--- title: "What E911 and legal requirements apply when an ISP adds voice?" topic: "E911 & Compliance" updated: 2026-07-09 canonical: https://acrobits.net/resources/knowledge-base/e911-legal-isp-voice/ summary: "An ISP adding interconnected VoIP (service that can place and receive calls to and from the public telephone network) takes on four sets of obligations: E911 under FCC Part 9, including dispatchable location under RAY BAUM's Act and direct 911 dialing under Kari's Law; STIR/SHAKEN caller ID authentication for calls originated to the PSTN; FCC registration and Universal Service Fund contributions; and, depending on state and service model, CLEC or VoIP-specific state licensing. The E911 rules apply to every interconnected VoIP provider, with no small-entity exemption." --- # What E911 and legal requirements apply when an ISP adds voice? > An ISP adding interconnected VoIP (service that can place and receive calls to and from the public telephone network) takes on four sets of obligations: E911 under FCC Part 9, including dispatchable location under RAY BAUM's Act and direct 911 dialing under Kari's Law; STIR/SHAKEN caller ID authentication for calls originated to the PSTN; FCC registration and Universal Service Fund contributions; and, depending on state and service model, CLEC or VoIP-specific state licensing. The E911 rules apply to every interconnected VoIP provider, with no small-entity exemption. An ISP adding interconnected VoIP (service that can place and receive calls to and from the public telephone network) takes on four sets of obligations: E911 under FCC Part 9, including dispatchable location under RAY BAUM's Act and direct 911 dialing under Kari's Law; STIR/SHAKEN caller ID authentication for calls originated to the PSTN; FCC registration and Universal Service Fund contributions; and, depending on state and service model, CLEC or VoIP-specific state licensing. The E911 rules apply to every interconnected VoIP provider, with no small-entity exemption. Each section below covers one requirement and where [Cloud Softphone](/cloud-softphone/) fits in the compliance picture. This is not legal advice; consult a telecom attorney for your specific situation. ## E911: the non-negotiable requirement If you offer interconnected VoIP, you have [E911](/voip-glossary/e911-location-reporting/) obligations. The FCC's Part 9 rules apply to all interconnected VoIP providers, with no small-entity exemption ([47 CFR Part 9](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9)). **Interconnected VoIP** is the trigger. If your service only allows app-to-app calls within your network, E911 rules don't apply. The FCC's definition is a multi-prong test: the service requires a broadband connection and IP-compatible equipment, and lets subscribers both place calls to and receive calls from the public telephone network ([47 CFR 9.3](https://www.law.cornell.edu/cfr/text/47/9.3)). If your service meets that definition, or otherwise falls under Part 9's E911 rules (the FCC has applied E911 obligations to some outbound-only services too), 47 CFR Part 9 applies. ### What E911 requires RequirementWhat It Means Route 911 calls to the correct PSAP (public safety answering point)Based on the caller's location, not your server location Provide callback numberThe PSAP must be able to call the subscriber back Provide location informationAddress must reach the PSAP's dispatcher screen Register with a 911 service providerTypically Intrado, Bandwidth, or similar E911 aggregator For mobile softphone users, location is the hard part. A subscriber using your app could be anywhere: home, office, hotel, car. You need a mechanism to capture and update their location. ## RAY BAUM's Act: dispatchable location RAY BAUM's Act (enacted in 2018, with FCC compliance deadlines phased through January 2021 for fixed devices and January 2022 for non-fixed devices) expanded the location requirement significantly. The key term is **dispatchable location**: an address validated to the point where emergency services can actually find the caller ([FCC dispatchable location requirements](https://www.fcc.gov/911-dispatchable-location)). For fixed locations (desk phones), this means a street address plus floor, suite, or room number. For mobile softphone users, compliance gets more complex: - **Device-based location:** The app can report GPS coordinates, but this requires user permission and doesn't work well indoors. - **User-registered address:** The subscriber enters their primary location. Many VoIP providers use this as their baseline approach. - **Dynamic location updates:** The app updates the registered address when the subscriber moves. This is the gold standard but requires app-level support. Cloud Softphone supports location reporting that can feed into your E911 infrastructure. The app can prompt subscribers to update their registered address and report location data to your provisioning system. ## Kari's Law: direct 911 dialing Kari's Law (named after Kari Hunt, who was killed in a Marshall, Texas motel in 2013 while her daughter couldn't reach 911 because the phone system required dialing a 9 prefix first; see the [FCC's MLTS 911 requirements](https://www.fcc.gov/mlts-911-requirements)) requires: - **Direct dialing:** Users must be able to dial 911 without a prefix. No "9 + 911" or any access code. - **Notification:** A designated on-site contact must be notified when a 911 call is placed (applies to multi-line telephone systems). For softphone apps, direct dialing is straightforward: configure the dial plan so 911 routes directly. The notification requirement