In August 2019 the FCC adopted rules implementing two federal laws that strengthen emergency calling from multi-line telephone systems: Kari's Law and Section 506 of RAY BAUM'S Act. They are frequently spoken about as one requirement. They are not — they ask for different things, and an estate can satisfy one while failing the other.
Kari's Law: reach 911, and tell someone
Kari's Law is named for Kari Hunt, who was killed in a motel room in Marshall, Texas in 2013. Her nine-year-old daughter tried to call 911 four times from the room phone. None of the calls connected, because she did not know the motel's phone system required dialing "9" for an outside line first.
The law imposes two obligations on organizations operating an MLTS:
- Direct dialing. Users must be able to dial 911 directly from any device capable of making a call, without a prefix, postfix, or trunk access code. Requiring a 9 first is no longer acceptable.
- On-site notification. When a 911 call is placed from the system, on-site security or designated staff must be notified.
RAY BAUM'S Act: say where the caller is
Section 506 of RAY BAUM'S Act requires that 911 calls convey a dispatchable location. The FCC defines this as a location delivered to the Public Safety Answering Point with a 911 call, consisting of the validated street address of the calling party plus additional information such as suite, apartment, or similar detail.
In practice, the obligation is to supply:
- A validated street address
- Additional detail sufficient to locate the caller — building, floor, suite, or room
- A valid callback number
On a campus, the street address alone is close to useless. "1 Hospital Way" tells responders nothing when there are nine buildings and eleven floors. The additional detail is the whole point of the requirement.
Scope and compliance dates
The dispatchable location rules apply to MLTS manufactured, imported, offered for first sale or lease, first sold or leased, or installed after 16 February 2020. Compliance deadlines of 6 January 2021 and 6 January 2022 apply depending on the nature of the device from which the MLTS 911 call originates.
Both dates are long past. The practical question in 2026 is not whether the deadline has arrived — it is whether your estate actually complies, and whether you could demonstrate it.
The three device categories
This is where most implementations fall short, because the obligation is defined differently for each category and organizations tend to solve only the first.
| Category | Example | Obligation |
|---|---|---|
| On-premises, fixed | Desk phone in a known office | Must provide automated dispatchable location with the 911 call. The system determines it; the user is not asked. |
| On-premises, non-fixed | Softphone on a laptop, wireless handset moving between floors | Automated dispatchable location where technically feasible; otherwise alternative location information sufficient to route and dispatch. |
| Off-premises | Home worker, agent on a softphone anywhere | Dispatchable location where technically feasible; otherwise alternative location, which may be user-provided and must be maintainable and updatable. |
Compliance applies to any facility using an MLTS — corporate offices, hotels, hospitals, college campuses, and similar.
How dispatchable location is actually determined
There is no single mechanism. Most estates need several, layered by device category.
| Method | Works for | Limitations |
|---|---|---|
| Switch port / patch panel mapping | Fixed desk phones on wired ethernet | Only as accurate as the cabling records, which decay. Needs a maintenance process, not a one-off survey. |
| LLDP-MED / network element discovery | Wired IP phones | Requires switch support and consistent configuration across the estate. |
| Wireless access point association | Wi-Fi handsets and softphones on site | AP-to-location mapping must be maintained; coverage overlap can put a device on the wrong floor. |
| Subnet / VLAN mapping | Coarse building-level location | Too coarse on its own for a large building. Useful as a fallback layer. |
| User-declared location | Off-premises and remote workers | Depends on users updating it. Needs prompting on network change and periodic reconfirmation. |
| Location service provider integration | All categories | Usually the practical answer at scale. Verify what your platform natively supports before assuming. |
An assessment checklist
- Census every endpoint by category. Fixed, nomadic on-site, off-premises. Include the systems people forgot were still connected.
- Test direct dialing from every system. Actually dial — using a test number or in coordination with your PSAP, never a live 911 call for testing. Legacy PBXs hiding in a corner are exactly where a prefix requirement survives.
- Verify what the PSAP receives, not what your platform believes it sent. These differ more often than expected.
- Trace the notification path end to end. Who is alerted, by what channel, and confirm a human receives it out of hours.
- Define the location maintenance process. Moves, adds and changes degrade location accuracy continuously. Without a process it is accurate on day one and wrong within a year.
- Document the evidence. If you are asked to demonstrate compliance, what would you produce?
Where this intersects with migration
Every telephony migration touches 911, and it is routinely treated as a cutover task rather than a workstream. Two specific risks:
- Number porting moves the association between a number and its registered location. If the new registration is not in place before the port completes, there is a window where 911 routes incorrectly.
- Carrier-side facilities that support 911 — selective router circuits, dedicated 911 TDM paths — carry their own coordination obligations during discontinuance. See copper retirement.
Related reading
- TDM to IP migration — where 911 belongs in the plan.
- Copper retirement — carrier-side 911 coordination requirements.
Sources
- FCC — Multi-line telephone systems: Kari's Law and RAY BAUM'S Act 911 direct dialing, notification, and dispatchable location requirements
- 911.gov — Kari's Law & RAY BAUM'S Act
- Intrado — Kari's Law and RAY BAUM'S Act: E911 compliance, MLTS
- Sinch — Kari's Law & RAY BAUM'S Act: essential guide to E911 laws
- 911 Secure — 911 legislation: Kari's Law, RAY BAUM'S Act
Current as of July 2026. This is a summary for planning purposes and is not legal advice. Verify obligations against the current FCC rule text and your counsel. Never place test calls to 911 without coordinating with your PSAP.
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