# Canadian 9-1-1 obligations for VoIP and NG9-1-1 Canonical: https://warmtransfer.net/knowledge/canada-911-voip Last verified: 2026-10-14 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]. ## Customer notification and consent 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]. See also [NG911 and i3 architecture transition](https://warmtransfer.net/knowledge/ng911-transition) and [Real-time text and TTY accessibility requirements](https://warmtransfer.net/knowledge/rtt-tty-accessibility). ## 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]. See also [Dispatchable location and nomadic user handling](https://warmtransfer.net/knowledge/dispatchable-location). ## 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]. See also [Meeting Kari's Law and RAY BAUM's Act on an enterprise phone system](https://warmtransfer.net/knowledge/kari-ray-baum-compliance) and [State MLTS 911 laws beyond Kari's Law](https://warmtransfer.net/knowledge/mlts-state-911-laws). ## 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. ## Sources [^1]: TD 2007-44 directed Canadian carriers to use 0-ECRS (zero-dialed emergency call routing service) as the interim solution to route fixed/non-native and nomadic VoIP 9-1-1 calls to PSAPs. Source: [Telecom Decision CRTC 2007-44 - Routing of fixed/non-native and nomadic VoIP 9-1-1 calls to public safety answering points](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2007/dt2007-44.htm), para. 60. Checked 2026-10-14. [^2]: In TD 2007-44 the CRTC found 0-ECRS to be the only 9-1-1 call routing method on the record functionally comparable to Basic 9-1-1, and found low-priority lines and restricted numbers inappropriate as an interim solution. Source: [Telecom Decision CRTC 2007-44 - Routing of fixed/non-native and nomadic VoIP 9-1-1 calls to public safety answering points](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2007/dt2007-44.htm), paras. 37 and 57. Checked 2026-10-14. [^3]: The ESWG report approved in TD 2005-61 requires existing customers to receive the 9-1-1 limitation notification at least once per 12 month period. Source: [Telecom Decision CRTC 2005-61 - Follow-up to Emergency service obligations for local VoIP service providers (customer notification)](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2005/dt2005-61.htm), appended ESWG report ESRE039D paras. 4 and 9. Checked 2026-10-14. [^4]: In the application decided by TD 2025-291, Quebecor and Rogers asked the CRTC to move the NG9-1-1 and ILEC E9-1-1 decommissioning date to 4 March 2026 and to end an ILEC's E9-1-1 tariff in a region once 98% or more of traffic ran over NG9-1-1. Source: [Telecom Decision CRTC 2025-291 - Quebecor Media Inc. and Rogers Communications Canada Inc. application to review and vary Telecom Decision 2025-67](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2025/2025-291.htm), para. 7. Checked 2026-10-14. [^5]: The 2012 CRTC letter states that resellers offering VoIP must also obtain a Basic International Telecommunications Services (BITS) licence from the Commission. Source: [CRTC letter to Pelitel Inc. - local VoIP service provider obligations (with appendix listing 9-1-1 obligations)](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2012/lt121214.htm), letter body. Checked 2026-10-14. [^6]: TRP 2011-426 requires that, when a 9-1-1 call is disconnected before the caller's location is determined, the VSP operator use the telephone number provided by the VSP to attempt a callback as a last resort. Source: [Telecom Regulatory Policy CRTC 2011-426 - Provision of a 9-1-1 caller's telephone number to nomadic and fixed/non-native VoIP service providers' 9-1-1 operators](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2011/2011-426.htm), paras. 15 and 17. Checked 2026-10-14. [^7]: TRP 2011-426 requires nomadic and fixed/non-native VoIP service providers to implement, within 9 months, the capability to provide their VSP operators with the 9-1-1 caller's telephone number. Source: [Telecom Regulatory Policy CRTC 2011-426 - Provision of a 9-1-1 caller's telephone number to nomadic and fixed/non-native VoIP service providers' 9-1-1 operators](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2011/2011-426.htm), paras. 