In the July 24, 2026 edition of the ICORE Blog we reported on a Report and Order (Order) adopted by the FCC regarding NG911. The Order introduced new rules to ensure that emerging NG911 networks are reliable and interoperable. The FCC noted that NG911 is replacing legacy 911 technology across the country with IP-based infrastructure that will support new 911 capabilities, including text, video, and data. Further, for NG911 to be fully effective, NG911 networks must be designed to safeguard the reliability of critical components and support the interoperability needed to seamlessly transfer 911 calls and data from one network to another. The Order reflected the following major steps:
* The definition of “covered 911 service provider” in the Commission’s rules is updated to include service providers that control or operate critical pathways and components in NG911 networks.
* Modernizes and streamlines the 911 reliability standards applicable to covered providers to reflect best practices appropriate to IP-based 911 networks.
* Promotes NG911 interstate interoperability by requiring certain providers to report on their ability to support seamless transfers of 911 traffic between NG911 networks.
* Replaces burdensome annual filing requirements for covered providers with a streamlined certification process.
* Empowers state and local 911 authorities to obtain key information from service providers so that 911 Authorities can more easily address reliability, interoperability, and accessibility.
Regarding the timeline for compliance with the new rules, the Order establishes an 18-month transition period for phasing in the new 911 reliability framework and interoperability measures. The 18-month period will commence when the Commission issues a Public Notice announcing approval by the Office of Management and Budget (OMB) of the information requirements adopted in the Order. Per the Order, all IP-based providers will have 18 months from the Public Notice date to come into compliance with the updated reliability benchmarks for physical diversity, operational integrity, and network monitoring, or to implement alternative measures. Providers covered under the Commission’s 2013 911 reliability rules will continue to be subject to the reliability benchmarks established under those rules.
On September 14, 2026, the Public Safety and Homeland Security Bureau issued a Public Notice (Notice) reminding covered service providers of their obligations during the phase-in of the NG911 rules adopted in the Order. The Notice reiterates that compliance with the newly adopted rules will not be required until the Commission announces OMB approval. The Notice advises covered service providers of their continuing obligations under the 2013 911 reliability rules during the phase-in period for the new regulations as follows:
* All providers that were covered service providers prior to Order must continue to provide reliable 911 service now and during the 18-month phase-in period in accordance with the reliability benchmarks that were originally adopted in 2013, however, providers may also take alternative measures that are “sufficient to mitigate the risk of failure”. IP-based providers that have previously filed reliability certifications may continue to use alternative measures appropriate to IP networks.
* Per the Order, covered service providers are no longer required to file annual 911 reliability certifications. Therefore, no reporting is required for 2026 or going forward until the conclusion of the 18-month phase-in period.
* Covered service providers will be required to file initial reliability certifications 18 months after the Public Notice announcing OMB approval of the information collection required by the Order. That Public Notice will also include information on filing deadlines for attestations for new covered service providers and interoperability reports for certain IP providers.
* Covered service providers covered by the 2013 911 reliability rules that completely cease to provide 911 services have an ongoing obligation to notify the Commission no later than 60 days after such cessation.
As always, we will continue to monitor this issue and will provide timely updates as more information becomes available.
