New Federal Emergency Calling Requirements Take Effect For Enterprise Telephone Systems and Interconnected VoIP Services

ArentFox Schiff

Arent Fox

On January 6, 2021, the Federal Communications Commission’s (FCC) location requirements go into effect for fixed multi-line telephone systems (MLTS) and interconnected VoIP services, which now include outbound-only VoIP services for purposes of emergency calling.

As a result, companies managing their own enterprise communications systems and interconnected VoIP service providers must ensure that automatic dispatchable location information is enabled when any user attempts to place a 911 call through a fixed device (e.g., an office desktop phone). In practice, this means that when an emergency call is placed, the caller’s granular location must be automatically transmitted to the public safety answering point, including a validated street address, plus additional information such as suite, apartment number, or similar information necessary to adequately identify the location of the caller. Finally, for nomadic calling services – such as application-based MLTS services – separate dispatchable location requirements take effect exactly one year later, or on January 6, 2022.


The FCC’s current E911 rules stem from two federal laws: Kari’s Law Act of 2017 (Kari’s Law), which required implementation of direct 911 dialing and on-site notification capabilities in MLTS (which requirements are already in effect for non-grandfathered MLTS equipment), and Section 506 of RAY BAUM’S Act, which required the FCC to consider adopting rules to ensure that dispatchable location is conveyed with a 911 call, including calls made from MLTS.

Rules Applicable to Enterprise Telephone Systems

For MLTS services specifically, the FCC’s E911 rules only apply to such systems installed after February 16, 2020 or which were “substantially upgraded” after that date. In other words, systems installed before February 16, 2020 are grandfathered and do not have to comply with the new requirements – provided substantial upgrades are not made to the system

Enterprise telephone systems subject to the rules have to meet the following three standards:

1. Direct access to 911 without dialing any prefix, postfix, or trunk access code (e.g., MLTS systems cannot be programmed to require a caller dial “9” before placing a 911 call). 

2. Notify on-site security whenever 911 is dialed within the enterprise

  • Notifications must meet the following standards: 
    • They must be initiated contemporaneously with the 911 call, provided that it is technically feasible to do so; and
    • They must not delay the call to 911; and
    • They must be sent to a location where someone is likely to see or hear it.

3. Provide a dispatchable location with every 911 call

  • The compliance deadline for this component will depend on whether a fixed or nomadic device is at issue.

Deadline for fixed devices:

  • For fixed devices, the compliance deadline is Jan. 6, 2021
  • For fixed devices, the automated dispatchable location must be provided when dialing 911, no exceptions.

Deadline for nomadic devices:

  • For nomadic devices, the compliance deadline is Jan. 6, 2022. If feasible, provide automated dispatchable location information; otherwise, allow the user to update their location manually.

VoIP Providers

The FCC’s new E911 dispatchable location rules applicable to interconnected VoIP providers also go into effect on the same dates as for MLTS services, as detailed above. That is, for fixed interconnected VoIP services, providers must supply automated dispatchable locations with each 911 call no later than January 6, 2021. For non-fixed interconnected VoIP services, beginning January 6, 2022, service providers must supply automated dispatchable location, if technically feasible, or registered location information obtained by the customer, or alternative location information.


The FCC’s new MLTS rules impact managers and operators of multi-line telephone systems of all sizes across all industries, and this is the first time companies managing their telephone services are directly subject to federal emergency calling standards, with the potential for enforcement actions by the FCC. In addition, outbound-only VoIP services are no longer considered non-interconnected VoIP for purposes of the E911 rules, and thus one-way providers must ensure that they offer E911 compliant functionality.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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