13 and 17. Checked 2026-10-14. [^8]: TRP 2011-426 requires Canadian carriers serving VSPs to include in their contracts a requirement that the VSP and any VSP reseller comply with the decision. Source: [Telecom Regulatory Policy CRTC 2011-426 - Provision of a 9-1-1 caller's telephone number to nomadic and fixed/non-native VoIP service providers' 9-1-1 operators](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2011/2011-426.htm), para. 18. Checked 2026-10-14. [^9]: TRP 2011-426 lets VSPs provide the caller's number to their VSP operator using either calling line identification (CLID) or automatic number identification (ANI). Source: [Telecom Regulatory Policy CRTC 2011-426 - Provision of a 9-1-1 caller's telephone number to nomadic and fixed/non-native VoIP service providers' 9-1-1 operators](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2011/2011-426.htm), para. 16. Checked 2026-10-14. [^10]: TRP 2017-182 originally directed ILECs to decommission 9-1-1 network components not forming part of their NG9-1-1 networks by 30 June 2023, or earlier if all TSPs and PSAPs in their territory had transitioned. Source: [Telecom Regulatory Policy CRTC 2017-182 - Next-generation 9-1-1 - Modernizing 9-1-1 networks to meet the public safety needs of Canadians](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2017/2017-182.htm), summary; para. 215. Checked 2026-10-14. [^11]: The ESWG notification report approved in TD 2005-61 includes user tips that 9-1-1 may be unavailable during a power outage or broadband Internet outage and that customers must keep their location information current with the VoIP provider. Source: [Telecom Decision CRTC 2005-61 - Follow-up to Emergency service obligations for local VoIP service providers (customer notification)](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2005/dt2005-61.htm), appended ESWG report ESRE039D para. 7. Checked 2026-10-14. [^12]: TD 2020-373 describes dispatchable location as the best location available at the time of a request, in civic or geodetic format or both. Source: [Telecom Decision CRTC 2020-373 - CISC Emergency Services Working Group - Consensus report ESRE0086 regarding dispatchable location from originating networks](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2020/2020-373.htm), para. 12. Checked 2026-10-14. [^13]: TD 2025-291 confirms the existing E9-1-1 rates and dual-rate model remain in place until decommissioning by 31 March 2027, or earlier if all TSPs and PSAPs in an ILEC's territory complete their transition. Source: [Telecom Decision CRTC 2025-291 - Quebecor Media Inc. and Rogers Communications Canada Inc. application to review and vary Telecom Decision 2025-67](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2025/2025-291.htm), para. 36. Checked 2026-10-14. [^14]: TD 2025-67 set 31 March 2027 as the new date for decommissioning the E9-1-1 networks in Canada. Source: [Telecom Decision CRTC 2025-67 - revised deadline for the transition to NG9-1-1](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2025/2025-67.htm), paras. 31 and 62. Checked 2026-10-14. [^15]: TD 2005-61 approved the CISC ESWG customer notification report ESRE039D (dated 21 July 2005) and directed carriers to comply with its requirements within 90 days. Source: [Telecom Decision CRTC 2005-61 - Follow-up to Emergency service obligations for local VoIP service providers (customer notification)](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2005/dt2005-61.htm), paras. 3 and 14. Checked 2026-10-14. [^16]: TD 2005-21 requires carriers to obtain the customer's express consent to the 9-1-1 limitations before service commences, using a method approved in TD 2005-15, with notices available in alternative formats on request. Source: [Telecom Decision CRTC 2005-21 - Emergency service obligations for local VoIP service providers](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2005/dt2005-21.htm), para. 98. Checked 2026-10-14. [^17]: TD 2020-373 requires TSPs to follow the appendix location request timing, except fixed services, which deliver a best location with the 9-1-1 call. Source: [Telecom Decision CRTC 2020-373 - CISC Emergency Services Working Group - Consensus report ESRE0086 regarding dispatchable location from originating networks](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2020/2020-373.htm), para. 22(2); appendix. Checked 2026-10-14. [^18]: In TD 2005-21 the CRTC uses 'fixed' to mean VoIP services without nomadic capability. Source: [Telecom Decision CRTC 2005-21 - Emergency service obligations for local VoIP service providers](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2005/dt2005-21.htm), para. 49. Checked 