Auto Attendant Article
Canada VoIP 9-1-1 Rules: What the CRTC Requires
The CRTC's three-part local VoIP test, the 9-1-1, notice and registration duties, fixed vs nomadic service, and the 31 March 2027 NG9-1-1 date.

Summary
- 01Local VoIP service providers must provide Basic or Enhanced 9-1-1, notify customers of applicable limitations, obtain express consent where required, and register with the CRTC.
- 02Fixed/native service can send an address automatically. Nomadic and fixed/non-native services provide service functionally comparable to Basic 9-1-1 and require notice and consent.
- 03A VoIP line can fail during a power or internet outage, even when it is fixed/native. Businesses should keep their address current and explain the limitations to staff.
- 04The article distinguishes receive-only forwarding from a phone that dials out, while noting that the CRTC has not ruled on inbound-only services. Ask vendors to confirm their position in writing.
- 05The article identifies 31 March 2027 as the legacy network retirement date. Businesses should check the CRTC page and ask whether their VoIP provider is NG9-1-1 ready.
Inside this article
- 01The short answer
- 02The CRTC test for a local VoIP service provider
- 03The three obligations
- 04Fixed, nomadic and non-native: why the type matters
- 05What customers must be told, and how they consent
- 06Forwarding services vs a phone that dials out
- 07Next-generation 9-1-1 and the 2027 date
- 08If you run your own phone system: MLTS best practices
- 09Checklist for a Canadian small business
- 10FAQ
- 11Sources
The short answer
In Canada, 9-1-1 duties for internet phone service fall on local VoIP service providers, a category the CRTC defines with a three-part test. A provider that meets it must give customers Basic or Enhanced 9-1-1, warn them about 9-1-1 limitations (for nomadic and fixed/non-native services), get their express consent to those limitations, and register with the CRTC [1].
For a business choosing VoIP:
- The duties sit with the provider. Your job is to know what 9-1-1 your service gives you, keep your address current, and make sure staff know the limits.
- 9-1-1 quality depends on whether the service is fixed or nomadic, and whether the number is native to your area. A fixed line on a local number can send your address automatically; a softphone used from anywhere generally cannot.
- A service that only receives calls and passes them to your phones is different from a phone that dials out. The 9-1-1 call is carried by whichever phone places it.
- The legacy 9-1-1 network is being retired: the CRTC's date is 31 March 2027 [2].
This describes the rules as of October 2026. It is educational information, not legal advice; for your own setup, ask your provider in writing or contact the CRTC.
The CRTC test for a local VoIP service provider
Local VoIP service providers [1]:
- provide their customers with telephone numbers that conform to the North American Numbering Plan;
- provide access to and from the public switched telephone network (PSTN); and
- enable customers to make and/or receive calls that originate and terminate within an exchange or a local calling area.
The definition comes from Telecom Decision CRTC 2005-21 of 4 April 2005. The decision's own wording is slightly broader than the CRTC's summary page: it speaks of access "to and/or from" the PSTN and the ability to "make and/or receive calls" (para 2). The same CRTC page adds two clarifications:
- "A company's use of VoIP technology does not make the company a local VoIP service provider automatically." It has to meet all three criteria.
- Companies providing only long-distance service, or services to other carriers, are not local VoIP service providers.
In plain terms, the rules were written for a service that replaces a local phone line: a local number, calls out to ordinary phones, and calls in from them.
The three obligations
| Obligation | What it means | Decision |
|---|---|---|
| 1. Provide 9-1-1 | Basic or Enhanced 9-1-1 for customers | 2005-21 |
| 2. Notify customers of limitations | At sign-up and installation, in marketing, in the terms of service, and on the web through an easily accessible link. Applies only to nomadic and fixed/non-native services | 2005-21, 2005-61 |
| 3. Register with the CRTC | As a reseller, or as a competitive local exchange carrier (CLEC) if it owns and controls transmission facilities; plus a BITS licence if it carries traffic internationally | 2005-28 |
Source: CRTC. When a company applies, it confirms which 9-1-1 provider it uses, how it obtains express consent, and that customers can update their "most likely physical address" online. Nomadic and fixed/non-native providers also submit their notice texts, liability wording and phone-sticker text for approval. A compliant provider therefore has its 9-1-1 limitations in writing. If one cannot show you that text, ask why.
- 01Provide emergency calling
Provide customers with Basic or Enhanced 9-1-1.
- 02Explain limits and obtain consent
For nomadic and fixed/non-native services, notify customers of limitations and obtain express consent before service starts.
- 03Register with the CRTC
Register as a reseller or, if the provider owns and controls transmission facilities, as a CLEC. International traffic also requires a BITS licence.
