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The Impact of 3G Network Shutdowns on Reliable Emergency Calling

  • Summary:
    • The potential impact of 3G network shutdowns on the ability to contact emergency services has been a concern in international attempts to manage these shutdowns. This is a public safety issue–with risks for older people, remote people, and those unable to afford upgrades.
    • In Australia in 2024, concern that 740,000 mobiles might be unable to contact emergency services led the Minister for Communications established a Working Group–including industry representation–to better manage the 3G shutdown transition.
    • Safety concerns in other countries have delayed previously planned 3G network shutdowns and also resulted in 2G networks staying active as a backup.

The critical importance of being able to contact emergency services has influenced how various countries have approached their 3G shutdown. In Aotearoa, there were 686,135 emergency calls for ambulance services in 2024. For the year ended June 30, 2024, Fire and Emergency New Zealand answered 95,619 emergency calls and the Police answered 992,873 emergency calls. If even a small percentage of emergency calls were unable to get through, the number of calls affected could be in the tens of thousands. This page contains a brief description of efforts to manage the risk to emergency calls during 3G mobile network shutdowns.

The impact of 3G network shutdowns have been considered from the point of view of business impacts and the level of inconvenience to some mobile phone customers but a major factor that has drawn public attention is the risk of some people not being able to make emergency calls on mobile phones that don’t support calls over 4G using VoLTE. Mobile network operators will have an idea of how many devices are actively using their 3G network. However, concern was raised–particularly in Australia–when it was realised that a significant number of mobiles that supported 4G for data did not support the VoLTE standard for voice calling. Some older mobiles were also configured to use 3G networks for emergency calling, unbeknownst to their owners.

Broadly, there seem to be four kinds of actions in the lead-up to 3G network shutdowns:

  • aiming to get an accurate measure of how many devices will be impacted;
  • delaying shutdown to extend the amount of time people have to upgrade their devices and expand 4G network coverage;
  • publicity campaigns to ensure that customers are aware of dangers of not being able to make emergency calls;
  • and providing additional support for people through the 3G shutdown who are more likely to be negatively impacted–older people, people in rural areas, and people with limited budgets.

How do Emergency Calls Differ from Normal Calls?

Let’s begin with a brief description of how emergency calls work.

The New Zealand Telecommunications Forum (TCF) Emergency Calling Code sets the quality standards that call providers must provide for emergency calls. There are some elements of emergency calls that differ from how regular calls are handled.

In a regular mobile calling situation, your Subscriber Identification Module (SIM) card will be used to determine which company’s mobile network your phone will use for calling. The signal strength bar on your phone only shows the signal strength of the connection to your mobile network’s nearest tower. Other companies may have towers closer to you that have a stronger signal but you won’t see the signal strength for any cellular base stations in their network because you do not have a mobile subscription with those companies.

Diagram of the Path of an Emergency Call from the TCF Emergency Calling Code (2022), page 8.

Emergency calls are different. The TCF Emergency Calling Code specifies special criteria for emergency calls that reflect how critical it is for 111 calls to reliably get through to the right service (police, fire, ambulance) as quickly as possible.

First, cell sites belonging to any network (not just the mobile network you have a plan with) must transmit the call. This ensures that the call will be placed over networks with the strongest signal strength, which might not be the mobile provider that you have an account with. Second, emergency calls are prioritised on mobile networks. If there is network congestion, emergency calls are prioritised as it is vital that emergency calls are not dropped. Third, if there are different levels of call quality, then emergency calls must be delivered at the highest call quality. Fourth, if you have a SIM card, then your phone number and limited identifying information is supplied to the emergency services. And lastly, the geographical position of the cell site that the mobile phone is connected to is also provided.

After the 3G shutdown, your mobile phone will need to support 4G calling with VoLTE to make emergency calls.

The Emergency Calling Code sets emergency call quality standards at a high bar because a fast response to emergencies can be the difference between life and death. The extraordinary importance of being able to make emergency calls is also reflected in the 111 Contact Code, that ensures that telecommunications companies make landline customers aware that they cannot make landline emergency calls during power cuts and that those companies also provide vulnerable customers with alternative means of communication, if needed. These codes emphasise the importance of reliable emergency communications for public safety.

Australia

In 2019, Telstra announced plans to shut its 3G network by the end of June 2024. Optus later planned to close down its network on September 1, 2024. (Vodafone shut down its 3G network in January, 2024.) However, in March, 2024, the Australian Government became concerned that 740,000 mobiles might not be able to make emergency calls after the 3G shutdowns and formed a Working Group to manage the shutdowns. The Minister for Communications, Michelle Rowland, became alarmed at the large number of people who had 4G mobiles for data but that did not support VoLTE for calling, and particularly emergency calling. Many of these customers might have no idea that their phone wouldn’t work as the public awareness campaigns had mostly focused on upgrading to a 4G phone. The Michelle Rowland described the purpose of the Working Group as follows:

The Working Group will formalise collaboration between industry to better identify impacted customers, improve the accessibility of public-facing information and contact points, and amplify messages to ensure the community is aware of the switchover.

