Text-to-911 availability and enterprise implications

See also

Sources

1. 1
   FCC 14-118 excluded text messaging services that use U.S. telephone numbers only for administrative or identification purposes and are not interconnected.

   Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications; Framework for Next Generation 911 Deployment - Second Report and Order and Third Further Notice of Proposed Rulemaking (FCC 14-118) · paragraph 35, footnote 96 · Checked 2026-10-14
2. 2
   Covered text providers that rely on device-based location which the consumer must activate must clearly inform consumers that they have to grant the text application access to location, and must send a bounce-back if access is denied.

   47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(10)(i) · Checked 2026-10-14
3. 3
   A software application provider that sends texts directly into the CMRS SMS network meets the bounce-back requirement if it does not prevent or inhibit delivery of the CMRS provider's bounce-back message to the consumer.

   47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(8) · Checked 2026-10-14
4. 4
   Because the routing duty is triggered only by a PSAP's valid request and the 911 authority's authorization, text-to-911 reaches a PSAP only where that PSAP has opted in; federal rules do not make it available everywhere in the US.inferred

   47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(10)(ii)-(iii) · Checked 2026-10-14
5. 5
   The provider of a preinstalled or downloadable interconnected text application is considered to control transmission for bounce-back purposes unless a user or third party modified the application so that it no longer supports bounce-back.

   47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(4)(ii) · Checked 2026-10-14
6. 6
   No bounce-back is required when a consumer texts 911 through a text messaging application that requires CMRS service from a handset that is not service-initialized.

   47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(4)(i)(B) · Checked 2026-10-14
7. 7
   No bounce-back is required where the provider does not control transmission of the text message.

   47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(4)(i)(A) · Checked 2026-10-14
8. 8
   No bounce-back is required when a consumer texts 911 from a device that cannot send texts to three-digit short codes and cannot be upgraded over the air to do so.

   47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(4)(i)(D) · Checked 2026-10-14
9. 9
   No bounce-back is required when a 911 text cannot be delivered because of a failure in the PSAP network that was not reported to the provider.

   47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(4)(i)(C) · Checked 2026-10-14
10. 10
    At a minimum, the automatic bounce-back message must tell the consumer that text-to-911 is not available and advise them to use another means to contact emergency services.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(5) · Checked 2026-10-14
11. 11
    Since no later than September 30, 2013, covered text providers must send an automatic bounce-back message when a consumer texts 911 and the provider cannot deliver it because text-to-911 is unavailable in that area or the provider does not support it.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(3) · Checked 2026-10-14
12. 12
    Text messages sent directly to 9-1-1 do not reach emergency services anywhere in Canada; senders get an automatic reply telling them to call 9-1-1.

    FAQs | TEXT with 9-1-1 (T9-1-1) · FAQ: texting 9-1-1 directly · Checked 2026-10-14
13. 13
    In Canada, the T9-1-1 service is intended only for Deaf, Deafened, hard of hearing or speech-impaired persons.

    FAQs | TEXT with 9-1-1 (T9-1-1) · FAQ: who can use T9-1-1 · Checked 2026-10-14
14. 14
    A person who wants to use Canada's T9-1-1 service must register for it with their wireless service provider.

    FAQs | TEXT with 9-1-1 (T9-1-1) · FAQ: registration · Checked 2026-10-14
15. 15
    Under T9-1-1 the user first places a voice call to 9-1-1, which establishes direct contact with the 9-1-1 centre and gives the call taker the caller's number and approximate location.

    FAQs | TEXT with 9-1-1 (T9-1-1) · FAQ: why a voice call is needed · Checked 2026-10-14
16. 16
    The 47 CFR 9.10(q) text-to-911 provisions read the same in the CFR editions revised as of October 1, 2024 and October 1, 2025 for the paragraphs compared: the covered text provider definition, bounce-back, roaming, routing deadline and exemptions.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2024) · 47 CFR 9.10(q)(1), (q)(3), (q)(4), (q)(7), (q)(10)(ii), (q)(10)(iv) · Checked 2026-10-14
17. 17
    CMRS providers that offer SMS must let other covered text providers access the capabilities needed to transmit their 911 texts, but they may migrate to other technologies and need not keep SMS networks solely for other providers' 911 use.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(11) · Checked 2026-10-14
18. 18
    FCC 14-118 describes covered text providers routing texts to 911 using coarse location, meaning cell ID and cell sector.

    Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications; Framework for Next Generation 911 Deployment - Second Report and Order and Third Further Notice of Proposed Rulemaking (FCC 14-118) · paragraph 57 · Checked 2026-10-14
19. 19
    Under 47 CFR 9.10(q)(1) a covered text provider includes all CMRS providers and all providers of interconnected text messaging services that let consumers send texts to and receive texts from all or substantially all text-capable U.S. telephone numbers, including through downloaded or installed apps.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(1) · Checked 2026-10-14
20. 20
    Because 47 CFR 9.10(q)(1) defines covered text providers by services that let consumers text substantially all numbers, and Microsoft classifies Teams SMS as non-consumer A2P, an enterprise cannot assume Teams SMS carries the text-to-911 routing or bounce-back obligations.inferred

    Planning for SMS in Microsoft Teams · Overview; read with 47 CFR 9.10(q)(1) · Checked 2026-10-14
21. 21
    The text-to-911 routing, location and valid-request requirements do not apply to in-flight text messaging providers, MSS providers, or IP Relay service providers.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(10)(iv) · Checked 2026-10-14
22. 22
    The text-to-911 routing requirements also do not apply to 911 texts that originate from Wi-Fi-only locations or from devices that cannot access the CMRS network.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(10)(iv) · Checked 2026-10-14
23. 23
    The FCC's text-to-911 Second Report and Order, FCC 14-118 in PS Docket Nos. 11-153 and 10-255, was adopted August 8, 2014 and released August 13, 2014.

    Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications; Framework for Next Generation 911 Deployment - Second Report and Order and Third Further Notice of Proposed Rulemaking (FCC 14-118) · caption block, page 1 · Checked 2026-10-14
24. 24
    A PSAP can satisfy the notification element of a valid request by registering in a database made available by the Commission, or by other written notice reasonably acceptable to the covered text provider.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(10)(iii)(C) · Checked 2026-10-14
25. 25
    No later than January 6, 2022, covered text providers must send location with 911 texts: automated dispatchable location if technically feasible, and otherwise either end-user manual provision of location or enhanced location information, which may be coordinate-based.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(10)(v)(A)-(C) · Checked 2026-10-14
26. 26
    FCC 14-118 excluded mobile satellite service from text-to-911 partly because it described MSS as a specialized offering focused on enterprise and government users.

    Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications; Framework for Next Generation 911 Deployment - Second Report and Order and Third Further Notice of Proposed Rulemaking (FCC 14-118) · paragraph 35, footnote 96 · Checked 2026-10-14
27. 27
    47 CFR 9.30 sets no calendar deadline for NG911 Phase 1 or Phase 2; every deadline runs from a 911 Authority's valid request or from the Phase 1 dates.

    47 CFR 9.30 Next Generation 911 implementation deadlines (edition revised as of October 1, 2025) · 47 CFR 9.30(a)-(b) · Checked 2026-10-14
28. 28
    For the FCC's Next Generation 911 rules, originating service providers expressly include covered text providers as defined in 47 CFR 9.10(q)(1), alongside wireline, CMRS, interconnected VoIP and internet-based TRS providers.

    47 CFR 9.28 Definitions (Subpart J Next Generation 911; edition revised as of October 1, 2025) · 47 CFR 9.28, definition of Originating service providers · Checked 2026-10-14
29. 29
    In NG911 Phase 1, once a 911 Authority makes a valid request, an originating service provider must deliver all 911 traffic for the relevant PSAPs in the IP-based SIP format the authority requests, to NG911 Delivery Points the authority designates, and must complete connectivity testing.

    47 CFR 9.29 Next Generation 911 transition requirements (edition revised as of October 1, 2025) · 47 CFR 9.29(a)(1), (a)(3), (a)(4) · Checked 2026-10-14
30. 30
    In NG911 Phase 2, an originating service provider must deliver 911 traffic in a SIP format that complies with commonly accepted NG911 standards, with location information embedded in the call signaling, using a Location Information Server or its functional equivalent.

