New 911 and 988 Outage Reporting Requirements Take Effect for Voice Service Providers

Starting on April 15, 2025, voice service providers – including all cable, satellite, wireless, and wireline voice service providers and interconnected VoIP providers – will be required to comply with the FCC’s new, stricter rules on reporting outages potentially affecting calls made to 911 and to the 988 Suicide and Crisis Lifeline.

A reportable 911 outage occurs when there is a loss of communications to Public Safety Answering Points (PSAPs) that potentially affects 900,000 user minutes and lasts 30 minutes or more. A reportable 988 outage occurs when there is a loss of the ability of the 988 Lifeline to receive, process, or forward calls that potentially affects 900,000 user minutes and lasts 30 minutes or more.

Under the new 911/988 outage reporting rules, voice service providers will be required to:

• Provide a 911 outage notification to all potentially affected PSAPs as soon as possible, but no later than 30 minutes after discovery of the outage;

• Provide a 988 outage notification to the Substance Abuse and Mental Health Services Administration (SAMHSA), the Department of Veterans Affairs (VA), and the 988 Lifeline administrator as soon as possible, but no later than 30 minutes after discovery of the outage;

• Provide follow-up notifications to affected PSAPs and/or the 988 Lifeline contacts as soon as any additional material information about the outage becomes available, with the first follow-up to be provided no later than two hours after the initial contact and additional follow-ups to continue until service is fully restored;

• Submit an initial report of the 911/988 outage in the FCC’s Network Outage Reporting System (NORS) within 72 hours after discovery of the outage and submit a final outage report in NORS within 30 days.

According to the FCC, the 30-minute window for notifying PSAPs and 988 contacts of an outage is triggered when the outage is first discovered by any party in the call-delivery chain, regardless of when or whether the voice service provider itself has been notified or made aware of the outage.

In addition to new reporting timelines, the FCC’s new rules include a list of the specific information that must be provided in the notifications sent to PSAPs and to the 988 Lifeline contacts, and also require service providers to exercise “special diligence” to identify and maintain current PSAP and 988 contact information and to confirm that information on an annual basis.

If you have questions or would like more information about the FCC’s new 911 and 988 outage reporting requirements, contact an attorney in our Broadband, Spectrum, and Communications Infrastructure Practice Group.