the PSAP. Learn more|
|Maine||Residential MLTS providers must deliver a distinct ANI and ALI for each living unit to the PSAP. Business MLTS providers must deliver ANI and ALI to the PSAP; specific ALI data requirements are outlined. Also includes requirements for hotels/motels, exemptions and guidelines to establish a private emergency answering point. Any public or private entity that installs or operates a multi-line telephone system ensures that it is connected to the PSTN in such a way that 911 can be dialed without requiring any prefixes. Learn more: http://www.maine911.com/laws_rules/rules.htm
|Maryland||MLTS operators must not require the dialing of any additional digits to access 911 as of December 31, 2017. Learn more|
|Massachusetts||All new or substantially renovated MLTS must route emergency calls to the appropriate PSAP and provide an ANI and ALI for every 911 call. The level of detail required for ALI data and exemptions are outlined as well. Learn more:
|Michigan||Michigan’s Emergency 911 Service Enabling Act was amended in 2019 to replace rules promulgated by the Michigan Public Service Commission requiring 911 emergency service capacity for multi-line telephone systems with new requirements. The bill specifically exempts certain small business, farms, and houses of worship from the requirement to maintain a multi-line telephone system that automatically provides detailed location data to the 911 dispatcher. Learn more:
|Minnesota||Operators of MLTS purchased after December 31, 2004 must ensure that their system provides ANI and ALI for each 911 call. Residential MTLS should provide one distinctive ANI and one distinctive ALI per residential unit. Location identification requirements for businesses are outlined. Also includes requirements for hotels/motels, schools, exemptions and guidelines to establish a private emergency answering point. Learn more|
|Mississippi||Service providers must provide callers with access to the appropriate PSAP. Anyone operating a shared tenant service is required to provide the ANI and ALI for each 911 call made from any extension. Exemptions are outlined as well. Learn more
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|New Hampshire||Telephone and VoIP service providers, as well as hotels, motels, hospitals, universities and potentially others, must deliver the 911 call with the ANI to the appropriate PSAP
|Oklahoma||Business owners or operators using VoIP service must allow a 911 call on the system to directly access 911 without an additional code, digit, prefix, postfix, or trunk-access code, and must provide a notification to a central location when someone on their network dials 911. Details and exemptions are outlined as well. Effective January 1, 2017.
|Pennsylvania||Shared residential MLTS operators must deliver 911 calls to the PSAP with one distinctive ANI and ALI for each living unit. Business MLTS operators must deliver the 911 call with an ANI and ALI detailed to the building and floor location of the caller, or must establish a private emergency answering point. Details, notification requirements and exemptions are outlined as well.
|Tennessee||An entity that owns or controls a telephone system that is capable of outbound dialing is required to configure the telephone system to allow a person to dial 911 without an additional code, digit, prefix, postfix, or trunk access code. An entity that owns or operates a residential or business facility utilizing a telephone system must provide notification to a central location on the site of the residential or business facility when a person within the facility dials 911. Exceptions are outlined as well. Learn more:
• Title 7, Chapter 86, part 4
|Texas||MLTS operators who serve residential users and facilities must provide the same level of 911 service as received by other residential users in the same regional plan area, including ANI. Business owners or operators using VoIP service must allow a 911 call on the system to directly access 911 without an additional code, digit, prefix, postfix, or trunk-access code, and must provide a notification to a central location when someone on their network dials 911. Details and exemptions are outlined as well. Learn more:
• Texas Administrative Code Title 1, Part 12, Chapter 251
Tarrant County, Texas, requires that MLTS providers offering residential or commercial service to non-affiliated businesses must provide the level of 911 service as required under the appropriate regional plan. Businesses must provide the PSAP with ANI and ALI data for each 911 call. Details, including location identification requirements for businesses and exemptions, are outlined as well. Learn more:
|Utah||Requires certain multi-line telephone systems to provide certain information to a public safety answering point; requires a multi-line telephone system to be capable of accessing 911 services directly. Learn more:
|Vermont||Any enterprise communications system shall provide to those end users the same level of 911 service that other end users receive and shall provide ANI signaling, station identification data, including dispatchable location, and updates to Enhanced 911 databases under rules adopted by the Board. Exemptions are outlined.
|Virginia||MLTS providers must ensure that an emergency call placed from any telephone is delivered to the PSAP with ANI and ALI, or an alternative method of providing call location information. Exemptions are outlined as well.
|Washington||Residential service providers must ensure that an emergency call placed from any caller is delivered to the PSAP along with a unique ALI for their unit. Business service providers must ensure that an emergency call placed from any caller is delivered to the PSAP along with a unique ALI for their telephone. Exemptions are outlined as well. Learn more:
|Federal||Multi-line telephone systems must have a configuration that permits users to directly initiate a call to 911 without dialing any additional digit, code, prefix, or post-fix. Learn more: https://www.congress.gov/115/bills/hr582/BILLS-115hr582enr.pdf|
Pending E911 Legislation
|New York||MLTS operating in state or local government buildings must allow any call to 911 on the system to be directly connected to a public safety answering point (PSAP). Exemptions are outlined. Learn more:
Proposes that “covered businesses”, “hotels” and “motels” operating a MLTS provide direct access to 911 without the dialing of additional codes. When feasible, notification should be provided to a central location on the same site on the system. Exemptions listed. Learn more:
CRTC E911 Regulations
The Canadian Radio-television and Telecommunications Commission (CRTC) has established decision 2007-44, which requires VoIP service providers to make 911 services available to their fixed/non-native and nomadic VoIP subscribers. VoIP service providers connect the IP realm and the Public Switched Telephone Network (PSTN), allowing subscribers to benefit from increased efficiency by routing calls over the Internet.
The CRTC decision obliges VoIP service providers to deliver all 911 calls to the appropriate Public Safety Answering Point (PSAP) using the zero-dialed emergency call routing service (0-ECRS), rather than PSAP low-priority lines. Adherence to this decision is mandatory for all VoIP service providers offering services in Canada, and is designed to protect the safety of VoIP users who expect that when they dial 911, they will quickly be connected to qualified emergency responders.
To view CRTC decision 2007-44, which establishes the regulations for VoIP 911 in Canada, click here (www.crtc.gc.ca/eng/archive/2007/dt2007-44.htm).