At the end of March, the Australian Senate’s Rural and Regional Affairs and Transport Committee began an inquiry into the 3G mobile network shutdown. In April, the estimate of the affected number mobile phones was revised and increased to over 1 million. At the beginning of August 2024, the Senate Committee Inquiry returned an interim report recommending that the 3G shut down be delayed until equivalent or better 4G coverage was in place and that people with affected devices will be contacted. The report also suggested potential Ministerial intervention if the networks did not do this voluntarily. Both Optus and Telstra extended their shut down dates to October 28.

On August 21, the Minister of Communications directed the Australian Communications and Media Authority (ACMA) to amend the “Telecommunications (Emergency Call Service) Determination” so that after the 3G network shutdown, mobile companies would deny carriage to mobile phones identified as not able to call emergency services.

The government approach could be described as erring on the side of caution, introducing measures to ensure that if there was any doubt about emergency calling using 4G with VoLTE on customers’ phones, those customers would most definitely be aware of this risk. Their measures indicated that it was deemed better that, where there was any doubt, phones that would actually be functional on the 4G network would clearly not supported by mobile networks rather than the other case where people were unaware that they were carrying phones that were actually non-functional for emergency calling purposes.

There were critics of the directive who claimed that it created a conflict of interest. There were claims that some mobiles that were in fact capable of 4G calling with VoLTE were blocked from calling by mobile operators. They also argued that this caused unnecessary purchasing of new phones specifically from the mobile networks (to ensure compatibility), which benefited those companies.

In the months before the October 3G shutdown:

Here is a video from tech vlogger Hugh Jeffries on the Australian 3G network shutdown.

After the 3G shutdown, on January 30, 2025, Telstra opened a helpline for customer issues related to the 3G shutdown. Community support groups are now assisting older people who have been caught out by the shutdown. Some members of those support groups have criticised the public awareness campaign for assuming that everyone was digitally connected and they argue that physical mailers should have been sent to customers who were less likely to be online.

Note that the Senate Committee inquiry runs until February 25, 2025, to include reports of the impact of the shutdown. Stay tuned.

Global efforts: Backup Networks and Delaying Shutdown

Here is a small selection of initiatives from other countries in relation to their 3G networks.

Some countries have kept their 2G networks running even as they have shut down their 3G networks. This allows the old 3G frequencies to be repurposed for newer technologies while also allowing emergency and critical communications for 2G compatible devices (e.g., older mobiles, medical devices, other industrial equipment) as well as maintaining coverage in rural areas. The UK and Germany have taken this approach and you can view other countries where mobile networks have taken a similar stance toward maintaining their 2G networks for the better part of the rest of the decade here. (Note that in Aotearoa, the only 2G network is run by One NZ and they plan to switch off their 2G network at the same time as the 3G network at the end of 2025.)

In France, 2G is scheduled to be shut down in 2026, followed by 3G by 2029. However, Frances Elevator Federation | Fédération des Ascenseurs have requested that the shutdown be extended by at least two years to give enough time to upgrade lift technologies, which includes emergency phones. The Federation estimates that there are at least 200,000 2G devices and nearly 60,000 3G devices that need replacement in France.

In India, one mobile company developed an app called JioCall that enabled 4G phones without VoLTE to make calls over their mobile network. (However, this app did not support emergency calls.)

Aotearoa

In 2022, One NZ announced that they planned to shut down their 3G network on August 31, 2024. This was subsequently delayed to March 31, 2025 and then further pushed out to December 31, 2025, to line up with Spark NZ and 2degrees. One NZ are similarly planning to close down the last 2G network in Aotearoa at the end of 2025. (That would put us in the same situation as Australia in not having both a 3G and 2G network.) So it is imperative that everyone is ready for this dramatic reliance on 4G and 5G calling.

There have been some press releases about the 3G shutdowns but little media attention about the impact on contacting emergency services. The major mobile networks have emailed and text messaged customers who have devices that may not be 4G and VoLTE compatible to advise that they upgrade. Each of the major mobile companies have web pages about the 3G shutdown. And One NZ has printed pamphlets in store.

However, there is not major public awareness of the risks of 4G phones that do not support VoLTE or of phones that support VoLTE for regular calls but that revert to 3G for emergency calls. There also does not seem to be an accurate measure of the number of phones/devices that would be affected by the shutdown.

Sam Fenwick from Opensignal notes the potential safety risks related to people getting caught out from the 3G network closure:

In the absence of 2G and 3G networks, the only way of making normal mobile voice calls is via Voice over LTE (VoLTE) or its 5G standalone access equivalent — Voice over New Radio (VoNR). […] Devices that aren’t 4G capable and even some older 4G devices don’t have these capabilities, posing safety issues given the need to make emergency calls.

In comparison to our neighbour Australia, it seems that insufficient attention is being paid by mobile services in Aotearoa to the risk to the public of not being able to contact emergency services after the 3G shutdown. Relatedly, there are currently inadequate provisions to support vulnerable customers through the 3G shutdown.

Our 3G network shutdowns are planned for the end of this year so there is time for more to happen in this space.

Page Last Updated February 6, 2025.