Emergency calling, honestly.

The plain statement first

That is the whole operational answer. The rest of this page explains the law it refers to, because if you are buying a business phone product you will meet these rules eventually and the summaries circulating online are frequently wrong about the dates.

The short legal answer is the same in both countries: the 911 rules govern calls a user places, and nobody can place a call through this service. Kari's Law covers calls a user initiates from a station with dialling facilities, the FCC's interconnected-VoIP 911 requirements apply "only to 911 calls placed by users", and the CRTC's 9-1-1 directions are about routing "a 9-1-1 call originating from a local VoIP service". Each section below quotes the rule.

Kari's Law: dial 911, not 9-911

Kari's Law is named for Kari Hunt, who was killed in a motel room in 2013 while her nine-year-old daughter tried repeatedly to call 911 and could not, because the motel's phone system required dialling 9 for an outside line first.

It became federal law on 16 February 20181 and is codified at 47 U.S.C. § 623. It does two things.

Direct dialling. A user must be able to reach 911 "without dialing any additional digit, code, prefix, or post-fix, including any trunk-access code such as the digit '9'".1 The FCC's implementing rule repeats it: a user must be able to "directly initiate a call to 911 from any station equipped with dialing facilities".2

On-site notification. The system must "provide a notification to a central location at the facility where the system is installed or to another person or organization regardless of location"1 — so that somebody on site knows a 911 call has been made and can meet the responders. The FCC adds quality requirements: the notification "must be initiated contemporaneously with the 911 call", "must not delay the call to 911", and "must be sent to a location where someone is likely to see or hear it."2

Note who is bound: not just operators. The rule separately binds "A person engaged in the business of manufacturing, importing, selling, or leasing multi-line telephone systems" and "A person engaged in the business of installing, managing, or operating multi-line telephone systems".2 If you configure a phone system for your own business, that second category can include you.

RAY BAUM'S Act: where, not just whether

Kari's Law makes sure the call connects. RAY BAUM'S Act § 506, enacted 23 March 2018,4 addresses the next problem: responders arriving at a building and not knowing which floor or room to go to.

It directed the FCC to ensure "that the dispatchable location is conveyed with a 9–1–1 call, regardless of the technological platform used",4 and defines dispatchable location as "the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location".4

The binding deadlines live in the FCC's rules rather than the statute, and there are four of them. Getting these confused is the single most common error in vendor content on this topic:

Scroll the table sideways to see every column.

Fixed on-premises phones must provide automated dispatchable location.2 For non-fixed and off-premises devices the rule is softer: automated location "when technically feasible", otherwise location "based on end user manual update, or alternative location information".2

What counts as an MLTS

This is the definition everything turns on, and it is broader than most people assume. From 47 CFR § 9.3:5

"A system comprised of common control units, telephone sets, control hardware and software and adjunct systems, including network and premises based systems, such as Centrex and VoIP, as well as PBX, Hybrid, and Key Telephone Systems … and includes systems owned or leased by governmental agencies and non-profit entities, as well as for profit businesses."

Two things are worth drawing out. It explicitly covers network-based and VoIP systems, not only a box on your premises. And it covers non-profits and government, not only companies.

The identical definition appears in statute at 47 U.S.C. § 1471 and is incorporated into Kari's Law by reference.7

The same section defines a "person engaged in the business of installing an MLTS" as one "that configures the MLTS or performs other tasks involved in getting the system ready to operate", including "establishing the dialing pattern for emergency calls".5 If you set up a phone system's dial plan, you may be in scope.

Kari's Law itself says what it regulates: a system configured so that "a user may directly initiate a call to 9–1–1 from any station equipped with dialing facilities".1 This service has no stations and no dialling facilities. Nobody can initiate any call through it, so there is no dial plan for 911 to sit in, and nothing for these rules to configure.

If you run a traditional office phone system with handsets on desks, the opposite is true: assume these rules are your problem and get advice.

