NG911 Mythbusters: The Critical Truth Behind Compliance Myths

NG911 Mythbusters: The Critical Truth Behind Compliance Myths

Published: May 2, 2025

An NG911 compliance storm is brewing for Originating Service Providers (OSPs) and 911 authorities – one that could disrupt your business, invite costly FCC NG911 penalties, and undermine public safety. 

Misinformation around Next Generation 911 (NG911) requirements and how to make a valid FCC NG911 migration request is widespread. Many providers on both sides mistakenly believe they're already compliant due to usage of terminology that has a definition in commonly accepted standards that is not fully acknowledged – or worse, that compliance isn't necessary at all. 

The confusion centers around two critical areas:

• FCC NG911 Migration Compliance: Are you truly ready for the FCC's Phase 2 NG911 requirements?

• Next Generation Core Services (NGCS): Do you know what's mandatory, what's optional, and why mastering these emergency call‑routing standards is mission critical?

Today, we’re going to separate the myths from the truth about NG911 compliance.

NG911 Compliance: Separating Fact From Fiction

Myth: “FCC Phase 2 NG911 migration does not affect data management.”

Fact: Phase 2 fundamentally transforms how all wireline, VoIP, and wireless providers must handle location data. It also requires that a 911 authority can demonstrate they have commissioned the functional element, Location Validation Function (LVF), for providers to use. It isn’t just the conformance to how data is represented but also constructing the data object that is used to validate and transmit the location of a 911 caller.

Once a 911 authority triggers Phase 2, this indicates that they can demonstrate the capabilities required for their request to be valid. Providers then have as little as six months – and no more than one year – to deploy and test the update.

Only two specifications meet the federal definition of “commonly accepted”: the NENA i3 standard and the CLDXF‑US schema. Otherwise, if you believe your “conversion” from legacy to CLDXF is complete, I’d suggest revisiting every relationship and definition of these functional elements and standards to confirm true compliance.

The Real Stakes of NG911 Compliance

Ignoring these rules doesn't just invite penalties or public criticism – it jeopardizes your entire operation and compromises the safety of 911 callers, your most critical customers. When emergency response systems fail due to non-compliance, the consequences impact lives literally hanging in the balance.

A developing interpretation of the FCC rules holds that, because the rules do not specify the required standards, the 911 authority must both identify those standards to the originating service provider and take responsibility for correcting the current originating service provider data from the legacy MSAG format to meet NG911 requirements.

In a future blog, we will discuss this in depth but the reality is that most 911 authorities feel that it is a cost of doing business for the OSP and no different than a 911 authority bearing the cost burden of GIS data governance for NG911. This is a very similar problem statement and there are some best practices and tools that the GIS community can share with the OSPs to aid them in making these updates.

While the 911 authority should communicate with all OSPs that have subscribers in its service area before making either phase request, only two standards meet the definition set by the federal government. FCC-defined standards do not change overnight, nor do new ones emerge without transparent development that includes anyone who wants to contribute.

This misinterpretation of the new regulatory requirements has caught many IT teams off guard, forcing them into emergency mode as they discover serious gaps between their existing data systems and what compliance actually demands.

The Compliance Advantage

Forward‑thinking telecommunications providers and NG911 core services vendors are turning compliance challenges into competitive advantages. By embracing NG911 standards early, they are positioning themselves as industry leaders, and at the same time, future‑proofing their operations. These providers know compliance is not about weighing potential penalties against upgrade costs – it is about delivering superior service in an increasingly connected world.

The transition to NG911 represents the most significant overhaul of emergency communications infrastructure in decades. It's not just about updated technology; it's about reimagining how emergency services integrate with modern communication methods.

What's Next?

Over the coming weeks, we will debunk the most dangerous myths in NG911 regulatory and standards compliance, bringing clarity and actionable insights directly from industry leaders. 

Next time, we'll drill deeper into the details of data management compliance, giving you practical steps and expert advice to secure your organization's readiness.

We'll explore how leading providers and 911 authorities are implementing these changes without disrupting their existing operations, and showcase case studies of seamless transitions that trimmed both cost and complexity.

Stay tuned – clarity is your best defense against fines, operational disruptions, and public‑safety failures.