Track Your Company’s NG911 Compliance Dates

The Federal Communications Commission’s Report and Order released last year which established new rules governing the provision of next generation 911 (NG911) services contained a requirement that originating service providers (OSPs) – defined as providers that originate 911 traffic, including wireline providers, commercial mobile radio service (CMRS) providers, covered text providers, and interconnected Voice over Internet Protocol providers – transition to NG911. As part of this requirement, OSPs must comply within specified time periods to a request for Phase 1 or Phase 2 NG911 service made by a 911 Authority.¹ 911 Authorities have begun to make such requests, which they may do filing such requests in FCC Docket No. 25-143.

A summary of requests submitted as of August 27 is attached here. 911 Authorities are not required to identify OSPs subject to the request and may instead identify only affected counties.

Rural local exchange carriers and non-nationwide CMRS providers in receipt of a valid NG911 Phase I request must comply with the request within 12 months of receipt. Under Phase I, OSPs will be required to deliver 911 traffic in a basic session initiation protocol (SIP) format. OSPs in receipt of a Phase 1 request have the ability to challenge such request within 60 days of receipt. OSPs in receipt of such a request who are concerned about their ability to meet the one-year deadline should consider seeking a waiver from the FCC.

Effective October 1, 2025, Womble Bond Dickinson (WBD) will provide a bi-weekly update of the list of NG911 requests and related deadlines to requesting entities.  If you would like to receive such updates, please click on the following link to register.

As an OSP, you remain responsible for ensuring that you are aware of all applicable requests from relevant 911 Authorities. Registering for this service will keep you abreast of the deadlines and requirements based on information provided by the FCC.

If you need assistance in responding to a NG911 request or seeking a waiver from the FCC, please contact Michael Bennet at [email protected]. 

¹ A 911 Authority is “[a] State, territorial, regional, Tribal, or local governmental entity that operates or has administrative authority over all or any aspect of a communications network for the receipt of 911 traffic at NG911 Delivery Points and for the transmission of such traffic from that point to PSAP” (public safety answering point). 47 C.F.R. §9.28.