emergency calling · published

Canadian 9-1-1 obligations for VoIP and NG9-1-1

Verified 2026-10-14 · 60 sources · tier 1 · 2 superseded

Also known as canada-ng911, crtc-voip-911.

Superseded guidance: 2 sources have been superseded by newer ones.

CRTC Telecom Decision 2005-21 distinguishes 3 local VoIP 9-1-1 configurations: fixed/native, fixed/non-native, and nomadic service, where the customer does not necessarily call from a fixed address 52. TD 2025-67 sets 31 March 2027 as the date for decommissioning the E9-1-1 networks in Canada 14.

Service configurations

In TD 2005-21 the CRTC uses "fixed" to mean VoIP services without nomadic capability 18. A fixed/native service uses a telephone number native to an exchange in the PSAP region 52. A fixed/non-native service uses a fixed number that is not native to that region 52.

A 2012 CRTC compliance letter summarizes 3 obligations for local VoIP service providers 51:

provide 9-1-1 service 51
notify customers of 9-1-1 limitations 51
register with the Commission 51

Legacy 9-1-1 routing obligations

TD 2005-21 directed carriers offering fixed/native local VoIP to provide 9-1-1/E9-1-1 service, where available from the ILEC, within 90 days of the decision 19. That obligation includes ALI database provisioning and routing to the correct PSAP 19.

Carriers supporting nomadic or fixed/non-native local VoIP were directed to implement, within 90 days, an interim 9-1-1 solution functionally comparable to Basic 9-1-1 service 36. That interim solution must not route 9-1-1 calls to a PSAP that does not serve the caller's location 34.

TD 2007-44 directed Canadian carriers to use 0-ECRS (zero-dialed emergency call routing service) as the interim solution for routing fixed/non-native and nomadic VoIP 9-1-1 calls to PSAPs 1. In that decision the CRTC found 0-ECRS to be the only routing method on the record that was functionally comparable to Basic 9-1-1 2. It also found low-priority lines and restricted numbers inappropriate as an interim solution 2.

TD 2007-44 records that most VoIP service providers use a third-party operator (TPO) call centre to deliver 9-1-1 calls 54. It also records that the intermediary may be either the provider's internal call centre or a TPO 54.

TD 2020-373 states in its background that nomadic VoIP calls are routed to a third-party operator, who routes them to the appropriate PSAP 35. It also states that nomadic VoIP provides basic 9-1-1 because there is no fixed address to give 9-1-1 operators 35.

Caller number and callback

TRP 2011-426 requires nomadic and fixed/non-native VoIP service providers to implement, within 9 months, the capability to give their VSP operators the 9-1-1 caller's telephone number 7. VSPs may provide that number using either calling line identification (CLID) or automatic number identification (ANI) 9.

If a 9-1-1 call is disconnected before the caller's location is determined, the VSP operator must use the number provided by the VSP to attempt a callback as a last resort 6. Canadian carriers serving VSPs must include a contract requirement that the VSP and any VSP reseller comply with the decision 8.

TD 2005-21 requires initial notification, ongoing notification and express consent 26 40 16:

Initial notification: carriers must notify customers of any 9-1-1 limitations before service starts, through channels such as marketing material, terms of service and starter kits 26.
Ongoing notification: carriers must continue to notify customers during service, including warning stickers affixed to telephone sets and billing inserts 40.
Express consent: carriers must obtain the customer's express consent to the 9-1-1 limitations before service starts, using a method approved in TD 2005-15 16. Notices must be available in alternative formats on request 16.

TD 2005-61 approved the CISC ESWG customer notification report ESRE039D, dated 21 July 2005, and directed carriers to comply with it within 90 days 15. That report requires existing customers to receive the 9-1-1 limitation notification at least once per 12 month period 3. Its user tips warn that 9-1-1 may be unavailable during a power outage or broadband Internet outage 11. The tips also tell customers to keep their location information current with the VoIP provider 11.

TD 2005-61 sets minimum font sizes for 9-1-1 limitation text 38:

at least 12 point font in terms of service, websites, contracts and starter kits 38
at least the size of the main marketing text in TV, print and online advertising 38

Local VoIP providers must submit proposed 9-1-1 notification texts to the Commission for review before using them 39. New entrants must submit them before offering service 39.

TD 2011-619 determined that these notification and consent requirements relate only to limitations specific to the 9-1-1 service, and therefore do not apply to fixed/native VoIP services 20. The same decision characterizes loss of service during power or broadband outages as a characteristic of the VoIP service, not of the 9-1-1 service itself 42.

Registration and legal basis

According to the 2012 CRTC letter citing TD 2005-28, registration depends on how the provider operates 47:

providers not operating as carriers must register with the Commission as resellers 47
providers operating over their own facilities must register as CLECs 47

Section 24.1 of the Telecommunications Act makes services offered by persons other than Canadian carriers subject to CRTC-imposed conditions, expressly including conditions relating to access to emergency services 50.

NG9-1-1 framework

TRP 2017-182 records the Commission's approval of the NENA i3 architecture standard for NG9-1-1 in Canada 30. ILECs build, operate and maintain NG9-1-1 networks under Commission oversight 21. Their tariff rates are based on cost plus an approved markup, and an ILEC may meet the obligation by outsourcing to another ILEC 21.

TSPs must route NG9-1-1 traffic to primary PSAPs over ILEC NG9-1-1 networks 49. Local VoIP providers and resellers that reach 9-1-1 indirectly through trusted entities (ILECs, CLECs or mobile carriers) may continue to do so under NG9-1-1 23.