2026-10-14. [^19]: TD 2005-21 directed carriers offering fixed local VoIP with a number native to the customer's PSAP region to provide 9-1-1/E9-1-1 service, where available from the ILEC, within 90 days of the decision, including ALI database provisioning and routing to the correct PSAP. Source: [Telecom Decision CRTC 2005-21 - Emergency service obligations for local VoIP service providers](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2005/dt2005-21.htm), para. 52. Checked 2026-10-14. [^20]: TD 2011-619 determined that the 9-1-1 customer notification and express consent requirements of TDs 2005-21 and 2005-61 relate only to limitations specific to the 9-1-1 service and therefore do not apply to fixed/native VoIP services. Source: [Telecom Decision CRTC 2011-619 - Bell Aliant application regarding 9-1-1 customer notification and express consent for fixed/native VoIP](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2011/2011-619.htm), para. 12. Checked 2026-10-14. [^21]: Under TRP 2017-182 ILECs build, operate and maintain NG9-1-1 networks under Commission oversight, with tariff rates based on cost plus an approved markup, and may meet the obligation by outsourcing to another ILEC. Source: [Telecom Regulatory Policy CRTC 2017-182 - Next-generation 9-1-1 - Modernizing 9-1-1 networks to meet the public safety needs of Canadians](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2017/2017-182.htm), paras. 70 and 71. Checked 2026-10-14. [^22]: TD 2025-67 directs ILECs to decommission the E9-1-1 network components by the revised deadline. Source: [Telecom Decision CRTC 2025-67 - revised deadline for the transition to NG9-1-1](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2025/2025-67.htm), para. 32. Checked 2026-10-14. [^23]: TRP 2017-182 states that entities such as local VoIP providers and resellers, which reach 9-1-1 indirectly through trusted entities (ILECs, CLECs or mobile carriers), may continue to do so under NG9-1-1. Source: [Telecom Regulatory Policy CRTC 2017-182 - Next-generation 9-1-1 - Modernizing 9-1-1 networks to meet the public safety needs of Canadians](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2017/2017-182.htm), para. 104. Checked 2026-10-14. [^24]: 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, since legacy E9-1-1 components are to be removed and gateways are a funded last resort (inferred). Source: [Telecom Decision CRTC 2025-67 - revised deadline for the transition to NG9-1-1](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2025/2025-67.htm), paras. 5 and 32; read with TRP 2017-182 paras. 104 and 216. Checked 2026-10-14. [^25]: Compliance with US MLTS rules (Kari's Law and RAY BAUM'S Act dispatchable location) does not by itself map onto a Canadian legal requirement, because Canada had no MLTS-specific legislation and treated MLTS practices as encouraged best practices as of TD 2022-265 (inferred). Source: [Telecom Decision CRTC 2022-265 - CISC ESWG consensus report ESRE0074b - Proposal to manage multi-line telephone systems in the Canadian E9-1-1 or NG9-1-1 environment](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2022/2022-265.htm), paras. 14 18 and 26. Checked 2026-10-14. [^26]: TD 2005-21 requires carriers to give initial customer notification of any 9-1-1 limitations before service commencement, through channels such as marketing material, terms of service and starter kits. Source: [Telecom Decision CRTC 2005-21 - Emergency service obligations for local VoIP service providers](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2005/dt2005-21.htm), para. 93. Checked 2026-10-14. [^27]: TRP 2017-182 requires TSPs whose originating networks cannot support NG9-1-1 Voice to maintain the existing 9-1-1 voice service for the remaining life of that network. Source: [Telecom Regulatory Policy CRTC 2017-182 - Next-generation 9-1-1 - Modernizing 9-1-1 networks to meet the public safety needs of Canadians](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2017/2017-182.htm), para. 162. Checked 2026-10-14. [^28]: The MLTS best practices appended to TD 2022-265 state that dialing 9-1-1 from any MLTS without a prefix or code should be implemented and that on-site personnel should be notified of a 9-1-1 call in parallel without interrupting it. Source: [Telecom Decision CRTC 2022-265 - CISC ESWG consensus report ESRE0074b - Proposal to manage multi-line telephone systems in the Canadian E9-1-1 or NG9-1-1 