FCC Urges Carriers and Enterprise MLTS Operators to Address Location-Data Gaps Before NG911 Migration Exposes Them
The Federal Communications Commission has issued new guidance highlighting an important—and potentially consequential—Next Generation 911 (“NG911”) problem involving legacy Time Division Multiplexing (“TDM”)-based Multi-Line Telephone Systems (“MLTS”) that rely on third-party Private Switch/Automatic Location Identification (“PS/ALI”) services.
In Public Notice DA 26-1043A1, the FCC identifies circumstances in which the telecommunications carrier responsible for originating a 911 call may not possess the location information necessary to route that call directly through an NG911 network.
The Commission’s message is straightforward: carriers, MLTS operators, PS/ALI providers, 911 authorities, and other stakeholders should identify these gaps now—before NG911 migration turns a legacy architecture issue into an emergency-calling problem.
On the same day, the FCC released DA 26-1042A1, granting Verizon a limited and conditional one-year waiver of certain NG911 Phase 1 deadlines in Massachusetts and other affected jurisdictions while the company conducts customer outreach and develops solutions.
For businesses, institutions, campuses, health-care facilities, hospitality operators, schools, government facilities, and other organizations operating enterprise telephone systems, the developments are another reminder that 911 compliance does not end at the telephone carrier’s network edge.
What Went Wrong?
The issue emerged during Verizon’s NG911 testing in Massachusetts.
Certain 911 calls originating from legacy TDM-based MLTS platforms used third-party PS/ALI services to associate individual telephone numbers with physical location information. Verizon, however, did not possess the underlying PS/ALI location records.
That created a problem.
The originating carrier could deliver the 911 call, but it did not necessarily have the location information needed by the NG911 environment to determine where the call should be routed.
Instead of being routed directly to the appropriate Public Safety Answering Point (“PSAP”), affected calls were routed to Intrado’s Emergency Call Relay Center. An operator then had to obtain the caller’s location and manually transfer the call to the appropriate emergency communications center.
That additional step matters.
In an emergency, additional call handling can mean additional delay. And reliance on a caller to verbally identify a location can become particularly problematic where the caller cannot speak, does not know the address, or is located within a large building, campus, hotel, hospital, school, warehouse, office complex, or other multi-location environment.
The Architecture Is Changing
Legacy 911 and NG911 networks do not necessarily use location information in the same way.
Historically, a telephone number could be associated with a PS/ALI record maintained within the 911 ecosystem. That architecture allowed location information to be retrieved downstream after the call entered the emergency-calling network.
NG911 increasingly depends on accurate location information being available earlier in the call-routing process so that the network can determine which emergency communications center should receive the call.
That distinction creates the potential gap identified by the FCC.
If the originating telecommunications provider has responsibility for routing the call but an MLTS operator or third-party PS/ALI provider possesses the information identifying where the caller actually is, the location information and routing function may reside with different parties.
NG911 migration can expose that separation.
What the FCC Is Telling Industry
The Commission’s Public Notice identifies several areas requiring attention.
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Originating Providers Should Identify Affected CustomersWireline originating service providers should determine whether they serve MLTS customers that rely on third-party PS/ALI arrangements and begin identifying the location information necessary to support NG911 routing. Providers should not assume that information maintained elsewhere in the legacy 911 ecosystem will automatically remain accessible following migration.
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MLTS Operators Still Have ResponsibilitiesThe FCC’s guidance does not shift enterprise 911 obligations away from MLTS operators and managers. Depending on the system and circumstances, the enterprise may be the party possessing—or controlling access to—the information necessary to establish a caller’s dispatchable location. Applicable requirements under Kari’s Law and Section 506 of RAY BAUM’S Act therefore remain important, including requirements concerning direct dialing of 911, notification of 911 calls, and transmission of appropriate dispatchable-location information.
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Legacy TDM Systems Deserve Particular AttentionThe Commission encourages organizations operating older TDM-based MLTS platforms to evaluate migration toward IP-based solutions as NG911 implementation progresses. That does not mean every legacy system must immediately be replaced. It does mean organizations should understand how their existing telephone architecture will interact with NG911 before their local 911 environment transitions.
Coordination Will Be Essential
The FCC expects cooperation among:
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originating telecommunications providers;
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NG911 service providers;
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state and local 911 authorities;
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MLTS owners and operators;
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PS/ALI providers; and
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other telecommunications and emergency-services vendors.
For many enterprises, determining who is responsible for what may itself be one of the first—and most important—compliance exercises.
Verizon Received Limited Relief—Not a General Exemption
The FCC separately granted Verizon limited relief from certain NG911 Phase 1 deadlines while the company conducts outreach and works toward solutions in affected jurisdictions.
That waiver is important, but its scope should not be overstated.
The relief is tied to Verizon’s particular circumstances and conditions. It does not create a blanket exemption for other carriers, MLTS operators, enterprises, or service providers facing similar technology or data-management challenges.
If anything, the waiver reinforces the FCC’s expectation that affected parties actively identify these problems and work toward remediation.
Why Enterprises Should Pay Attention Now
A common assumption is that once an organization contracts with a carrier, cloud communications provider, PBX vendor, managed service provider, or E911 vendor, the emergency-calling problem has been “handled.”
