Access Alert: Ireland launches public consultation on emergency caller location information obligations

Providers of publicly available number-based interpersonal communications services in Ireland must ensure that end-users can access the emergency services free of charge by using the single European emergency number “112” or the national emergency number “999” via voice calls, SMS and, eCalls.

The preciseness of emergency caller location information is crucial for effective call handling and timely routing to emergency services. As a result, the Commission for Communications Regulation (ComReg) has launched a public consultation on accuracy and reliability criteria for communications to emergency services.

ComReg proposes that in the case of fixed emergency communications, information related to the physical address of the network termination point will be the Eircode (allocated under the Irish postcode system) or the geographic coordinates of the address (if available) and the installation address (if not).

The vast majority of calls to emergency services are made using mobile phones. This percentage continues to increase. For mobile emergency calls, the Cell ID (a number used to refer to the cell from which the caller is calling) must be provided in every instance.

ComReg is of the view that mobile operators should be required to make all reasonable efforts to keep the mobile network topology data provided to the Emergency Call Answering Service (ECAS – the Irish term for a Public Safety Answering Point) up to date, as well as to provide accurate, rather than default, values for cell area and azimuth.

ComReg’s approach aims to establish measures that will enhance accuracy and reliability within the limits of technical feasibility. However, it should be noted that the legal framework governing the provision of emergency services has been drafted with “traditional technology” in mind.

As a result, the provision of emergency services using VoIP falls into a grey area, with uncertainty regarding the extent to which VoIP providers are subject to the obligation to provide access to emergency services. The public consultation is equally silent on the applicability of emergency services obligations for VoIP providers.

With the use of fixed telephony becoming obsolete and a shift in individual and enterprise end-users’ preference towards the use of VoIP telephony, it is crucial to put in place a legal framework that not only ensures the welfare and safety of citizens and the prompt dispatch of life-saving services but also aligns with the current technical advancements of market tendencies.

ComReg has invited stakeholders to provide comments on the proposed measures by 5 February 2024. If you are interested in learning more about Irish legislation or require support in sending comments to ComReg, please contact Chrystel Erotokritou, Compliance Manager, at [email protected], Sofia Stellatou, Policy Analyst, at [email protected], or Juliana Ramirez, Senior Manager, at [email protected].