environment](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2022/2022-265.htm), para. 13; appendix items 1.1 and 3.1. Checked 2026-10-14. [^29]: In TD 2022-265 the CRTC encourages, rather than requires, TSPs and MLTS providers to adopt the ESWG MLTS 9-1-1 best practices. Source: [Telecom Decision CRTC 2022-265 - CISC ESWG consensus report ESRE0074b - Proposal to manage multi-line telephone systems in the Canadian E9-1-1 or NG9-1-1 environment](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2022/2022-265.htm), para. 26. Checked 2026-10-14. [^30]: TRP 2017-182 records the Commission's approval of the NENA i3 architecture standard for NG9-1-1 in Canada. Source: [Telecom Regulatory Policy CRTC 2017-182 - Next-generation 9-1-1 - Modernizing 9-1-1 networks to meet the public safety needs of Canadians](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2017/2017-182.htm), para. 16. Checked 2026-10-14. [^31]: TRP 2017-182 requires TSPs to ensure emergency-related data is used only to respond to 9-1-1 communications, subject to express consent or a legal order, and to set retention and destruction procedures flowed down to third parties. Source: [Telecom Regulatory Policy CRTC 2017-182 - Next-generation 9-1-1 - Modernizing 9-1-1 networks to meet the public safety needs of Canadians](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2017/2017-182.htm), paras. 232 and 233. Checked 2026-10-14. [^32]: In a 6 May 2026 speech, CRTC Commissioner Bram Abramson said there are no plans to extend the 31 March 2027 NG9-1-1 deadline further. Source: [Bram Abramson to the National Emergency Number Association ON (speech)](https://www.canada.ca/en/radio-television-telecommunications/news/2026/05/bram-abramson-to-the-national-emergency-number-association-on.html), passage on the deadline. Checked 2026-10-14. [^33]: TD 2022-265 notes that Canada, unlike the United States, has no MLTS-specific 9-1-1 legislation. Source: [Telecom Decision CRTC 2022-265 - CISC ESWG consensus report ESRE0074b - Proposal to manage multi-line telephone systems in the Canadian E9-1-1 or NG9-1-1 environment](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2022/2022-265.htm), para. 14. Checked 2026-10-14. [^34]: Under TD 2005-21 the interim nomadic and fixed/non-native VoIP solution must not route 9-1-1 calls to a PSAP that does not serve the caller's location. Source: [Telecom Decision CRTC 2005-21 - Emergency service obligations for local VoIP service providers](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2005/dt2005-21.htm), para. 68. Checked 2026-10-14. [^35]: TD 2020-373 states in background that nomadic VoIP calls are routed to a third-party operator who routes them to the appropriate PSAP, and that nomadic VoIP provides basic 9-1-1 because there is no fixed address to give 9-1-1 operators. Source: [Telecom Decision CRTC 2020-373 - CISC Emergency Services Working Group - Consensus report ESRE0086 regarding dispatchable location from originating networks](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2020/2020-373.htm), para. 2; footnote 4. Checked 2026-10-14. [^36]: TD 2005-21 directed carriers supporting nomadic or fixed/non-native local VoIP to implement within 90 days an interim 9-1-1 solution functionally comparable to Basic 9-1-1 service. Source: [Telecom Decision CRTC 2005-21 - Emergency service obligations for local VoIP service providers](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2005/dt2005-21.htm), para. 68. Checked 2026-10-14. [^37]: TNC 2023-156 states 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. Source: [Telecom Notice of Consultation CRTC 2023-156 - Call for comments: Enabling direct 9-1-1 and 9-8-8 calls from multi-line telephone systems](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2023/2023-156.htm), paras. 15 and 21. Checked 2026-10-14. [^38]: TD 2005-61 requires local VoIP providers to use at minimum 12 point font for 9-1-1 limitation text in terms of service, websites, contracts and starter kits, and at least the size of the main marketing text in TV, print and online advertising. Source: [Telecom Decision CRTC 2005-61 - Follow-up to Emergency service obligations for local VoIP service providers (customer notification)](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2005/dt2005-61.htm), para. 12. Checked 2026-10-14. [^39]: TD 2005-61 requires local VoIP providers to submit proposed 9-1-1 customer notification texts to the Commission for review before use, with new entrants submitting before offering service. Source: [Telecom Decision CRTC 2005-61 - Follow-up to Emergency service obligations for local VoIP service providers (customer notification)](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2005/dt2005-61.htm), paras. 