Two federal laws set the 911 rules for business phone systems. Kari's Law requires multi-line telephone systems to let anyone dial 911 directly, without a prefix such as 9, and to notify someone, such as a front desk or security, when 911 is called. RAY BAUM's Act requires 911 calls to carry a "dispatchable location": the street address plus the floor, suite or room needed to find the caller. This article is a plain-English summary for business owners. It is not legal advice.
A note on scope: this summarises the federal rules as generally understood in September 2026. Rules change, states can add their own requirements, and your obligations depend on your system and your role. For a definitive answer about your business, speak to a telecom attorney or your compliance advisor, and check the FCC's own guidance.
Why these laws exist
Kari's Law is named after Kari Hunt, who was killed in a Texas motel room in 2013. Her young daughter tried to call 911 several times, but the motel phone system required dialling 9 first for an outside line, and the calls did not go through. The law passed in 2018.
RAY BAUM's Act, also from 2018, is a broader telecom law. Its Section 506 directed the FCC to make sure 911 calls from phone systems carry location information precise enough for responders to find the caller. In a large office building, "123 Main Street" is not enough if the person is on the 14th floor in a conference room at the back.
Who the rules apply to
The rules centre on multi-line telephone systems, or MLTS: phone systems where many users share outside lines through one system. That covers traditional PBXs and key systems, and also cloud and hosted systems such as hosted PBX and UCaaS platforms, including Teams used as a phone system.
The obligations fall on the businesses that manufacture, import, sell, lease and install these systems, and on those that manage or operate them. In practice, if your business runs a phone system for your staff, some of this applies to you, and your provider or installer carries part of it too.
The MLTS rules generally apply to systems manufactured, imported, first sold or leased, or installed after February 16, 2020. Older systems were not generally required to be replaced, but a replacement system, including a move to a new cloud service, brings the new system into scope. Whatever the legal position of an old PBX, the safety case does not depend on its installation date.
Kari's Law: the two requirements
1. Direct dialling
A user must be able to dial 911 without any prefix, extension or access code. If your system requires 9 for an outside line, 911 on its own must still reach emergency services. Many systems also let 9-911 work, which is sensible, since people under stress dial the way they always do.
2. Notification
When someone dials 911, the system must notify a central location, on site or elsewhere, where someone is likely to see or hear it, such as a front desk, a security office or a facilities manager's phone. Where technically feasible, the notification should include that 911 was dialled, a callback number, and the same location information sent to the 911 centre.
Notification must not delay the 911 call itself. The rules do not require that location to be staffed around the clock, but the point is for someone to know help is coming, so they can meet responders at the door, open a gate or hold an elevator.
RAY BAUM's Act: dispatchable location
A dispatchable location is a validated street address plus the additional detail needed to find the caller, such as floor, suite, room or wing. The FCC's rules phase this in by type of device:
| Type of device | What the 911 call should carry | MLTS compliance date |
|---|---|---|
| Fixed, on premises (a desk phone that stays put) | Automated dispatchable location | February 16, 2021 |
| Non-fixed, on premises (a softphone or handset that moves around the building) | Automated dispatchable location if technically feasible; otherwise a location the user provides or other approved location information | January 6, 2022 |
| Off premises (home workers, travellers) | Automated dispatchable location if technically feasible; otherwise a location the user updates, or approved alternatives, which can include routing to a national emergency call centre that confirms the caller's location | January 6, 2022 |
For a traditional office, the practical meaning is simple: every phone and every user needs an accurate location record down to the floor and room or zone, and it has to be kept current.
Remote and hybrid workers
Remote work is where most offices fall short. A softphone on a laptop in someone's kitchen still makes a 911 call through your system. Modern platforms handle this in a few ways:
- Network-based location. The system recognises which office network, subnet, Wi-Fi access point or switch port the device is on, and assigns the matching location automatically.
- User-confirmed location. When the app detects an unknown network, it prompts the user to enter or confirm their address.
- Fallbacks, such as routing to a national emergency call centre, where the platform supports it and the rules allow.
Teams has emergency addresses and dynamic emergency calling for this. See Teams calling explained. Hosted PBX and UCaaS platforms have their own equivalents.
A compliance checklist
- 911 dials directly from every phone and softphone, with no prefix.
- 9-911 also works, if your users are used to dialling 9.
- 911 notification goes to a place someone will see or hear it, with callback number and location where supported.
- Every fixed phone has a validated address with floor and room or zone.
- Softphones and roaming handsets pick up location from the network, or users are prompted.
- Remote users can set and update their location, and know they should.
- Location records are updated whenever people or phones move.
- Test calls have been made in a coordinated way, and the results recorded.
- Special lines, such as elevator phones and alarm panels, have been reviewed separately, since they follow their own codes.
- Phones and network switches have backup power, so 911 works during a power cut for as long as practical.
A worked example
A hypothetical office and setup, used to show how the rules turn into a plan. Not a real client.
Suppose a company occupies three floors of a building. It has 90 desk phones, 20 conference room and common area phones, and 25 hybrid staff who use a softphone at home two or three days a week.
- Location records. Each floor is split into four zones, giving 12 location records for the building, each with street address, floor and zone. Every desk and common phone is assigned to one.
- Network mapping. Each floor's network is mapped to its zones, so a softphone used in the office picks up the right location without anyone typing anything.
- Remote staff. The 25 hybrid staff are prompted to confirm their home address the first time they sign in from home, and whenever the app sees a new network.
- Notification. A 911 call triggers an alert to the reception console, the building security desk and the office manager's mobile, showing the caller's name, extension and zone.
- Testing. The company uses the provider's 933 test service, where supported, to confirm the address read back for sample phones on each floor, and coordinates any live test with the local 911 centre on its non-emergency line.
That is 12 location records, one alert group and a short test plan: a morning of work, not a project. The part that takes discipline is keeping it current. When the company later moves a team to another floor, or ports its numbers to a new platform, the location records have to move with them, and the network mapping has to be updated when switches or Wi-Fi are replaced. A managed network provider can own that mapping if your team does not want to.
How to test without causing a problem
Do not test by dialling 911 casually. Some providers support a 933 test call that reads back the registered address for the phone you are using; ask yours. If a live 911 test is needed, call the local 911 centre on its non-emergency number first, agree a time, and tell the call-taker immediately that it is a test. If anyone ever dials 911 by accident, stay on the line and explain.
Questions to ask your provider
- Does 911 dial directly from every device, including softphones and mobile apps?
- How is 911 notification set up, who receives it, and what does it show?
- How are dispatchable locations stored, validated and updated?
- How does location work for remote users and for softphones inside the office?
- Do you support 933 test calls?
- Which parts of compliance do you handle, and which are my responsibility?
- What happens to 911 calls if my office internet or power fails?
Getting 911 set up properly
When we quote business voice or hosted phones, 911 configuration is part of the conversation, not an afterthought, and we ask each provider how it handles notification and location. If you are choosing a system, SIP trunking vs hosted PBX is the place to start. For legal questions about your specific obligations, please consult counsel; this guide is not legal advice. The quote is free with no obligation and you usually hear back the same day. Tell us about your phone system, call 478-758-8091 or text (347) 870-0965.
