Emergency calling is the one area of business telephony where the consequences of getting it wrong are measured in something other than money. Two federal laws — Kari's Law and Section 506 of RAY BAUM's Act — set specific, testable requirements for what a business phone system must do when someone dials 911. Both are in force now, both apply to systems most businesses already operate, and compliance is not something your provider can handle entirely on your behalf. This article explains what each law requires and how to verify your own system meets it.
Kari's Law: Direct Dialling and Notification
Kari's Law is named for Kari Hunt, who was killed in a Texas motel room in 2013 while her daughter repeatedly tried to call 911 — unsuccessfully, because the motel's phone system required dialling 9 for an outside line first. The law took effect for equipment manufactured, imported, sold or installed after 16 February 2020, and imposes two requirements on multi-line telephone systems.
Direct dialling. A user must be able to reach 911 by dialling 9-1-1 and nothing else — no prefix, no access code, no "dial 9 first". If your system requires 9-911, it is non-compliant. A well-configured dialplan accepts both, so that muscle memory does not become a hazard, but bare 911 must always work.
On-site notification. When someone dials 911, the system must notify a central location on site — reception, security, a facilities manager — where someone is likely to be present. The notification must include that a 911 call was made, a callback number, and the caller's location to the extent the system can determine it. This exists so that when emergency services arrive at a large building, someone can direct them to the right floor and room. Notification can be a screen pop, an email, an SMS, or a call to a designated extension; the law does not mandate the method, only that it happens and that it is not configurable away by an end user.
RAY BAUM's Act Section 506: Dispatchable Location
Kari's Law makes sure the call gets out. RAY BAUM's Act makes sure responders can find the caller. It requires that a dispatchable location be conveyed with every 911 call — meaning the street address plus additional information such as floor, suite, room number or similar data sufficient to locate the caller within the building.
The compliance deadlines have all now passed: fixed multi-line telephone systems from 6 January 2021, and non-fixed MLTS devices — softphones, mobile apps and any endpoint a user can move — from 6 January 2022. That second deadline is the one that catches modern deployments, because it covers exactly the remote and hybrid working setups that expanded fastest.
Why VoIP Makes This Harder Than It Sounds
With a traditional analogue line, location was implicit: the copper pair terminated at a known physical address. IP endpoints have no such property. A softphone registered to your Houston PBX may be sitting in a hotel in Denver. A desk phone can be unplugged and moved two floors up during an office reshuffle, and nothing in the signalling notices.
This is why compliance requires ongoing administrative work rather than a one-time configuration. The practical approaches are:
- Register a location per device, mapped to the MAC address, and update it when phones move. Suitable for fixed desk phones in a stable office.
- Map network topology to location — associating a subnet, a VLAN, a switch port or a wireless access point with a specific floor or zone, so a device's location is derived automatically from where it connects. This is the most robust approach for large sites.
- Prompt remote users to confirm their location when a softphone registers from an unrecognised network, and store the response. Imperfect, but far better than defaulting to the head office address.
Who Is Actually Liable
This is the point most often misunderstood. Your provider is responsible for delivering the 911 call and the location data you have registered to the correct Public Safety Answering Point. You are responsible for the accuracy of that registered data and for configuring the dialplan and notification behaviour correctly. If a phone was moved from the second floor to the fourth and nobody updated the record, that is not a carrier failure.
Penalties under the Communications Act can reach five figures per violation with additional daily amounts for continuing violations — but the civil liability exposure from an emergency response sent to the wrong floor is the more serious risk.
A Compliance Checklist You Can Actually Run
- Dial 911 from a desk phone and a softphone — with prior arrangement with your local PSAP, or using your provider's designated test number. Confirm bare 911 connects without a prefix.
- Confirm the on-site notification actually arrives, and that a real person receives it during all hours the building is occupied.
- Verify the dispatchable location shown to the PSAP includes floor and room, not just the street address.
- Audit your device-to-location register against reality — walk the floors if the site is small enough.
- Confirm remote and hybrid workers' softphones have a current registered address, and that there is a process for updating it when they move.
- Document who owns this process, and put a recurring review in the calendar — quarterly is a reasonable cadence for most organisations.
Build It Into the Move, Not After It
The cheapest time to get emergency calling right is during a system migration, when you are already documenting every extension, every device and every location. Retrofitting a location register onto a live system with several hundred phones is considerably more work than capturing it as you provision.
PBX SIP Trunking's Cloud PBX enforces direct 911 dialling by default, supports on-site notification to any combination of extension, email and SMS, and provides per-device and per-subnet location registration with an audit view showing which devices have stale or missing location data. Our engineers will run a compliance review of your existing configuration on request, whether or not you are a customer.