    47 CFR 9.29 Next Generation 911 transition requirements (edition revised as of October 1, 2025) · 47 CFR 9.29(b)(2)-(b)(3) · Checked 2026-10-14
31. 31
    Under 47 CFR 9.30(a), covered text providers, like non-rural wireline, nationwide CMRS and interconnected VoIP providers, must meet NG911 Phase 1 within six months of a valid Phase 1 request; RLECs, non-nationwide CMRS and internet-based TRS providers get 12 months under 9.30(b).

    47 CFR 9.30 Next Generation 911 implementation deadlines (edition revised as of October 1, 2025) · 47 CFR 9.30(a)(1) and (b)(1), introductory text · Checked 2026-10-14
32. 32
    The NG911 rules define 911 traffic as all 911 calls and/or 911 text messages as defined in 47 CFR 9.10(q)(9), together with the location, originating number and routing information sent with them.

    47 CFR 9.28 Definitions (Subpart J Next Generation 911; edition revised as of October 1, 2025) · 47 CFR 9.28, definition of 911 traffic · Checked 2026-10-14
33. 33
    FCC 14-118 limited the text-to-911 requirements to interconnected text applications and excluded non-interconnected applications that only support communication among a defined set of users of compatible applications.

    Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications; Framework for Next Generation 911 Deployment - Second Report and Order and Third Further Notice of Proposed Rulemaking (FCC 14-118) · footnote 1 (attached to paragraph 1) · Checked 2026-10-14
34. 34
    Covered text providers that use the CMRS network to deliver 911 texts must clearly inform consumers that, without an SMS plan with their underlying CMRS provider, they may be unable to deliver 911 texts.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(11) · Checked 2026-10-14
35. 35
    FCC 14-118 encouraged covered text providers to use text messaging to inform consumers about the availability of text-to-911.

    Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications; Framework for Next Generation 911 Deployment - Second Report and Order and Third Further Notice of Proposed Rulemaking (FCC 14-118) · paragraph 70 · Checked 2026-10-14
36. 36
    Covered text providers must give PSAPs that accept text-to-911 a mechanism to request temporary suspension and later resumption of text-to-911, and must send bounce-back messages to affected consumers during a suspension.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(6) · Checked 2026-10-14
37. 37
    RingCentral's US Emergency Services Policy says that dialing or texting the emergency number from the RingCentral smartphone app closes the app and launches the native dialer or SMS function, and the call or text is handled by the user's wireless carrier.

    Emergency Services Policy: Operation and Limitations of Emergency Service · Section 3, When You Call Emergency Services from Your Smartphone App · Checked 2026-10-14
38. 38
    RingCentral's US Emergency Services Policy describes text-to-emergency only as a handoff from the smartphone app to the phone's native SMS; it describes no text-to-911 path from desk phones or desktop apps.inferred

    Emergency Services Policy: Operation and Limitations of Emergency Service · Section 3 and Disclaimer of Liability (whole policy reviewed) · Checked 2026-10-14
39. 39
    RingCentral states that emergency dialing is not available on tablets or other mobile devices that lack a native phone dialer and a wireless service plan.

    Emergency Services Policy: Operation and Limitations of Emergency Service · Section 3, When You Call Emergency Services from Your Smartphone App · Checked 2026-10-14
40. 40
    RingCentral states that its smartphone app cannot place emergency calls over Wi-Fi.

    Emergency Services Policy: Operation and Limitations of Emergency Service · Section 3, When You Call Emergency Services from Your Smartphone App · Checked 2026-10-14
41. 41
    RingCentral tells smartphone app users to call or text emergency services, where texting is available, from the smartphone's native dialer, and says the app is not a replacement for wireless cellular service.

    Emergency Services Policy: Operation and Limitations of Emergency Service · Section 3, When You Call Emergency Services from Your Smartphone App · Checked 2026-10-14
42. 42
    When a consumer is roaming, the covered text provider operating the consumer's home network must originate the bounce-back message, and the host provider must not impede the consumer's 911 text to the home provider.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(7) · Checked 2026-10-14
43. 43
    No later than December 31, 2014, all covered text providers had to be able to route a 911 text message to a PSAP.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(10)(i) · Checked 2026-10-14
44. 44
    Covered text providers must begin routing all 911 text messages to a PSAP by June 30, 2015 or within six months of the PSAP's valid request, whichever is later, unless the provider and PSAP agree to a different date.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(10)(ii) · Checked 2026-10-14
45. 45
    Covered text providers must obtain location information sufficient to route a 911 text to the same PSAP that would receive a voice 911 call from that location, unless a local or state entity designates a different PSAP.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(10)(i) · Checked 2026-10-14
46. 46
    A CMRS provider migrating away from SMS must notify affected covered text providers at least 90 days before the migration.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(11) · Checked 2026-10-14
47. 47
    US Teams SMS is carried over the 10DLC A2P network, and a tenant must get Brand and Campaign approval from The Campaign Registry before any Teams Calling Plan number can be enabled for SMS.

