DVGVoIP — Thunder Bay, Ontario

The Ontario VoIP 9-1-1 Compliance Checklist

CRTC obligations for every business running VoIP — with the employee notice template you legally need on file.

Why VoIP 9-1-1 Is Different

VoIP 9-1-1 is regulated by the CRTC under a distinct framework from traditional wireline and wireless 9-1-1. Because a VoIP phone can physically move to any address, on any internet connection, the CRTC requires providers and their customers to jointly maintain location accuracy — and to acknowledge the service's limitations in writing. Most Ontario businesses using VoIP today are out of compliance with at least one of these obligations without knowing it.

This checklist walks through the four things every VoIP-using business must do, the CRTC rules that require them, and the employee-notice template you need to have on file.

The Four Major VoIP 9-1-1 Limitations

LimitationWhy it matters
Power outageVoIP phones run over internet-connected hardware (IP phones, softphones, routers). When power fails, phones fail. Traditional copper wireline phones often stayed up during outages because they drew power from the telco's central office. VoIP does not.
Internet outageNo internet, no VoIP. If your connection is down, 9-1-1 calls won't complete over VoIP. Mobile cellular service is the realistic backup for emergencies during outages.
Address registrationVoIP providers rely on a customer-registered address to route 9-1-1 calls to the correct Public Safety Answering Point (PSAP). If the address is outdated or wrong, emergency responders may be dispatched to the wrong location.
Nomadic useA VoIP phone or softphone used away from its registered location (home office, hotel, coffee shop) still reports the registered address to 9-1-1 — not the caller's actual location. The caller must verbally confirm the actual address during any 9-1-1 call placed from outside the registered site.
Critical for multi-site operations: A VoIP extension registered at your Thunder Bay head office, but in use by a remote worker in Nipigon, will route 9-1-1 to the Thunder Bay PSAP with the head-office address. The CRTC framework treats this as the customer's responsibility to manage — through notice, acknowledgment, and staff training.

What the CRTC Actually Requires

Under Telecom Regulatory Policy CRTC 2009-40 and Telecom Decision CRTC 2010-387, all Canadian VoIP service providers and their business customers must satisfy the following:

1. Written notice of limitations

The VoIP provider must notify each customer — in writing, before service activation — of the specific 9-1-1 limitations that apply to the service being purchased. This notice must cover power/internet dependency, address registration, and nomadic use. The notice must appear in:

2. Signed customer acknowledgment

Before activation, the customer must sign (physical or electronic signature) confirming they have read and understood the limitations. For businesses, this acknowledgment should extend to all employees who will use the service — which is why a per-employee notice is good practice even when the master acknowledgment is signed by a single authorized signatory.

3. Address confirmation and update mechanism

Telecom Decision CRTC 2010-387 (June 2010) specifically requires providers of nomadic and fixed/non-native VoIP services to:

For a business running a hosted PBX across multiple sites, this means each DID (direct inward dial) or extension associated with a physical location must have that location registered and kept current.

4. Phone-side warning (sticker or printed notice)

Most providers include a VoIP 9-1-1 warning sticker designed to be placed on or near every VoIP phone. The CRTC does not mandate a specific sticker format, but the notification obligation is ongoing — so a visible reminder near the handset is how most Canadian VoIP providers satisfy it for the day-to-day user.

The Compliance Checklist

Go through each line. Any "no" is an open compliance item.

  1. Our VoIP provider has given us written notice of 9-1-1 limitations YESNO
  2. An authorized person at our business has signed the acknowledgment and we have a copy on file YESNO
  3. Every employee who uses the phone system has received a written copy of the limitations notice (template below) YESNO
  4. We know the physical address registered against each DID and extension YESNO
  5. We have a documented process for updating addresses when staff move or new extensions are added YESNO
  6. Remote workers using the VoIP system from home have been instructed to verbally confirm their actual location on any 9-1-1 call YESNO
  7. A visible 9-1-1 limitation notice (sticker, printed card) is present at every VoIP phone or reception area YESNO
  8. We know which of our staff use mobile softphones outside the registered location YESNO
  9. We have documented our backup plan for when internet or power is down and 9-1-1 can't be placed over VoIP (typically: use a cell phone) YESNO
  10. Our business continuity plan references the VoIP 9-1-1 limitations and backup plan YESNO
  11. We review this checklist annually or whenever we change providers, locations or staff YESNO

Employee Notice Template

Print one copy per employee. Have each employee sign and date. Keep the signed copies on file with HR or whoever maintains your compliance records. This satisfies the spirit of the CRTC's ongoing notice obligation at the staff level.

VoIP 9-1-1 SERVICE — LIMITATIONS NOTICE AND ACKNOWLEDGMENT This notice is given under the Canadian Radio-television and Telecommunications Commission (CRTC) rules governing Voice over Internet Protocol (VoIP) 9-1-1 service — Telecom Regulatory Policy CRTC 2009-40 and Telecom Decision CRTC 2010-387. Employer: _______________________________________________ Employee: _______________________________________________ VoIP extension: ______ Primary work location: _____________________________ VoIP 9-1-1 is NOT the same as traditional wireline or wireless 9-1-1. The following limitations apply: 1. Power outages. Our VoIP phones will not work during a power outage. If a power outage occurs and you need emergency services, use a mobile phone. 2. Internet outages. Our VoIP phones will not work when our internet connection is down. If an internet outage occurs and you need emergency services, use a mobile phone. 3. Registered address. The address registered with our VoIP provider is the address that will be displayed to emergency responders when a 9-1-1 call is placed from your extension. The registered address for your extension is: ____________________________________________________________ 4. Using the phone outside the registered address. If you use the VoIP system (including the mobile or desktop softphone) from any location other than the registered address — including your home, a hotel, or any remote worksite — and you place a 9-1-1 call, emergency responders will initially be directed to the registered address above. You MUST verbally confirm your actual physical address to the 9-1-1 operator at the start of the call. 5. Address updates. If your primary work location changes, you must notify ________________________ (role, e.g. Office Manager) so the registered address can be updated with our VoIP provider. By signing below, I acknowledge that I have read and understood the limitations of VoIP 9-1-1 service. Signature: ______________________________ Date: ___________________

Multi-Site and Remote Worker Considerations

Annual Review

Set a recurring calendar item: Review this checklist, the list of registered addresses against every extension, and the employee notice file once per calendar year — or immediately on any of: a move, a new site, a staff turnover exceeding 20%, or a provider change. Most compliance gaps are introduced by one of those events.

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