The "interconnected VoIP" definition, and why it does not reach this service

A separate set of 911 duties attaches to "interconnected VoIP service", defined at 47 CFR § 9.3 as a service that:5

1. "Enables real-time, two-way voice communications";
2. "Requires a broadband connection from the user's location";
3. "Requires internet protocol-compatible customer premises equipment (CPE)"; and
4. "Permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network."

A second paragraph extends the definition, for 911 purposes only, to services meeting (i)–(iii) that "permit users generally to terminate calls to the public switched telephone network"5 — that is, outbound-capable services.

Those duties are substantial where they apply: obtaining a Registered Location before service starts, giving users a way to update it "at will and in a timely manner", advising every subscriber "prominently and in plain language" where E911 may be unavailable or limited, and keeping "a record of affirmative acknowledgement by every subscriber".6

What to ask any business phone vendor

One timing note worth carrying across: the FCC warns that wireless 911 location and callback services may be affected while a number is being transferred between providers, which we cover on porting your existing number and in the long-form article on how long porting takes.

Whoever you buy from, including us, these are the questions worth asking in writing:

• Can a user dial 911 directly from anything this service provides, with no prefix? If the service has no outbound dialling at all, say so explicitly.
• What location, if any, is transmitted with an emergency call, and how do I keep it current?
• If my people answer calls on mobiles, whose network carries their 911 calls?
• Does this product make me an MLTS operator? For anything users can dial out from, the answer depends on your setup, and a vendor that answers confidently without knowing it is guessing. A service nobody can call out from has no stations to configure.
• Where is your written 911 limitations notice? Any serious provider has one.

Canada: 9-1-1 and VoIP

In Canada the emergency number is 9-1-1 and the regulator is the CRTC. The CRTC's 9-1-1 duties for internet-based phone services attach to local VoIP service providers, which it defines by three tests: they "(i) provide their customers with telephone numbers that conform to the North American Numbering Plan, (ii) provide access to and from the public switched telephone network, and (iii) enable customers to make and/or receive calls that originate and terminate within an exchange or a local calling area." It adds that "a company's use of VoIP technology does not make the company a local VoIP service provider automatically."8 That page is a summary. The decision behind it, Telecom Decision CRTC 2005-21, words the definition more broadly: services that give subscribers "access to and/or from" the public network "along with the ability to make and/or receive calls" within a local calling area.9

Where they apply, the duties are three: provide Basic or Enhanced 9-1-1 service; tell customers about 9-1-1 limitations "upon sign-up and installation, in marketing materials, and in the terms of service", with the information "posted on the Web through an easily accessible link" (this second duty applies only to nomadic and fixed/non-native services); and register with the CRTC.8 The notice duty comes from Telecom Decision CRTC 2005-21, which also requires the customer's express consent to the limitations before service starts.9 Fixed services on a number native to the customer's area are exempt from the notice and consent requirements.10

The CRTC's consumer page adds two practical points: "All VoIP service providers are obligated to provide access to 9-1-1 services", and "during a power (unless battery back-up is provided) or an Internet outage, VoIP services, including 9-1-1, will be unavailable." Basic rather than Enhanced 9-1-1 is provided in Newfoundland and Labrador, Yukon and the Northwest Territories, and where 9-1-1 is not available, such as in Nunavut, emergency services are reached on an ordinary telephone number.11

Next-generation 9-1-1. The CRTC has directed all telecommunications providers to update their networks for NG9-1-1 voice by 31 March 2027,12 and directed the incumbent carriers to decommission the parts of the old E9-1-1 network that will not form part of NG9-1-1 by the same date; after it, providers not using NG9-1-1 will not be able to send 9-1-1 calls.13 A date for NG9-1-1 real-time text for the general public is still to be set.12 None of this changes anything for a team member dialling 9-1-1 from their own mobile: that call is their carrier's.

Elsewhere

The UK (999 and 112, regulated by Ofcom) and every other country have their own frameworks. We have not set them out here because the service is offered in the United States and Canada only.