Fixed, nomadic and non-native: why the type matters
Two levels of 9-1-1 exist [3]:
- Basic 9-1-1 routes the call to a public safety answering point (PSAP). The call-taker typically sees the number but not the location, so the caller must say where they are.
- Enhanced 9-1-1 (E9-1-1) adds Automatic Location Information (ALI): name, number, address and service type arrive with the call.
Decision 2005-21 then sorted local VoIP into three configurations:
| Configuration | What it is | 9-1-1 required | Notice and consent? |
|---|---|---|---|
| Fixed/native | One address, number native to that address's PSAP area | 9-1-1/E9-1-1 where the incumbent offers it, with your address in the ALI database (para 52) | No, since Decision 2011-619 |
| Fixed/non-native | One address, number from outside your PSAP area | Functionally comparable to Basic 9-1-1, never routed to a PSAP that does not serve your location (para 68) | Yes |
| Nomadic | Usable from any internet connection (softphone, portable adapter) | Same as fixed/non-native (para 68) | Yes |
The reason: the 9-1-1 database may reject an out-of-area number, and with nomadic use the provider cannot know where you are (paras 54-56). The accepted interim fix sends the call to a third-party centre whose agents ask for the location and transfer it to the right PSAP (para 60). The CRTC's consumer page calls this zero-dialed emergency call routing, and says the registered address is a fallback, used only when the caller cannot give a location [4].
That page sums it up: fixed VoIP provides Enhanced 9-1-1 equivalent to a traditional line, nomadic VoIP provides Basic 9-1-1 "because there is no fixed address to provide to 9-1-1 operators." The page (last modified October 2024) lists Newfoundland and Labrador, Yukon and the Northwest Territories as Basic 9-1-1 areas, and notes that where 9-1-1 is not available, such as in Nunavut, emergency services use an ordinary phone number.
One limit applies to every type: a VoIP line, even fixed/native, "may be unavailable during periods of power outage or broadband Internet outage." The CRTC dropped the special notice for fixed/native service because it saw this as a trait of VoIP, not of its 9-1-1 (Telecom Decision CRTC 2011-619, paras 10-12). The outage risk remains.
- One address, with a number native to that address's PSAP area.
- Provides 9-1-1/E9-1-1 where the incumbent offers it, with the address in the ALI database.
- Special notice and consent are no longer required following Decision 2011-619.
- Fixed/non-native uses one address with a number from outside its PSAP area.
- Nomadic service works from any internet connection, including a softphone or portable adapter.
- Both require service functionally comparable to Basic 9-1-1, routed to a PSAP serving the location.
- Both require notice of limitations and express consent.
Every VoIP configuration can be unavailable during a power outage or broadband internet outage.
A compliant provider therefore has its 9-1-1 limitations in writing. If one cannot show you that text, ask why.
What customers must be told, and how they consent
Decision 2005-21 requires notice before service starts (marketing, terms of service, online material, customer service staff, contracts, starter kits) and during service (including stickers on phone sets and billing inserts) [3].
Telecom Decision CRTC 2005-61 (20 October 2005) set the minimum content: that VoIP 9-1-1 has limits compared with traditional E9-1-1; when it is or is not available; what is provided and on what conditions; the material differences; what callers should do about them; the subscriber's duty to tell all users; and limitations of liability. It also set user tips (confirm your location and call-back number, expect failure in a power or internet outage, keep your address current, do not hang up) and a 12-point minimum type size for terms, websites and contracts.
Express consent. Where 9-1-1 is limited, the provider must get your express consent before service starts, for example in writing, by internet confirmation or by recorded oral consent. Notices must be available in Braille or large print and explained on request [3].
The CRTC's suggested sticker reads: "ATTENTION. When dialing 9-1-1, be prepared to provide your address/location." Its terms template makes the subscriber responsible for telling anyone who uses the service about the limits [1]. That lands on you: if staff or visitors could pick up a nomadic VoIP phone in your office, they need to know.
Forwarding services vs a phone that dials out
Many small-business phone products are not phone lines in the 2005 sense. Separate two roles:
- A service that receives calls. Call forwarding, a virtual number that rings your mobile, or an auto attendant that plays a menu and rings the person chosen. Calls come in; nobody places a call through it.
- A service that places calls. A desk phone, softphone app or cloud phone system your team dials out on.
The 9-1-1 rules are about the second role. A 9-1-1 call is routed and located by the network of the phone that dials it: when someone dials 9-1-1 on their mobile, their mobile carrier carries it, whatever business number rang that mobile a minute earlier.
