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In the winter of 1944, Allied commanders knew the importance of preparation. 

After all, a bad map in the Ardennes could send an armored division straight into an ambush. In modern warfare, the stakes are even higher, as soldiers rely on satellite imagery, GPS-guided movement, encrypted communication networks, and real-time data fusion to stitch intelligence together. If any of those systems fail – if the digital “map” is corrupted or their comms aren’t aligned with command – the consequences ripple through the battlefield. Today’s public safety leaders are preparing for a similarly high-stakes mission.

In this sense, December isn’t just another month on the calendar — as holiday lights go up, the countdown begins for PSAPs and 9-1-1 authorities to lock in their readiness, certify their “Valid Requests,” and trigger the carrier timelines that dictate whether their regions enter NG9-1-1 on schedule or slip behind.

For agencies that have already filed, the clock is ticking. For everyone else, right now is the time you should be preparing your GIS data for NG9-1-1. December is the moment to kickstart your 2026 plan, validate your infrastructure, and ensure your request meets every FCC requirement before its 2026 NG9-1-1 compliance push.

Once your “maps” are in order and your Valid Request is certified, the battlefield shifts from strategy to execution. That’s where the FCC’s compliance windows come into play, and the clock starts dictating the pace.

The Crunch: 6-Month vs. 12-Month Compliance Windows

Under the FCC’s framework, Originating Service Providers (OSPs) must implement NG9-1-1 in two phases, each within a default timeframe once a Valid Request is made. 

Major nationwide carriers (like the big wireless and VoIP providers) have six months to comply with Phase 1 requests (and another six for Phase 2), while smaller or rural carriers get 12 months per phase.

What does this mean in practice?

If you submitted a request in mid-2025, national carriers should be delivering NG9-1-1 calls by year-end and calls with properly formatted location information by mid-2026, whereas rural telcos might have until mid-to-late 2026. Every month you delay your request pushes your region’s NG9-1-1 go-live further out and ensures you will continue to pay for legacy 911 location information. 

Use this time wisely to avoid being left behind.

What Makes a Request “Valid”? (Checklist for PSAPs)

Not just any letter or email to a carrier will do – the FCC defines a Valid Request with specific readiness criteria. Before you ring in the new year, double-check that you have all the pieces in place for a Phase 1 request. 

These include the following:

Infrastructure Installed & Operational: You must certify you are technically ready to receive 9-1-1 calls via SIP (Session Initiation Protocol); meaning all necessary NG9-1-1 network components are in place and working. This includes an IP-enabled 9-1-1 system (ESInet connection, i3-capable systems) that can receive SIP calls and then route them to your PSAP equipment. In short, your network and call-handling gear should be NG9-1-1-ready (or have gateways to handle IP calls).

Designated NG9-1-1 Delivery Point(s): Identify your NG9-1-1 ingress points, or at least one in-state network demarcation where carriers will deliver the IP calls. Typically, this could be a point on your ESInet or an aggregator point. You’ll need to provide details like the location (often by ZIP code) of these delivery points to the carriers.

Commitments from Service Providers: Have you lined up your ESInet provider, NG9-1-1 Core Services provider, and call-handling equipment vendor to support this transition? The FCC requires certification that you have agreements or commitments with these partners to conduct any needed connectivity testing within the carrier’s compliance window. Essentially, you’re saying, “Our vendors are on board and ready to plug in and test alongside the carrier in time.”

Authorized and Registered: Ensure the request comes from the proper authority – you should certify that your agency has the legal authority to request NG9-1-1 and that you’re authorized to do so. The FCC also encourages registering your request in their NG9-1-1 database (docket) once available, so consider filing the FCC’s optional valid request form in addition to notifying carriers. This public filing isn’t mandated, but it adds transparency and helps track progress.

Our NG9-1-1 Knowledge Gateway provides detailed resources covering these points and more. Take advantage of that resource to ensure your submission is airtight. Remember, a complete and valid request is your ticket to start the countdown for carrier compliance.

