911 Emergency Calling Disclosure
Effective date: October 26, 2026
Draft for review. This document is a starting template and is not legal advice. Have it reviewed by a qualified attorney before publishing.
Important: Please read this entire disclosure. 911 service provided through Your Brand works differently from traditional landline 911 service and has limitations that could affect your ability to reach emergency help.
This 911 Disclosure is provided by [Company Legal Name] ("we," "us," or "our") as required by Federal Communications Commission (FCC) rules for interconnected Voice over Internet Protocol (VoIP) services, including the rules at 47 CFR § 9.11. It is incorporated into our Terms of Service. "Customer" or "you" means the business that holds the account.
1. How 911 Works With This Service
1.1 When a user dials 911 from a phone number or device on your account, the call is routed through our network and a third party emergency routing provider to the public safety answering point (PSAP) that serves the Registered Location associated with that number or device.
1.2 In most areas, the call is delivered with the caller's callback number and Registered Location so the emergency dispatcher can see where to send help. In some areas, or in some failure conditions, the call may be routed to a national emergency call center or the location may not be displayed, and the caller will need to state their location verbally.
1.3 Users should always be prepared to tell the dispatcher their exact location and callback number, and should not hang up unless told to do so. If the call drops, call back.
2. Registered Location (Dispatchable Location)
2.1 What it is. The Registered Location is the street address, plus additional information such as suite, floor, or room, where the phone or device is used. This is the address emergency responders will be sent to. It should be specific enough to let responders find the caller, which is often called a dispatchable location.
2.2 Setting it in the portal. Each phone number on your account has a 911 address setting in the customer portal. You must enter a valid, complete Registered Location for each number before using it to make calls, and confirm the address validates successfully.
2.3 Keeping it current. You must update the Registered Location whenever a phone, user, or number moves to a different address, building, floor, or suite. If you do not, emergency services may be sent to the wrong location.
2.4 Accuracy. You are responsible for the accuracy of every Registered Location on your account. We do not independently verify that a device is physically located at its Registered Location.
3. Moving Devices and Nomadic Use
3.1 The Service can be used from any internet connection, and softphone and mobile apps can be used away from the office. This is called nomadic use.
3.2 If a desk phone, softphone, or mobile app is used at a location other than its Registered Location, a 911 call may be sent to the wrong PSAP and emergency responders may be sent to the wrong address.
3.3 Before using a device at a new location, update its Registered Location in the portal. Where the Service or app supports automatic location or prompting for a location, follow those prompts. If you cannot update the address, use another phone, such as a mobile phone using its native dialer or a landline, to call 911.
3.4 When using a mobile app, users should be aware that the app may place 911 calls through the Service rather than through the mobile carrier. [Confirm and describe the app's actual 911 behavior.]
4. Delays in Location Updates
4.1 After you add or change a Registered Location, it may take time for the update to be processed and loaded into emergency routing databases. During this period, 911 calls may route using the previous address or may not include location information.
4.2 Updates are typically processed within [X hours], but processing time is not guaranteed. During this period, use an alternative way to call 911 if possible, or be prepared to state your location verbally.
4.3 Newly activated or newly ported numbers may not have 911 location information available until provisioning is complete.
5. Power Outages
5.1 911 calls will not work during a power outage unless your internet equipment (modem, router, network switches) and phones have backup power.
5.2 After a power outage, you may need to reset or reconfigure your equipment before you can use the Service, including 911.
5.3 Consider using battery backup or an uninterruptible power supply for your network equipment and phones. Backup power has limited duration.
6. Internet and Broadband Outages
6.1 911 calls will not work if your internet or broadband connection fails, is congested, or is degraded.
6.2 911 calls will not work if our service or our providers' networks experience an outage, or if your network configuration (such as a firewall) blocks the Service.
6.3 Poor network quality can cause calls to fail, drop, or be difficult to hear.
7. Suspension, Termination, and Other Service Interruptions
7.1 911 will not work if your account is suspended, including suspension for non-payment, or if your account or the specific phone number is cancelled or terminated.
7.2 911 may not work if the phone number has been ported out, released, or is not yet fully provisioned.
7.3 911 may not work during scheduled maintenance or service interruptions.
7.4 911 may not work if a device is not registered, is misconfigured, or if a user has changed device settings.
8. Multi-line Telephone Systems, Kari's Law, and RAY BAUM'S Act
8.1 The Service is a multi-line telephone system (MLTS). Federal rules implementing Kari's Law and RAY BAUM'S Act apply to MLTS.
