At Intrado, we understand the complexity of regulatory compliance—because we’re in it with you. We partner with service providers, public safety answering points (PSAPs), enterprises, and schools every day to solve complex problems and comply with state and federal 911 regulations.
For originating service providers (OSPs), staying up to speed with regulatory requirements has become a challenge in 2025 amid a flurry of changes. We’re committed to simplifying the path forward.
In general, Intrado's regulatory team advises reviewing the rules with your counsel to validate and gain insight into your specific requirements. To aid in that conversation, here’s a breakdown of four major Federal Communication Commission (FCC) orders impacting OSPs—plus tips on how to confidently prepare for the regulatory milestones ahead.
FCC 24-78: Expediting the Transition to NG911
Let’s start with what might be the most substantial shift. As of March 25, 2025, OSPs must respond to service requests to connect to Emergency Services IP Networks (ESInets) using Session Initiation Protocol (SIP), or if the state or PSAP is already more advanced, using a NG911 common standard (probably NENA i3). Think of it as the final push away from time-division multiplexing (TDM)-based infrastructure and toward an all-IP future, modernizing how OSPs connect with PSAPs.
FCC 24-78 outlines two phases—each with its own technical demands. Nationwide providers must become compliant within six months per phase; non-nationwide providers have 12 months per phase.
But it’s not just a technology shift; it’s operational, too. OSPs must track PSAP readiness, validate Requests for Service (RFSs), maintain certificates, ensure formatting standards are met, perform interoperability testing, and stay on top of deadlines.
The compliance clock is ticking, and deadlines kick in once a PSAP requests service. Intrado helps service providers navigate these complexities with NG Nexus, a fully managed, hosted solution that alleviates the compliance burden.
Additional Resources:
Accelerating the Future of NG911 Services
Quick Guide for PSAPs on NG911 Service Requests
NG911 Compliance FAQs: A Quick Guide for OSPs
FCC 24-4: Improving Wireless 911 Call Routing via Location Technology
For many years, wireless 911 calls were routed based on cell tower location, which can cover up to a 10-mile radius. Because only one PSAP is designated to take requests for assistance (RFAs) per cell tower, calls must often be transferred to the jurisdictionally appropriate PSAP. According to the FCC, as many as 23 million wireless 911 calls are rerouted each year for this reason. These transfers can add 40 seconds of delay or more.
Smartphones have evolved and location technology has advanced significantly, making tower-based routing outdated. Wireless 911 call routing needs to evolve.
Adopted January 25, 2024, FCC 24-4 mandates nationwide wireless carriers implement location-based routing as of November 2024. Non-nationwide carriers must become compliant by May 13, 2026. All wireless carriers must also adopt location-based routing for real-time text (RTT) by May 13, 2026.
Take note: Wireless carriers that have not yet begun deployment need to start now. Location-based routing is not plug-and-play. Extensive validation with device manufacturers and rigorous testing are required—and these steps can take many months.
Intrado helps carriers of all sizes meet FCC location-based routing requirements with our Locate Before Route solution—recognized by Popular Science and Fierce Network for delivering a more precise dispatchable location to public safety and improving response times.
Additional Resources:
Why Can Uber Find Me But 911 Can’t?
What’s the Problem With 911 Call Routing?
FCC Location-Based Routing Rules
FCC 22-88: Improving 911 Reliability (Outage Notification Requirements)
Let’s face it—outages happen. But how service providers respond makes all the difference. As of April 15, 2025, FCC 22-88 OSPs must comply with new outage notification standards. Potentially affected PSAPs must be notified of an outage within 30 minutes, with updates provided at least every two hours until the issue is resolved.
The order also requires “special diligence” in PSAP contact data management, meaning maintaining accurate, up-to-date PSAP contact data. While details are somewhat limited, the FCC mandates annual updates and several outreach attempts to ensure PSAP responses during contact data verification processes.
Intrado has been curating a highly accurate list of contacts, covering PSAPs across the US and its territories, for more than 20 years. Our PSAP Outage Contact List is maintained (at minimum) through a biannual, multistage process and supports providers of all sizes in meeting FCC expectations with confidence.
Additional Resources:
Special Diligence: Breaking Down the FCC’s Outage Notification Requirements
Notifying PSAPs During an Outage: How OSPs Can Comply with FCC Regulations
Navigating the FCC’s 911 Outage Notification Rules
FCC 24-111: Localized Routing for 988 Calls
Since its adoption, 988 has been a lifeline for millions, with nearly 7 million calls in 2024. But routing those calls to local resources—while protecting user privacy—has been a challenge.
Historically, 988 routing was based on the area code and exchange (NPA/NXX) of a caller’s number. With number portability, many people keep their original phone number after moving, which means their 988 call might reach a crisis center in a different state—far from where help is needed.
The best help is local help, and FCC 24-111 addresses this by requiring georouting for all wireless 988 calls. Nationwide OSPs must already be compliant. Non-nationwide providers must comply by December 12, 2026. The rule currently applies to voice calls only, but we expect text to follow and will be monitoring developments.
Intrado played a leading role in proving that georouting is possible and effective. Our 988 Georouting solution ensures calls reach local resources, protecting privacy and improving access to care. In the interest of the public safety community, we also published a network interface specification designed to meet current demands while remaining adaptable for future requirements.
Additional Resources:
988 Georouting: No Need to Reinvent the Wheel
Empowering Communities with Mental Health Awareness, Crisis Response, and Innovative Solutions
What Comes Next?
If you’re not yet compliant with these regulations, we encourage you to reach out for more information. Some deadlines have passed while others will be coming up soon—and timeframes for deployment must be factored in. Here are some next steps:
Audit your current capabilities against each regulation.
Initiate planning and deployment—especially for long-lead efforts like NG911 interconnection and location-based routing.
Work with partners who understand the operational and technical lift these changes require.
In addition to the regulations we’ve discussed here, our regulatory team is monitoring other developments that impact our service provider community, including:
FCC 24-28, which addresses 911 over supplemental coverage from space (SCS)
FCC 25-21, which proposes new reliability rules for NG911 and would extend the definition of covered 911 service provider
FCC 25-22, which proposes measures to fine-tune 911 location accuracy requirements, in particular z-axis location
Need help planning your compliance roadmap? Let’s talk. Reach out to our account team or use the form on the right side of this page to get the conversation started.