Location-Based Routing for Wireless Voice Calls and Real-Time Text (RTT) Communications to 911

In January 2024, the Commission adopted rules to require wireless providers, or Commercial Mobile Radio Service (CMRS) providers, to use location-based routing to improve the routing of wireless 911 voice calls and certain categories of texts to 911 nationwide.*

Historically, wireless calls to 911 have been routed to the 911 call center, or Public Safety Answering Point (PSAP), associated with the cell tower that first receives the call. In some cases, this results in the 911 call being routed to a PSAP in a different jurisdiction from the 911 caller. Such calls must then be transferred to the PSAP serving the caller’s actual location, which can delay the arrival of first responders.

Recent technological advances now make it possible for CMRS providers to use precise information about the location of the caller, as opposed to the location of the cell tower, to determine how to route the call. The Commission’s new location-based routing rules require CMRS providers to implement and use this capability.

Location-Based Routing Requirements

The Commission’s location-based routing rules (47 CFR § 9.10(s)) require CMRS providers to take certain steps to enable location-based routing on their Internet Protocol (IP)-based networks (meaning 4G LTE, 5G, and subsequent generations of IP-based networks). Location-based routing is the use of information regarding the location of the caller’s handset or device to deliver wireless voice calls and real-time text (RTT) communications to 911 to point(s) designated by the authorized local or state entity to receive 911 calls and texts, such as a PSAP or Emergency Services IP network (ESInet). (47 CFR § 9.3.)

Under these rules, CMRS providers must deploy technology on their IP-based networks nationwide that supports location-based routing
(47 CFR § 9.10(s)(1)(i)-(ii), (s)(2).)
CMRS providers must also use location-based routing to route wireless 911 voice calls and RTT communications to 911 when caller location information is available to the network at the time of routing and locates the caller within a radius of 165 meters at a confidence level of at least 90%. (47 CFR § 9.10(s)(3)(i).) In the absence of these conditions, wireless providers are required to use alternative routing methods based on “best available” location information, which may include but is not limited to device-based or tower-based location information.
(47 CFR § 9.10(s)(3)(ii).)

The location-based routing rules govern initial 911 call routing by wireless (CMRS) providers that the public uses to call or text 911. They do not apply to the entities that receive the 911 calls and may perform additional routing functions, e.g., ESInet providers or Next-Generation 911 Core Services providers.

Compliance Timeline

CMRS providers must comply with the location-based routing rules by the following dates:

November 13, 2024:
Nationwide CMRS providers - deployment and routing obligations for voice calls to 911. Nationwide CMRS providers must deploy location-based routing technology for wireless 911 voice calls on their IP-based networks nationwide, and must route all wireless 911 voice calls originating on such networks pursuant to the requirements in paragraph (s)(3) of section 9.10 of the rules. (47 CFR § 9.10(s)(1)(i).)
January 12, 2025:
Nationwide CMRS providers – Compliance certifications and reports due.
Nationwide CMRS providers must comply with certain certification and reporting requirements (discussed in “Certification and Reporting Requirements” below). (47 CFR § 9.10(s)(4).)
May 13, 2026:
Non-nationwide CMRS providers – deployment and routing obligations for voice calls to 911. Non-nationwide CMRS providers must deploy location-based routing technology for wireless 911 voice calls on their IP-based networks, and must route all wireless 911 voice calls originating on such networks pursuant to the requirements in paragraph (s)(3) of section 9.10 of the rules. (47 CFR § 9.10(s)(1)(ii).)
All CMRS providers – deployment and routing obligations for RTT communications to 911. All CMRS providers must deploy location-based routing technology for RTT communications to 911 originating on their IP-based networks, and must route all RTT communications to 911 originating on such networks pursuant to the requirements in paragraph (s)(3) of section 9.10 of the rules. (47 CFR § 9.10(s)(2).)
July 12, 2026:
Nationwide CMRS providers and non-nationwide CMRS providers – Compliance certification and reports due. Nationwide and non-nationwide CMRS providers must comply with certain certification and reporting requirements (discussed in “Certification and Reporting Requirements” below). (47 CFR § 9.10(s)(4).)

Modification of Deadlines by Agreement

The Commission's rules allow PSAPs and CMRS providers to establish, by mutual consent, deadlines different from those established in the location-based routing rules. CMRS providers are required to notify the Commission of the dates and terms of the alternate time frame within 30 days of the parties' agreement. The CMRS provider must subsequently notify the Commission of the actual date by which it comes into compliance. Parties may not delay compliance with the location-based routing rules indefinitely. (47 § CFR 9.10(s)(5).) PSHSB has issued a Public Notice with filing instructions for CMRS providers to submit such notifications.

Certification and Reporting Requirements

CMRS providers are required to comply with certain certification and reporting requirements. PSHSB has issued a Public Notice providing filing instructions for CMRS providers to submit compliance certifications and live call data reports under these rules. Within 60 days after each compliance date, CMRS providers must:

Certify that they are in compliance with the location-based routing requirements applicable to them.
Identify specific network architecture, systems, and procedures used to comply with the location-based routing requirements applicable to them, including the extent to which the CMRS provider validates location information for routing purposes and the validation practices used in connection with this information.
Certify that neither they nor any third party they rely on to obtain location information or associated data used to comply with the applicable location-based routing requirements will use such location information for any non-911 purpose, except with prior express consent or as otherwise required by law. The certification must state that the CMRS provider and any third parties it relies on have implemented measures to safeguard the privacy and security of such location information or associated data.
Collect and report aggregate data on the routing technologies used for all live wireless 911 voice calls in the locations specified for live 911 call location data for a 30-day period beginning on each applicable compliance date above.

*The summary of the location-based routing rules on this webpage does not include the full text of the rules, and does not replace or supersede the rules. Although the Bureau has attempted to cover all parts of the rules that might be relevant, the coverage may not be exhaustive, and the timeline may not anticipate all situations in which the rules apply. This summary represents the Bureau's interpretation of the rules and is not legally binding on the Commission. Furthermore, the Commission retains the discretion to adopt case-by-case approaches, where appropriate, that may differ from the approach in the webpage. Any decision regarding a particular regulated entity will be based on the statutes and relevant rules. The full text of the 911 rules codified in 47 CFR Part 9 can be found here.

Resources

911 Regulations – 47 CFR Part 9

Location-Based Routing Requirements – 47 CFR § 9.10(s)

Location-Based Routing Report and Order Federal Register Notice – 89 FR 18488

Small Entity Compliance Guide – DA 24-447

Public Notice with Instructions for Filing Compliance Certifications and Reports – DA 24-1002

The FCC will closely monitor any complaints about alleged violations of these 911 rules.

Consumers may file a complaint via the Consumer Complaint Center.
Public Safety Answering Points (PSAPs), also known as 911 call centers, and other public safety entities may request support from the Public Safety and Homeland Security Bureau and notify the Bureau of problems or issues affecting the provision of emergency services through the Public Safety Support Center.