The New FCC NG911 Rules: What PSAPs and 911 Authorities Need to Know in 2026

For years, the transition from legacy 911 systems to Next Generation 911 has been a goal on the horizon, something the public safety community knew was coming but lacked a clear, enforceable timeline for. That changed in 2024 when the Federal Communications Commission 

adopted its first-ever nationwide NG911 transition rules, and 2026 is the year those rules are

starting to take effect.

Whether you manage a PSAP, serve as a 911 Authority, or work with an originating service

provider, understanding these new requirements is no longer optional. The FCC has laid out

specific phases, deadlines, cost responsibilities, and compliance expectations that will shape the next several years of emergency communications.

In this post from NGA, we’ll  break down the FCC's NG911 transition framework, including the two-phase implementation process, what 911 Authorities and OSPs are each responsible for, key deadlines to watch, the upcoming reliability rules expected later this year, and what PSAPs should be doing right now to stay ahead of the curve.

Why the FCC Acted Now

The case for NG911 has been building for over a decade. Legacy 911 infrastructure, built on

circuit-switched analog technology, was never designed to handle the demands of modern

communication. It cannot support text, photo, or video transmission to PSAPs. It relies on aging

selective routers and ALI databases that are increasingly difficult and expensive to maintain. And it lacks the interoperability that modern IP-based networks can provide.

Despite widespread agreement on the need to modernize, the transition has been uneven.

Some states have made significant progress deploying ESInets and NG911 Core Services, while others remain almost entirely on legacy systems. Without a federal framework, PSAPs, OSPs, and 911 Authorities had no consistent set of expectations or deadlines to work from.

The FCC's Report and Order (FCC 24-78), adopted in mid-2024, was designed to address exactly this gap. It creates a structured, phased process that establishes clear responsibilities for both 911 organizations and originating service providers, with the flexibility to accommodate local conditions.

The Two-Phase Transition Framework

At the core of the FCC's approach is a two-phase implementation model. Each phase has specific requirements, and the timeline is driven by requests from 911 Authorities rather than a single national deadline.

Phase 1: Establishing the IP Foundation

Phase 1 focuses on building the basic IP connectivity between OSPs and NG911 infrastructure.

When a 911 Authority submits a valid Phase 1 request, the OSP must:

• Deliver all 911 traffic bound for the relevant PSAPs in IP-based Session Initiation Protocol (SIP) format as specified by the 911 Authority.
• Route 911 traffic through ESInets and other NG911 network facilities to reach the destination PSAP.
• Deliver all traffic to one or more in-state NG911 Delivery Points designated by the 911 Authority.
• Complete connectivity testing to confirm that the 911 Authority receives traffic in the correct IP-based format.

Before submitting a Phase 1 request, the 911 Authority must certify that it has the infrastructure in place to receive 911 traffic in SIP format and transmit it to PSAPs. This includes identifying the NG911 Delivery Points that OSPs will connect to.

Phase 2: Full NG911 Standards Compliance

Phase 2 takes the transition further by requiring full adherence to NG911 commonly accepted

standards. 

Upon receiving a valid Phase 2 request, an OSP must:

• Deliver all 911 traffic in an IP-based SIP format that conforms to NG911 standards specified by the 911 Authority.
• Embed location details in call signaling using PIDF-LO (Presence Information Data Format, Location Object) or its functional equivalent, ensuring accurate and standards-compliant location data transmission.
• Continue delivery to NG911 Delivery Points designated in Phase 1.

Before submitting a Phase 2 request, the 911 Authority must certify that it can receive SIP traffic

compliant with NG911 standards and that its ESInet is connected to an NG911 Core Services network.

Timeline and Deadlines

The FCC's rules do not set a single national go-live date. Instead, the clock starts when a 911

Authority submits a valid request to an OSP. 

From that point:

• Facilities-based fixed and mobile wireless providers have 6 months to comply with a Phase 1 or Phase 2 request.
• All other covered OSPs, including interconnected VoIP providers, have 12 months to comply.
• If an OSP provides multiple service types subject to different timelines, it may comply under the later of the two deadlines.

This request-driven model means that the transition pace will vary by region, depending on how

quickly 911 Authorities are ready to issue requests and how prepared their infrastructure is to

receive IP-based traffic.

Cost Responsibilities: Who Pays for What

The FCC's rules establish a clear cost-sharing framework:

• OSPs are responsible for the cost of transmitting 911 traffic from their end users to the

NG911 Delivery Points designated by the 911 Authority. OSPs also bear the cost of

compatibility testing. 

• 911 Authorities are responsible for the cost of transmitting calls from NG911 Delivery Points to PSAPs, and for any reformatting or call translation within the NG911 network beyond the handoff point.

This division is designed to be straightforward, though the financial impact will vary depending

on the complexity of each region's network architecture and the number of OSPs involved.

Flexibility Through Alternative Agreements

Recognizing that a one-size-fits-all approach will not work for every situation, the FCC allows

OSPs and 911 Authorities to enter into mutual agreements that specify different requirements,

timetables, or other terms than the default Phase 1 and Phase 2 rules. If such an agreement is

reached, the OSP must notify the FCC within 30 days of execution, including the pertinent terms.

This flexibility is important for regions where unique geographic, financial, or infrastructure

challenges require a customized approach.

Coming Soon: Updated Reliability and Interoperability Rules

Beyond the transition framework, the FCC is also working on sweeping updates to its 911

reliability and interoperability regulations. 

These updates, expected in late summer 2026, would:

• Expand the definition of "covered 911 service provider" (C9SP) to include all entities essential to NG911 delivery, not just traditional wireline operators.
• Require physical diversity and automatic failover for critical IP paths.
• Mandate annual interoperability testing with ESInets in other states and annual certification that equipment conforms to commonly accepted NG911 standards.
• Establish a formal deficiency and corrective order process, giving the FCC and state 911

Authorities new tools to address reliability issues proactively.

For providers that may not currently consider themselves covered under existing 911 reliability

rules, these proposed changes could bring new obligations. Monitoring this rulemaking closely is essential.

What PSAPs and 911 Authorities Should Do Now

Even if your region has not yet issued Phase 1 requests, there are important steps you can take today to prepare:

• Assess your infrastructure readiness. Can your network receive 911 traffic in SIP format? Is your ESInet operational and connected to NG911 Core Services? Identifying gaps now avoids delays when you are ready to issue requests.
• Identify your NG911 Delivery Points. The FCC requires 911 Authorities to designate these before submitting Phase 1 requests. Start that planning process early.
• Engage with your OSPs. Open communication with the originating service providers in your area will make the transition smoother. Discuss timelines, technical requirements, and whether alternative agreements might be appropriate.
• Plan for cost allocation. Understand the financial responsibilities on your side and build

them into your budget planning. State grants and federal funding programs may be available to offset costs.

• Stay informed on the reliability rulemaking. The FCC's upcoming rules could expand your oversight tools, but they may also affect providers you work with. Being informed early helps you adapt quickly.

Conclusion 

The FCC's NG911 transition rules represent the most significant federal action in the history of

911 modernization. For the first time, there is a structured national framework with defined

responsibilities, timelines, and enforcement mechanisms. While the transition will not happen

overnight, the direction is clear, and the clock is ticking.

For PSAPs and 911 Authorities, this is the moment to move from planning to action.

Understanding the rules, preparing your infrastructure, and building relationships with your

OSPs now will put you in the strongest position as the transition accelerates.

At NGA, we help PSAPs and 911 agencies navigate every stage of the NG911 transition, from

infrastructure planning to full deployment. 

Learn more about how we can support your agency at nga911.com.