9 15 and 16. Checked 2026-10-14. [^40]: TD 2005-21 requires on-going customer notification of 9-1-1 limitations during service provision, including warning stickers affixed to telephone sets and billing inserts. Source: [Telecom Decision CRTC 2005-21 - Emergency service obligations for local VoIP service providers](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2005/dt2005-21.htm), para. 94. Checked 2026-10-14. [^41]: Under TD 2025-67 originating network providers continue paying ILEC wholesale tariff rates for both E9-1-1 and NG9-1-1 networks until E9-1-1 decommissioning. Source: [Telecom Decision CRTC 2025-67 - revised deadline for the transition to NG9-1-1](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2025/2025-67.htm), paras. 3 35 and 51. Checked 2026-10-14. [^42]: TD 2011-619 characterizes unavailability of service during power or broadband outages as a characteristic of the VoIP service rather than of the 9-1-1 service itself. Source: [Telecom Decision CRTC 2011-619 - Bell Aliant application regarding 9-1-1 customer notification and express consent for fixed/native VoIP](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2011/2011-619.htm), para. 10. Checked 2026-10-14. [^43]: Before TD 2025-67 the E9-1-1 decommissioning deadline was 4 March 2025. Source: [Telecom Decision CRTC 2025-67 - revised deadline for the transition to NG9-1-1](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2025/2025-67.htm), summary; para. 61. Checked 2026-10-14. [^44]: 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. Source: [Next-generation 9-1-1](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2026/https://crtc.gc.ca/eng/phone/911/gen.htm), main body. Checked 2026-10-14. [^45]: The 6 May 2026 CRTC speech states that under the contingency framework PSAPs must notify their network provider by 31 December 2026 if they need a contingency plan. Source: [Bram Abramson to the National Emergency Number Association ON (speech)](https://www.canada.ca/en/radio-television-telecommunications/news/2026/05/bram-abramson-to-the-national-emergency-number-association-on.html), passage on the contingency framework. Checked 2026-10-14. [^46]: As of its 2025-02-28 revision, the CRTC's NG9-1-1 consumer page states that a deadline for providing NG9-1-1 real-time text messaging to the general public will be set at a later date. Source: [Next-generation 9-1-1](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2026/https://crtc.gc.ca/eng/phone/911/gen.htm), main body. Checked 2026-10-14. [^47]: Per the 2012 CRTC letter citing TD 2005-28, local VoIP providers not operating as carriers must register with the Commission as resellers, and those operating over their own facilities must register as CLECs. Source: [CRTC letter to Pelitel Inc. - local VoIP service provider obligations (with appendix listing 9-1-1 obligations)](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2012/lt121214.htm), appendix section iii; letter body. Checked 2026-10-14. [^48]: In TD 2025-291 (3 November 2025) the CRTC denied the Quebecor and Rogers application to review and vary TD 2025-67, leaving the 31 March 2027 deadline in place. Source: [Telecom Decision CRTC 2025-291 - Quebecor Media Inc. and Rogers Communications Canada Inc. application to review and vary Telecom Decision 2025-67](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2025/2025-291.htm), paras. 36 and 49. Checked 2026-10-14. [^49]: TRP 2017-182 requires TSPs to route NG9-1-1 traffic to primary PSAPs over ILEC NG9-1-1 networks. Source: [Telecom Regulatory Policy CRTC 2017-182 - Next-generation 9-1-1 - Modernizing 9-1-1 networks to meet the public safety needs of Canadians](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2017/2017-182.htm), para. 72. Checked 2026-10-14. [^50]: Section 24.1 of the Telecommunications Act makes telecommunications services offered by persons other than Canadian carriers subject to CRTC-imposed conditions, expressly including conditions relating to access to emergency services. Source: [Telecommunications Act (S.C. 1993 c. 38) - sections 24 and 24.1](https://laws-lois.justice.gc.ca/eng/acts/t-3.4/page-4.html), s. 24.1(c). Checked 