911 for hosted phones in Canada: what a reseller must know
This is a plain-words guide, not legal advice. It sets out what is well established about 911 on internet phones in Canada, and points you to the public sources. Read them, and ask a lawyer about your own obligations.
Resources · Published 2026-10-18
Rules change and some of the sources above are archived. Treat this page as a starting point. Telquay is confirming with a lawyer which rules apply to it and to partners, and will tell each partner in writing before they sign. We make no claim of any registration or approval on this site.
Why hosted phones are different
A traditional phone line is fixed to one place. When someone dials 911, the network knows which building the line serves, and help goes there. A hosted phone is a number carried over the internet. The number does not belong to a place by itself, so the service has to be told where it is.
The civic address is the whole game
For a number to reach the right emergency centre, the provider must have a correct civic address stored against it. That address travels with the call. If it is missing, wrong or out of date, the call can reach the wrong place or take longer to route.
- Collect a civic address for every number before it goes live.
- Use a street address, not "head office" or a post office box. Include the suite or floor if there is one.
- Record a new address whenever the client moves or a user relocates.
- Decide who owns that job. In a white-label arrangement it is usually the partner who knows the client moved, so write it into your agreement.
Softphones and mobile apps
A softphone on a laptop or mobile app can be used from anywhere. 911 sends help to the address stored for the number, not to where the person is standing. A user who works from home or travels must understand this, and must keep a correct address on file for the number they use.
Power and internet outages
A hosted phone needs power and an internet connection to make any call, 911 included. In a power or internet outage the desk phones may not work. Clients who depend on phones in an emergency should keep another way to call, such as a mobile phone, and know that is the reason.
What customers must be told
Canadian rules from the VoIP 9-1-1 decisions require service providers to tell customers about the limits of 911 on internet phones before service starts and to get their acknowledgement. The rules set minimum content for the notice. Pass the limits on to every customer, in writing, and keep a record that they accepted them. At a minimum, cover:
- 911 depends on the address you have on file and must be kept current.
- Softphones and apps may be used away from that address.
- 911 may not work in a power or internet outage.
- How to update an address, and who to tell.
Check the exact wording against the current CRTC decisions; the source below is the starting point.
Testing
Never test 911 by placing an emergency call. Use a test route that ends in a recording, or the method your carrier gives you. Test after any change to addresses or routing.
Questions for any platform provider
- How is the civic address stored for each number, and how do I change it?
- Does the address go to the carrier with each call? How is it registered?
- What do you do when an address is missing?
- What notice text do you supply, and who keeps the customer's acknowledgement?
- Which rules apply to you, and which to me as a reseller?
Our own approach is on the 911 and compliance page. If you plan to resell hosted phones, see phones for MSPs or become a partner and ask us the questions above.
Sources
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