On April 15, 2025, new 911 Outage Notification Rules adopted by the Federal Communications Commission (FCC) will take effect, imposing expanded Public Safety Answering Point (PSAP) outage notification requirements on all Originating Service Providers (OSPs) that enable 911 calling. These new obligations, established in the 911 Outage Reporting Second Report and Order, will require affected service providers to notify impacted PSAPs in the event of an outage that could disrupt emergency calling services.
What is an Originating Service Provider (OSP)?
Under the FCC’s rules, an Originating Service Provider (OSP) is defined as any entity that enables a 911 voice call to be placed by an end user, regardless of whether that entity owns or operates the underlying network infrastructure. OSPs include, but may not be limited to, all:
- Facilities-based wireline and wireless carriers
- Interconnected VoIP providers
- Non-interconnected VoIP providers that enable outbound calling to 911
If you’re unsure about your company’s compliance obligations under the new regulations, consult with qualified telecom counsel before assuming an exemption applies.
What Do You Need to Know?
If your company qualifies as an OSP, you will be required to:
- Notify affected PSAPs within 30 minutes of discovering a potential 911-impacting outage (§ 19).
- Provide follow-up outage notifications according to FCC-mandated timelines (§§ 23-24).
- Maintain and update accurate PSAP contact information for all areas where you provide 911 service (§ 7).
Failure to comply with these requirements may result in FCC enforcement action, including potential fines and other penalties.
How to Prepare for Compliance
To avoid compliance risks, impacted providers should:
- Determine whether your company qualifies as an OSP under the FCC’s definition.
- Implement internal outage monitoring and PSAP notification procedures to ensure compliance with the 30-minute notification rule (or explore the marketplace to identify a viable and compliant vendor solution).
- Maintain accurate PSAP contact information for all 911 service areas.
- Train staff and update compliance policies ahead of the April 15, 2025, deadline.
Questions? Contact Us
Clients affected by these new requirements should promptly review their compliance obligations and prepare for implementation. For questions or guidance on how these rules impact your business, please contact the Responsible Partner serving your account or reach out to Michael P. Donahue at mpd@commlawgroup.com or Christine (“Chris”) McLaughlin at czm@commlawgroup.com.
Our team is ready to assist with compliance assessments, policy updates, and procedural implementation to help your organization navigate these new regulatory obligations.