That assumption can be dangerous.
An enterprise may have several different parties involved in completing a single 911 call:
Enterprise telephone system → PBX or UC platform → carrier → E911/PS-ALI provider → NG911 network → PSAP
Location records may be administered separately from call routing. Systems may have been installed years before current federal dispatchable-location requirements took effect. Facilities may have expanded or changed. Numbers may have moved between buildings. New cloud or SIP services may have been layered on top of older PBX infrastructure.
A configuration that functioned adequately in a legacy 911 environment may not function the same way once the underlying emergency network migrates to NG911.
The time to discover that problem is before an emergency call depends upon it.
Recommended Actions
Organizations operating MLTS environments should consider taking the following steps:
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Inventory legacy systems. Identify facilities that continue to rely on TDM-based MLTS platforms, PRI connections, CAMA trunks, legacy PBXs, or similar architecture.
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Identify PS/ALI relationships. Determine whether a third party maintains emergency-location records and identify precisely who controls and updates those records.
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Map the 911 call path. Understand every provider involved between the enterprise telephone and the PSAP.
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Confirm NG911 readiness. Ask carriers, managed service providers, PBX vendors, and E911 providers how emergency calls will be routed following NG911 migration and how location information will be exchanged.
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Validate location records. Confirm that emergency-location information remains accurate following office moves, number changes, system upgrades, remote-work implementations, acquisitions, renovations, and other operational changes.
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Review Kari’s Law and RAY BAUM’S Act compliance. Confirm direct 911 dialing, required notifications, and applicable dispatchable-location capabilities.
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Clarify contractual responsibility. Review agreements among the enterprise, carrier, MLTS provider, PS/ALI provider, and other vendors to determine who is responsible for maintaining, transmitting, testing, and updating emergency-location information.
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Test carefully. Develop a coordinated protocol for testing emergency-call routing and location delivery without unnecessarily burdening PSAP resources.
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Evaluate modernization. Where legacy architecture creates recurring risk, consider whether migration to an IP-based telephone environment should become part of the organization’s technology roadmap.
Looking Ahead
NG911 represents a significant modernization of the nation’s emergency communications infrastructure.
But modernization at the network level can expose dependencies that were largely invisible under legacy architecture.
The FCC’s latest guidance illustrates the problem clearly: a 911 call may technically complete while the information necessary to route it quickly and accurately resides somewhere else.
For enterprises operating multi-line telephone systems, NG911 readiness therefore requires more than asking whether “911 works.”
Organizations should understand how a 911 call is routed, where location information resides, who maintains it, who transmits it, and whether each piece of that process will continue functioning as local emergency networks transition to NG911.
THE COMMLAW GROUP CAN HELP
Enterprise 911, MLTS & NG911 Compliance
The CommLaw Group advises enterprises, telecommunications providers, cloud communications companies, PBX and UCaaS providers, managed service providers, property operators, health-care organizations, educational institutions, hospitality companies, and other businesses on the increasingly complicated intersection of 911 technology, federal regulation, state law, and enterprise communications systems.
Our attorneys can assist with:
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Kari’s Law and RAY BAUM’S Act compliance assessments;
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federal and state MLTS requirements;
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dispatchable-location analysis;
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NG911 migration and readiness;
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E911 and PS/ALI arrangements;
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PBX, hosted voice, cloud communications, and UCaaS architectures;
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carrier and vendor responsibility analysis;
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customer and vendor contracting;
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multi-state 911 regulatory reviews;
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enterprise implementation and remediation planning; and
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regulatory counseling when communications technology does not fit neatly within legacy regulatory frameworks.
The firm’s practice in this area is led by:
Christine (“Chris”) McLaughlin
Of Counsel, The CommLaw Group
(703) 714-1328 • czm@commlawgroup.com
Leela Vangala
Telecommunications Attorney, The CommLaw Group
(703) 714-1300 • lgv@commlawgroup.com
To assist organizations evaluating enterprise 911 obligations, The CommLaw Group offers the 2026 Enhanced Edition Federal + State 911 Regulatory Compliance Guide.
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2026 Enhanced Edition
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Federal + State 911 Regulatory Compliance Guide
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Purpose
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Practical handbook addressing federal MLTS requirements, including Kari’s Law and Section 506 of RAY BAUM’S Act, along with selected state-law requirements.
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Applicable Systems
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PBX, Key Systems, Hybrid Systems, Hosted Voice, Cloud Communications, Unified Communications, and other enterprise calling environments.
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Intended Audience
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Legal, compliance, telecommunications, IT, facilities, risk management, and procurement professionals.
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Key Benefit
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Helps organizations identify and address potential 911 compliance issues before deployments, audits, transactions, emergencies, or NG911 migrations.
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Important Note
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Federal FCC requirements are only part of the compliance landscape. State, local, tribal, public-safety, building-code, licensing, healthcare, education, contractual, and other sector-specific requirements may also apply.
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Information
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Contact The CommLaw Group at (703) 714-1300 or mail@commlawgroup.com to obtain the Guide or discuss an enterprise 911 compliance review.
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