8.2 Direct dialing. Under Kari's Law, users must be able to dial 911 directly, without first dialing a prefix such as 9 or any other code. Do not configure dial plans or devices in a way that prevents direct 911 dialing.
8.3 Notification. Kari's Law also requires that an MLTS be configured, where technically feasible, to notify a central location (such as a front desk or security office) when a 911 call is made. Where the Service supports 911 notifications, you are responsible for configuring a notification recipient (such as an email address or extension) in the portal and keeping it current. [Confirm and describe available notification features.]
8.4 Dispatchable location. RAY BAUM'S Act rules require that 911 calls from MLTS and VoIP services convey a dispatchable location, meaning a validated street address plus additional information such as floor, suite, or room needed to locate the caller, where technically feasible. Your accurate and specific Registered Location entries are essential to meeting this requirement.
8.5 Depending on how you use the Service, you may have your own obligations as the operator or installer of an MLTS. You are responsible for understanding and meeting those obligations. Consult your own legal counsel if needed.
9. Your Obligations to Inform Users and Label Devices
9.1 You must inform every person who uses or may use the Service on your account, including employees, contractors, and visitors, of the 911 limitations described in this disclosure.
9.2 You must place a 911 warning label on or near every phone and device used with the Service, including desk phones and conference phones. Warning labels are available from us on request at support@example.com or for download in the portal. [Confirm label availability.] Do not remove labels.
9.3 For softphone and mobile app users, you must make sure users have read this disclosure and understand the limitations of nomadic use.
9.4 You must make sure users know how to update the Registered Location, or whom to contact to update it, when they move.
10. Other Limitations
10.1 911 calls may be routed to a PSAP that is not equipped to receive the callback number or Registered Location, in which case the caller must state this information.
10.2 Text to 911, TTY, and other accessible 911 services may not be supported through all devices or applications. [Confirm and describe supported options.]
10.3 Calls to 911 from fax lines, IVR or auto attendant menus, ring groups, or virtual numbers that are not tied to a specific device may not deliver accurate location information. Use a phone assigned to a specific user and Registered Location to call 911.
10.4 Do not make test calls to 911. If you need to test 911 routing, contact us first at +1 (555) 010-0000 so we can arrange an approved test, such as a test call to a designated test number where available.
10.5 We strongly recommend that you maintain an alternative way to reach emergency services, such as a mobile phone or landline.
11. Limitation of Liability for 911
11.1 To the fullest extent permitted by law, neither [Company Legal Name] nor its officers, employees, agents, carriers, or emergency routing providers will be liable for any claims, damages, losses, fines, or expenses arising from or related to: (a) the inability to dial 911 or reach emergency services using the Service; (b) misrouting of 911 calls; (c) inaccurate or missing location or callback information, including where the Registered Location was not provided, not updated, or is inaccurate; (d) delays in processing location updates; (e) power, internet, equipment, or network failures; (f) suspension or termination of the Service; or (g) the acts or omissions of PSAPs, emergency responders, or third party providers.
11.2 You agree to defend, indemnify, and hold harmless [Company Legal Name] and the parties listed above from any claims by you, your users, or third parties arising from 911 calls made using your account, including claims related to the accuracy of Registered Locations or your failure to inform users of these limitations, except to the extent caused by our gross negligence or willful misconduct or as otherwise limited by law.
11.3 Some jurisdictions do not allow certain limitations of liability. In those jurisdictions, our liability is limited to the extent permitted by law.
12. Customer Acknowledgment
By creating an account, activating a phone number, or using the Service, you acknowledge and agree that:
- You have received, read, and understand this 911 Disclosure.
- 911 service through the Service has the limitations described here, including during power outages, internet outages, account suspension for non-payment, and when devices are moved.
- You will provide and keep current an accurate Registered Location for every phone number and device on your account.
- You will configure your system to allow direct dialing of 911 and, where supported, 911 notifications.
- You will inform all users of these limitations and place warning labels on all devices.
- You accept the limitation of liability and indemnification provisions in this disclosure.
We may require an authorized representative to confirm this acknowledgment electronically in the portal. We keep a record of your acknowledgment as required by FCC rules.
13. Contact
For questions about 911 service or help updating your Registered Location:
[Company Legal Name] [Street address, City, State ZIP] Email: support@example.com Phone: +1 (555) 010-0000 Website: https://example.com
In an emergency, if 911 through the Service does not work, use another phone to call 911.