    Planning for SMS in Microsoft Teams · Registering to use the 10DLC network · Checked 2026-10-14
48. 48
    Microsoft classifies all SMS to and from Teams as business, non-consumer, application-to-person (A2P) messaging, not consumer SMS.

    Planning for SMS in Microsoft Teams · Overview · Checked 2026-10-14
49. 49
    Microsoft's Teams SMS planning article does not mention 911, emergency texting or text-to-911 anywhere, so it gives administrators no basis to treat Teams SMS as an emergency channel.inferred

    Planning for SMS in Microsoft Teams · whole article (absence) · Checked 2026-10-14
50. 50
    SMS in Teams is available only in public clouds and not in GCC.

    Planning for SMS in Microsoft Teams · Considerations and limitations · Checked 2026-10-14
51. 51
    Teams Calling Plan users in the US and Canada can send SMS to numbers that can receive SMS and are regionally assigned to recipients in the US or Canada; SMS outside the US and Canada is not supported.

    Planning for SMS in Microsoft Teams · Overview · Checked 2026-10-14
52. 52
    47 CFR 9.10(q)(9) defines a 911 text message as a message of text characters sent to the short code 911 and intended for delivery to a PSAP by a covered text provider, regardless of the text messaging platform used.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(9) · Checked 2026-10-14
53. 53
    Since a 911 text is by definition sent to the short code 911 and Twilio rejects short-code To values with error 21265, an SMS addressed to 911 through the Twilio Messaging API would be expected to fail rather than reach a PSAP.inferred

    21265: 'To' number cannot be a Short Code · Description; combined with 47 CFR 9.10(q)(9) · Checked 2026-10-14
54. 54
    Twilio's US and Canada emergency services terms limit customers to its listed Approved Services for contacting 911, and the only two listed are Elastic SIP Trunking and Programmable Voice SIP Interfaces.

    Emergency Services in the United States and Canada · Approved Services table · Checked 2026-10-14
55. 55
    Because Twilio Programmable Messaging is not on Twilio's list of Approved Services for contacting 911, a customer may not offer end users 911 texting through it under those terms.inferred

    Emergency Services in the United States and Canada · Approved Services table · Checked 2026-10-14
56. 56
    Twilio returns error 21265 when the To parameter of an SMS is a short code rather than a full recipient phone number.

    21265: 'To' number cannot be a Short Code · Description and Possible causes · Checked 2026-10-14
57. 57
    A valid PSAP request for text-to-911 requires that the PSAP is, and certifies that it is, technically ready to receive 911 texts in the requested format; that the local or state 911 governing authority has specifically authorized it to accept them; and that it has notified the covered text provider.

    47 CFR 9.10 Wireless E911 Service (annual edition revised as of October 1, 2025) · 47 CFR 9.10(q)(10)(iii)(A)-(C) · Checked 2026-10-14
58. 58
    The same customer knowledge base reports that after an attempted emergency text, Zoom Phone automatically calls the emergency number after 10 seconds unless the user cancels.field report

    Using SMS (Text Messaging) on Zoom Phone App · section on emergency numbers · Checked 2026-10-14
59. 59
    One Zoom Phone customer's IT knowledge base reports that Zoom Phone users cannot text emergency numbers in the US or Canada and that attempting it produces an error message.field report

    Using SMS (Text Messaging) on Zoom Phone App · section on emergency numbers · Checked 2026-10-14

Documents

Cite this page

WarmTransfer. (2026, October 14). Text-to-911 availability and enterprise implications. WarmTransfer. https://warmtransfer.net/knowledge/text-to-911

@misc{warmtransfer-text-to-911,
  title  = {Text-to-911 availability and enterprise implications},
  author = {{WarmTransfer}},
  year   = {2026},
  url    = {https://warmtransfer.net/knowledge/text-to-911},
  note   = {Verified 2026-10-14}
}