Our reading of the framework, which is not a CRTC ruling: the definition alone does not settle the question, because Decision 2005-21 says "to and/or from" the PSTN. What settles it is what the duties require. Every 9-1-1 direction in the decision is about routing a 9-1-1 call that a customer places, "a 9-1-1 call originating from a local VoIP service" (paras 52 and 68). A service through which nobody can place any call cannot originate a 9-1-1 call, so there is nothing for it to route. The duty that still makes sense is the notice: such a service should say plainly that it cannot reach 9-1-1 and that 9-1-1 is dialled from your own phone. US rules point the same way and say it outright: for 911 purposes, the test is whether users can place calls to the public network (47 CFR 9.3, "interconnected VoIP service", para (2)).
Two cautions:
- Hybrid products. Some forwarding apps also let staff place calls showing the business number. That outbound feature is a dial-out service, and the 9-1-1 duties apply to it; ask how it handles 9-1-1.
- Get it in writing. The CRTC's consumer page states that "all VoIP service providers are obligated to provide access to 9-1-1 services" [4], and it has not ruled on inbound-only services. If a vendor says its product carries no 9-1-1, ask it to confirm in writing that nobody can place calls through it, and make sure everyone on your team has another phone that can dial 9-1-1.
For how one receive-only service explains its position, see our emergency calling guide, Canada section.
Next-generation 9-1-1 and the 2027 date
Canada is moving 9-1-1 from the legacy E9-1-1 network to an IP-based next-generation network (NG9-1-1).
- 2017. Telecom Regulatory Policy CRTC 2017-182 (1 June 2017) mandated NG9-1-1 under an "ILEC stewardship model", with the incumbent carriers building and running the networks under CRTC oversight, and chose real-time text (RTT) as the second way to reach 9-1-1. Its original dates (voice by 30 June 2020, legacy decommissioning by 30 June 2023) have been replaced.
- 2025. The deadline had moved to 4 March 2025. Telecom Decision CRTC 2025-67 (28 February 2025) found most 9-1-1 centres would not be ready and directed the incumbents to decommission the E9-1-1 components not forming part of NG9-1-1 by 31 March 2027, or earlier where every provider and PSAP in a territory has moved. After that, providers not on NG9-1-1 "will not be able to send 9-1-1 calls" without their own gateways. Quebecor and Rogers asked the CRTC to review and vary that timeline; the CRTC disposed of the application in Telecom Decision CRTC 2025-291 in late 2025, and the date it publishes is still 31 March 2027.
- 2026. The CRTC's NG9-1-1 page says all telecommunications providers must be ready for NG9-1-1 voice by 31 March 2027, that the RTT deadline for the public "will be set at a later date", and that "these updates will not affect current access to 9-1-1" [5]. In May 2026 a CRTC commissioner said "there are no plans to extend that deadline further" [6].
As of October 2026, the CRTC's most recent decision we could verify sets 31 March 2027. The date has moved before, so check the CRTC page before relying on it. For a business, dialing 9-1-1 does not change; ask your VoIP provider whether it is NG9-1-1 ready.
The CRTC mandated NG9-1-1, with incumbent carriers building and running the networks under CRTC oversight.
After finding most centres would not be ready, the CRTC directed retirement by 31 March 2027, or earlier where all providers and PSAPs in a territory had moved.
The CRTC page says all telecommunications providers must be ready for NG9-1-1 voice by this date. The public RTT deadline remains to be set.
If you run your own phone system: MLTS best practices
The CRTC's page on multi-line telephone systems (MLTS) notes that Canada does not have legislation similar to the US rules for these systems. It publishes best practices instead, which it says "ensure 9-1-1 calls are received locally with accurate location information" [7][8]. For owners and operators:
- Direct dialing. 9-1-1 should work without a prefix where technically feasible, and also with any prefix used for outside calls.
- No internal detour. Calls go straight to the PSAP, not to reception or security first.
- Location per phone. Work with your carrier so each fixed phone, or group of co-located phones, maps to an accurate location, with building, floor or room where useful.
- A callable number. The number sent to the PSAP should be dialable from outside.
- On-site notification. Alert trained staff (who, when, where) that someone dialled 9-1-1, without interrupting the call.
- Test and educate. Test what the PSAP receives, and explain the risks of prefix dialing and missing location data to users.
Checklist for a Canadian small business
Before you sign:
- Ask whether the service is fixed or nomadic, and whether your number is native to your area.
- Ask what level of 9-1-1 (Basic or Enhanced) it delivers at your address.
- Read the 9-1-1 section of the terms and the liability wording.
- Expect to give express consent if 9-1-1 is limited; keep a copy.
- Ask how you update your service address online, and whether the provider is NG9-1-1 ready.
After you switch:
- Put the 9-1-1 sticker or a printed notice on each desk phone.
- Tell staff in writing: give the address, do not hang up, call back if dropped.