TSPs whose originating networks cannot support NG9-1-1 Voice must maintain the existing 9-1-1 voice service for the remaining life of that network 27. TSP and PSAP gateways are not part of NG9-1-1 networks 56. They should be used only as a last resort and are funded by the TSPs and PSAPs that use them 56.

TSPs must ensure that emergency-related data is used only to respond to 9-1-1 communications, unless the customer gives express consent or a legal order applies 31. TSPs must also set retention and destruction procedures and flow them down to third parties 31.

TRP 2017-182 directed mobile wireless carriers to support RTT-based NG9-1-1 Text Messaging throughout their operating territories by 31 December 2020, where their networks were capable 60. As of its 2025-02-28 revision, the CRTC's NG9-1-1 consumer page states that a deadline for NG9-1-1 real-time text messaging to the general public will be set later 46.

Location delivery

TD 2020-373 describes dispatchable location as the best location available at the time of a request, in civic format, geodetic format, or both 12. TSPs must deliver the most accurate dispatchable location available (geodetic, validated civic, or both) to the PSAP call handling element when it is requested, automatically or manually 55.

TSPs must follow the location request timing in the decision's appendix 17. Fixed services are the exception: they deliver a best location with the 9-1-1 call 17.

Transition deadline

Before TD 2025-67, the E9-1-1 decommissioning deadline was 4 March 2025 43. TD 2025-67 set 31 March 2027 as the new decommissioning date 14. It directs ILECs to decommission the E9-1-1 network components by that deadline 22.

An originating network provider or PSAP that has not transitioned to NG9-1-1 by the deadline will be responsible for the gateways within its network 59:

LNGs for originating network providers 59
LPGs for PSAPs 59

Originating network providers continue paying ILEC wholesale tariff rates for both E9-1-1 and NG9-1-1 networks until E9-1-1 decommissioning 41. The CRTC's NG9-1-1 consumer page states that all telecommunications providers were directed to update their networks for NG9-1-1 voice services by 31 March 2027 44.

In the application decided by TD 2025-291, Quebecor and Rogers asked the CRTC to 4:

move the NG9-1-1 and ILEC E9-1-1 decommissioning date to 4 March 2026 4
end an ILEC's E9-1-1 tariff in a region once 98% or more of traffic ran over NG9-1-1 4

In TD 2025-291, dated 3 November 2025, the CRTC denied that application and left the 31 March 2027 deadline in place 48. TD 2025-291 confirms that the existing E9-1-1 rates and dual-rate model remain until decommissioning by 31 March 2027 13. They can end earlier in an ILEC's territory if all TSPs and PSAPs there complete their transition 13.

In a 6 May 2026 speech, CRTC Commissioner Bram Abramson said there are no plans to extend the 31 March 2027 deadline further 32.

WarmTransfer's reading of the sources is that, after E9-1-1 decommissioning, a Canadian local VoIP provider will need to deliver 9-1-1 traffic either over its own NG9-1-1 interconnection or through an upstream trusted entity that has one 24. This is inferred from the fact that legacy E9-1-1 components are to be removed and gateways are a funded last resort 24.

Multi-line telephone systems

TD 2022-265 notes that Canada, unlike the United States, has no MLTS-specific 9-1-1 legislation 33. In that decision the CRTC encourages, but does not require, TSPs and MLTS providers to adopt the ESWG MLTS 9-1-1 best practices 29. It directs TSPs to inform MLTS providers about those best practices, with an implementation date of 27 March 2023 58.

The best practices appended to TD 2022-265 state that dialing 9-1-1 from any MLTS without a prefix or code should be implemented 28. They also state that on-site personnel should be notified of a 9-1-1 call in parallel, without interrupting the call 28.

In TNC 2023-156, dated 23 May 2023, the CRTC stated its aim to move beyond voluntary MLTS rules toward legally enforceable rules 53. Those rules would cover direct 9-1-1 and 9-8-8 dialing, routing, and dispatchable location information 53. TNC 2023-156 states that the Commission may impose MLTS-related obligations on Canadian carriers under section 24, and on any person offering a telecommunications service, including resellers, under section 24.1 of the Telecommunications Act 37.

We infer that complying with US MLTS rules (Kari's Law and RAY BAUM'S Act dispatchable location) does not by itself satisfy a Canadian legal requirement 25. We infer this because Canada had no MLTS-specific legislation and treated MLTS practices as encouraged best practices as of TD 2022-265 25.

Applicability

Applies to: Canadian 9-1-1 obligations for VoIP and NG9-1-1. Deployments: fixed, fixed-native, fixed-non-native, mlts, nomadic, and wireless. Sources checked 2026-10-14. The 9-1-1 customer notification and express consent requirements of TDs 2005-21 and 2005-61 do not apply to fixed/native VoIP services 20. The MLTS 9-1-1 best practices in TD 2022-265 are encouraged rather than required 29. The location request timing in TD 2020-373's appendix applies to TSPs other than fixed services, which deliver a best location with the 9-1-1 call 17. The statement on the NG9-1-1 real-time text deadline for the general public comes from the CRTC consumer page as revised on 2025-02-28 46.

What remains uncertain

Whether the consultation opened in TNC 2023-156 has produced legally enforceable MLTS rules is not covered by the sources below. Whether 0-ECRS routing for nomadic and fixed/non-native VoIP continues after E9-1-1 decommissioning is not covered by the sources below. The technical interconnection requirements a local VoIP provider must meet to originate NG9-1-1 Voice directly are not covered by the sources below. How specific enterprise UC, hosted voice, or contact center platforms implement these Canadian obligations is not covered by the sources below.