applies to multi-line telephone systems (MLTS), including cloud-based and hosted deployments, under 47 CFR 9.16. ## CLEC licensing: when you need a certificate **The general guidance:** - **Pure hosted VoIP (no facilities):** State treatment of VoIP varies widely. In some states, providers who don't own network facilities and resell SIP trunking from a licensed carrier may not need a CLEC (competitive local exchange carrier) certificate; others require registration or a VoIP-specific authorization instead (telecom law firm Bronston Legal tracks [state-by-state VoIP regulation](https://techlawyers.com/state-voip-regulation/)). - **Facilities-based service:** If you own switches, trunk lines, or interconnection points, you likely need a CLEC certificate in each state where you operate. - **FCC registration:** Regardless of state requirements, interconnected VoIP providers must register with the FCC's CORES system, file FCC Form 499-A/499-Q to report revenues for Universal Service Fund (USF) contributions, and report voice subscription data through the Broadband Data Collection (which replaced Form 477). ## STIR/SHAKEN: caller ID authentication If you're originating calls to the PSTN, you have STIR/SHAKEN obligations under [47 CFR 64.6301-64.6308](https://www.law.cornell.edu/cfr/text/47/64.6301). This framework authenticates caller ID to combat robocalling. Obligations now follow your network type, not your subscriber count: the earlier small-provider implementation extension expired on June 30, 2023. Provider / network typeRequirement Providers with IP networksFull STIR/SHAKEN implementation with SIP Identity headers Providers with non-IP network portionsRobocall mitigation program covering those portions All providersMust be listed in the FCC's Robocall Mitigation Database For a deeper dive on STIR/SHAKEN implementation, see our [STIR/SHAKEN guide for white-label operators](/blog/cloud-softphone/stir-shaken-white-label/). ## USF contributions Interconnected VoIP providers must contribute to the Universal Service Fund. The contribution factor changes every quarter; the FCC's proposed factor for Q3 2026 is 38.8% of interstate and international revenues (check the FCC's [quarterly contribution factor filings](https://www.fcc.gov/general/contribution-factor-quarterly-filings-universal-service-fund-usf-management-support) for the current rate). ## What Cloud Softphone handles Cloud Softphone addresses the app-level compliance requirements: - **E911 location reporting:** The app can collect and transmit subscriber location data to your E911 service provider. - **Direct 911 dialing:** 911 routes directly without prefix, compliant with Kari's Law. - **E911 callback reliability via SIPIS:** If a 911 call drops, the PSAP calls back. Cloud Softphone uses [SIPIS](/voip-glossary/sipis/), Acrobits' SIP Instance Server routing wake signals across FCM, APNs, and Local Push, to ensure that return call rings through even when the app is running in the background. WebRTC-based softphones generally cannot match the background wake reliability of native PushKit/CallKit VoIP apps (see [Apple's VoIP best practices](https://developer.apple.com/library/archive/documentation/Performance/Conceptual/EnergyGuide-iOS/OptimizeVoIP.html)). - **STIR/SHAKEN passthrough:** SIP Identity headers are supported at the protocol level. The business-layer obligations (USF contributions, FCC filings, state licensing, E911 provider contracts) remain your responsibility as the service provider. ## Six steps before you launch voice service StepAction 1Consult a telecom attorney on CLEC/state requirements 2Register with the FCC Robocall Mitigation Database 3Contract with an E911 aggregator (Intrado, Bandwidth, etc.) 4Implement STIR/SHAKEN or file mitigation plan 5Set up USF contribution tracking and reporting 6Deploy a compliant softphone app with location reporting Step 6 is where [Cloud Softphone](/cloud-softphone/) fits. The regulatory filings, licensing, and fund contributions are on you, but the app that your subscribers actually use can be deployed in weeks at a fraction of what it would cost to build compliant push infrastructure in-house. Published [Cloud Softphone pricing](/cloud-softphone/pricing/) runs roughly a $4K setup fee plus a $500/month subscription and per-user charges, against what we estimate at $500K to $1M+ in year one for a custom in-house build. Cloud Softphone works with any SIP softswitch: MetaSwitch, BroadSoft, FreeSWITCH, Asterisk, or your existing infrastructure. No stack migration required. Get the legal questions answered, then get the app deployed. { "@context": "https://schema.org", "@type": "Article", "headline": "E911 and Legal Requirements for ISPs Adding Voice", "description": "An ISP adding interconnected VoIP (service that can place and receive calls to and from the public telephone network) takes on four sets of obligations: E911 under FCC Part 9, including dispatchable location under RAY BAUM's Act and direct 911 dialing under Kari's Law; STIR/SHAKEN caller ID authentication for calls originated to the PSTN; FCC registration and Universal Service Fund contributions; and, depending on state and service model, CLEC or VoIP-specific state licensing. The E911 rules apply to every interconnected VoIP provider, with no small-entity exemption.", "url": "https://acrobits.net/blog/cloud-softphone/e911-legal-isp-voice/", "datePublished": "2026-05-06T09:00:00Z", "dateModified": "2026-05-06T09:00:00Z", "author": {"@type": "Organization", "name": "Acrobits"}, "publisher": {"@type": "Organization", "name": "Acrobits", "url": "https://acrobits.net"} }