2026-10-14. [^51]: A 2012 CRTC compliance letter summarizes three obligations for local VoIP service providers: provide 9-1-1 service, notify customers of 9-1-1 limitations, and register with the Commission. Source: [CRTC letter to Pelitel Inc. - local VoIP service provider obligations (with appendix listing 9-1-1 obligations)](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2012/lt121214.htm), letter body; appendix sections i ii iii. Checked 2026-10-14. [^52]: CRTC Telecom Decision 2005-21 distinguishes three local VoIP 9-1-1 configurations: fixed with a telephone number native to an exchange in the PSAP region (fixed/native), fixed with a non-native number (fixed/non-native), and nomadic service where the customer does not necessarily call from a fixed address. Source: [Telecom Decision CRTC 2005-21 - Emergency service obligations for local VoIP service providers](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2005/dt2005-21.htm), para. 48. Checked 2026-10-14. [^53]: In TNC 2023-156 (23 May 2023) the CRTC stated its aim to move beyond voluntary MLTS rules toward legally enforceable rules on direct 9-1-1 and 9-8-8 dialing, routing and dispatchable location information. Source: [Telecom Notice of Consultation CRTC 2023-156 - Call for comments: Enabling direct 9-1-1 and 9-8-8 calls from multi-line telephone systems](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2023/2023-156.htm), paras. 13 and 17. Checked 2026-10-14. [^54]: TD 2007-44 records that most VoIP service providers use a third-party operator (TPO) call centre to deliver 9-1-1 calls, and that the intermediary may be the provider's internal call centre or a TPO. Source: [Telecom Decision CRTC 2007-44 - Routing of fixed/non-native and nomadic VoIP 9-1-1 calls to public safety answering points](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2007/dt2007-44.htm), paras. 10 and 54. Checked 2026-10-14. [^55]: TD 2020-373 directs TSPs to deliver the most accurate dispatchable location available (geodetic, validated civic, or both) to the PSAP call handling element when requested automatically or manually. Source: [Telecom Decision CRTC 2020-373 - CISC Emergency Services Working Group - Consensus report ESRE0086 regarding dispatchable location from originating networks](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2020/2020-373.htm), para. 22(1). Checked 2026-10-14. [^56]: TRP 2017-182 states that TSP and PSAP gateways are not part of NG9-1-1 networks, should be used only as a last resort, and are funded by the TSPs and PSAPs that use them. Source: [Telecom Regulatory Policy CRTC 2017-182 - Next-generation 9-1-1 - Modernizing 9-1-1 networks to meet the public safety needs of Canadians](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2017/2017-182.htm), para. 216. Checked 2026-10-14. [^57]: TRP 2017-182 originally directed TSPs to make the changes needed to support NG9-1-1 Voice in their originating networks by 30 June 2020, where network-capable. Source: [Telecom Regulatory Policy CRTC 2017-182 - Next-generation 9-1-1 - Modernizing 9-1-1 networks to meet the public safety needs of Canadians](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2017/2017-182.htm), para. 162. Checked 2026-10-14. [^58]: TD 2022-265 directs TSPs to inform MLTS providers about the MLTS 9-1-1 best practices, with an implementation date of 27 March 2023. Source: [Telecom Decision CRTC 2022-265 - CISC ESWG consensus report ESRE0074b - Proposal to manage multi-line telephone systems in the Canadian E9-1-1 or NG9-1-1 environment](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2022/2022-265.htm), para. 26. Checked 2026-10-14. [^59]: TD 2025-67 states that an originating network provider or PSAP not transitioned to NG9-1-1 by the deadline will be responsible for the gateways (LNGs and LPGs respectively) within its network. Source: [Telecom Decision CRTC 2025-67 - revised deadline for the transition to NG9-1-1](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2025/https://crtc.gc.ca/eng/archive/2025/2025-67.htm), para. 5. Checked 2026-10-14. [^60]: 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 networks were capable. Source: [Telecom Regulatory Policy CRTC 2017-182 - Next-generation 9-1-1 - Modernizing 9-1-1 networks to meet the public safety needs of Canadians](https://webarchiveweb.wayback.bac-lac.canada.ca/web/2024/https://crtc.gc.ca/eng/archive/2017/2017-182.htm), para. 182. Checked 2026-10-14.