- Make sure anyone working alone or after hours has a mobile or landline that can dial 9-1-1, including during a power or internet outage.
- Update the registered address whenever you move or add a location.
- If you use a forwarding or menu service, write down which phone your team dials 9-1-1 from.
- If you run a PBX, walk through the MLTS points with your vendor and test the call path.
FAQ
Can I dial 9-1-1 from a VoIP phone in Canada? From a local VoIP service that makes calls, yes: Basic or Enhanced 9-1-1 is required, depending on the configuration. From a service that only receives calls, no; use a phone that can dial out.
Who answers 9-1-1, and who regulates it? The CRTC regulates the phone and cell companies that connect 9-1-1 calls. The call centres and responders fall under provincial, territorial and municipal governments [9].
Does my business need to register with the CRTC? Not as an ordinary customer. Registration is the provider's obligation; a company that itself offers local VoIP to others registers as a reseller or CLEC [1].
What happens to 9-1-1 in a power or internet outage? A VoIP line, even a fixed one, may stop working, and 9-1-1 with it [10]. Keep a charged mobile at hand.
Can I text 9-1-1? Not for the general public yet; the CRTC has still to set the NG9-1-1 real-time text deadline [5]. A separate Text with 9-1-1 service exists for people with hearing or speech disabilities [11].
Do these rules apply to US service? No. The CRTC rules apply to service in Canada; the US has its own FCC framework. Our emergency calling guide covers both.
Auto Attendant only receives calls and rings your team's phones; it places no outbound calls, so 9-1-1 is dialled from your own mobile or landline. More for Canadian businesses is on our Canada page.
Sources
- CRTC, 9-1-1 Obligations of Local VoIP Service Providers in Canada (modified 20 January 2026; read via Internet Archive). https://crtc.gc.ca/eng/phone/911/voip.htm. Local VoIP test, three obligations, notice channels, sample sticker.
- Telecom Decision CRTC 2005-21, 4 April 2005. https://crtc.gc.ca/eng/archive/2005/dt2005-21.htm. Basic vs E9-1-1, configuration duties, notice and express consent.
- Telecom Decision CRTC 2005-61, 20 October 2005. https://crtc.gc.ca/eng/archive/2005/dt2005-61.htm. Notice objectives, user tips, type size.
- Telecom Decision CRTC 2011-619, 26 September 2011. https://crtc.gc.ca/eng/archive/2011/2011-619.htm. Fixed/native exemption; outage limits.
- CRTC, 9-1-1 Services for Traditional Wireline, VoIP and Wireless Phone Services. https://crtc.gc.ca/eng/phone/911/can.htm. Fixed vs nomadic levels, zero-dialed routing, regional Basic 9-1-1.
- CRTC, 9-1-1 services. https://crtc.gc.ca/eng/phone/911/. Federal vs provincial and municipal roles.
- CRTC, Telephone and cell service providers. https://crtc.gc.ca/eng/phone/911/serv.htm. Provider duty to offer 9-1-1; MLTS pointer.
- CRTC, Multi Line Telephone System (MLTS) Best Practices (modified 21 November 2022). https://crtc.gc.ca/eng/phone/911/multi.htm. MLTS practices.
- Telecom Regulatory Policy CRTC 2017-182, 1 June 2017. https://crtc.gc.ca/eng/archive/2017/2017-182.htm. NG9-1-1 mandate, original dates, Text with 9-1-1.
- Telecom Decision CRTC 2025-67, 28 February 2025. https://crtc.gc.ca/eng/archive/2025/2025-67.htm. 31 March 2027 E9-1-1 decommissioning.
- CRTC, Next-generation 9-1-1 (modified 28 February 2025). https://crtc.gc.ca/eng/phone/911/gen.htm. NG9-1-1 voice readiness date; RTT date pending.
- CRTC, Bram Abramson to the National Emergency Number Association Ontario, 6 May 2026. https://www.canada.ca/en/radio-television-telecommunications/news/2026/05/bram-abramson-to-the-national-emergency-number-association-on.html. No further extension planned.
- CRTC, Decisions 2025 list (read via Internet Archive, 13 August 2026). https://crtc.gc.ca/eng/8045/d2025.htm. Title and record of Telecom Decision CRTC 2025-291 (application to review and vary 2025-67).
- 47 CFR 9.3, Definitions (eCFR, current to 27 October 2026). https://www.ecfr.gov/current/title-47/section-9.3. Interconnected VoIP for 911 purposes.
CRTC pages (1-11) block automated access and were read through Internet Archive copies captured in 2025-2026; the original URLs are cited.
External Sources (11)
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Researched and written by Auto Attendant Editorial with AI-assisted research tools; sources are cited inline and checked before publication. Report an error: https://autoattendant.io/contact/.