Testing & Validation: The Hidden Bottlenecks

Even with a solid plan, many agencies find testing and data validation to be the hardest part of the transition. NG9-1-1 isn’t just about new network pipes; it also introduces new data workflows for location and routing. While you are working on Phase 1 and receiving calls in an IP format, you should also be preparing your location data and validation process for Phase 2. 

In Phase 2 especially, your systems must handle rich location data (like precise coordinates and properly formatted addresses embedded in the call signaling). That’s where components like the Location Validation Function (LVF), Location Information Server (LIS), and Emergency Call Routing Function (ECRF) come into play. 

These ensure that an incoming caller’s location is valid, retrievable, and usable for routing to the correct PSAP. It’s complex, and many early adopters have learned that “data readiness” can make or break your timeline.

Why are these items potential bottlenecks? 

Consider the LVF: it checks caller address from the LIS against your GIS data that you have stored in the ECRF. If your GIS data (road centerlines, address points, etc.) has errors or isn’t up to the latest NENA standards, the LVF may reject valid addresses or flag issues, slowing down your deployment. 

In fact, civic address validation via the LVF is cited as an area of particular concern for Phase 2 requests. Many 9-1-1 authorities underestimate how much cleanup their GIS needs to pass muster. 

Similarly, a LIS must be set up to store or generate location info for devices that don’t send it directly – a new responsibility that may require coordination with carriers or additional infrastructure. And your ECRF (the GIS-based routing database) needs to be configured with your jurisdiction’s data and tested to ensure it routes calls correctly for every possible location. 

These tasks can be time-consuming, often requiring iterative testing cycles. It’s no wonder that this is place where projects stumble; a single address error could send a call to the wrong PSAP, so the bar for accuracy is high.

Making December Count: Tips to Meet the Deadline

Rather than a slow period, December 2025 should be a sprint for NG9-1-1 readiness. Here are some ways to use this month wisely and stay on track for 2026 compliance:

Finalize Your Valid Request: If you haven’t sent your request to OSPs yet, now is the time. Double-check the checklist above, coordinate with your state or regional authority (if they’re filing on behalf of local PSAPs), and get that request out the door. The FCC’s rules allow and encourage filing as soon as you’re ready – there’s no benefit to waiting.

Complete Internal Testing: Use the relative quiet of the holidays to run internal tests on your NG9-1-1 systems. For example, verify that your LVF correctly validates a sample of local addresses, test your GIS data in an ECRF for a few test calls (does the route come back correctly?), and ensure your SIP call handling equipment can ingest 9-1-1 calls with location. Identifying and fixing issues now, before carriers are involved, will save precious time later.

Coordinate with Carriers and Vendors: Reach out to your carrier contacts now to sketch out testing schedules. National carriers, in particular, face a six-month shot clock once your request is in. Aligning schedules in advance can prevent last-minute scrambles. Likewise, engage your ESInet and core service vendors to ensure they have resources allocated during the compliance window (for example, to do joint test calls or troubleshoot interconnect issues). December is a great time to confirm everyone’s holiday on-call/support arrangements and kickoff plans for Q1.

Documentation and FCC Filing: If you plan to register your request with the FCC, have that documentation ready to go. The FCC’s PSHSB opened a special docket for NG9-1-1 requests, so prepare your filing (which may include the request letter and a cover sheet or form). While voluntary, filing with the FCC helps federal stakeholders monitor progress and could help if any disputes arise.

Ensure your ECRF and GIS Interfaces do the work: You have worked hard to get your address points and road centerlines into a NENA complaint status. Your ECRF and GIS interface should be able to support multiple workflows, make recommendations on how to correct errors, leverage multiple data sources to ensure you have the best data, and integrate with other GIS tools (like ESRI). Don’t hesitate to reach out to the 1Spatial team and we will walk you through the 1Spatial way of meeting these challenges. 

By tackling these action items now, you’ll enter 2026 with momentum – instead of playing catch-up.

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