Kari's Law and RAY BAUM'S Act: E911 Compliance in 2026

If your business runs a multi-line phone system — a PBX, a cloud phone service, anything where more than one phone shares the system — two federal laws govern how that system must handle 911: Kari's Law and RAY BAUM'S Act. They are not optional, they are not new, and the FCC enforces them with real fines. This guide covers what each law requires, the deadlines that already passed, and how to verify your own system complies.

Kari's Law: direct 911 dialing and notification

Kari's Law is named after Kari Hunt Dunn, who was attacked and killed in a Texas motel room in 2013. Her nine-year-old daughter tried to call 911 four times from the room phone. The calls never went through, because the motel's phone system required dialing 9 for an outside line first — something a child in an emergency had no way to know.

The law was signed on February 16, 2018, and took effect two years later. It applies to multi-line telephone systems (MLTS) manufactured, imported, sold, or installed after February 16, 2020, and it imposes two requirements:

• Direct dialing. Anyone must be able to dial 911 directly — no prefix, no access code, no "dial 9 first." If a guest, patient, visitor, or brand-new employee picks up any phone on your system and dials those three digits, the call must go to 911.
• Central notification. When someone dials 911, the system must send a notification to a central location on-site — a front desk, a security office, an IT team — wherever someone is likely to see it. The notification can be a screen pop, an email, or a text message, and it must go out without delaying the actual 911 call. The FCC requires this where it's technically feasible without an expensive system upgrade, which for modern cloud systems means: it's required.

The notification requirement is the piece businesses most often miss. Its purpose is practical: when paramedics arrive at a 40,000-square-foot building, someone at the front desk should already know an emergency call went out and roughly where it came from, so responders aren't searching hallways.

RAY BAUM'S Act: dispatchable location

RAY BAUM'S Act — formally "Repack Airwaves Yielding Better Access for Users of Modern Services," named for a former congressional staff director — addresses a different failure mode. A 911 call that connects but delivers only a company's main street address sends responders to a lobby, not to the third-floor suite where someone collapsed.

Section 506 of the act required the FCC to ensure that a dispatchable location travels with every 911 call from an MLTS. Dispatchable location means the validated street address plus the information needed to actually find the caller: floor, suite, room number, or equivalent. The FCC's compliance deadlines were phased:

• January 6, 2021 — fixed MLTS devices (a desk phone that stays at one desk).
• January 6, 2022 — non-fixed devices and off-premises use: softphones, laptops, mobile apps, and employees working from home.

That second deadline is the one that catches modern businesses. If your team uses desktop or mobile apps to make calls — and on any modern cloud system, they do — those apps are covered. A 911 call from a sales rep's softphone at their kitchen table must deliver that home address, not your headquarters.

What compliance looks like in practice

Walk through this checklist against your current system:

• Dial 911 access works from every device with no prefix. (Test with your provider's guidance — many PSAPs accept brief test-call arrangements; never casually dial 911 to "check.")
• A designated person or group receives an immediate notification — with the caller's extension and location — whenever anyone dials 911.
• Every fixed phone has a location record that includes suite, floor, or room detail, not just the building address.
• Softphone users are prompted to confirm or update their address when they work from a new location, and that address is what 911 receives.
• Location records are updated as part of your move/add/change process, so a phone that moves desks doesn't keep its old room number.

How this plays out by business type

Hotels and motels were the original target — Kari's Law exists because of a motel phone system. Guest room phones must dial 911 directly, and the front desk should receive the room number with every notification. If your property management system still requires dialing 9 or 8 for an outside line, 911 must bypass that requirement entirely.

Medical and dental offices combine both laws' concerns: multiple operatories or exam rooms mean dispatchable location must identify the specific room, and the front desk notification lets staff meet EMS at the door and direct them — minutes that matter when the emergency is a patient in a chair.

Schools and daycares often run older phone systems the longest. Direct dialing from every classroom phone plus notification to the main office is the exact scenario the law envisions, and many states layer additional notification requirements on top of the federal floor.

Multi-location retail and offices face a data-hygiene problem more than a technology problem: each site's phones need locations registered against that site's address, and a phone shipped from the Tampa store to the Orlando store must not carry Tampa's 911 record with it. Centralize the process or it will drift.

Penalties are real

The FCC has authority to fine MLTS managers and vendors for non-compliance, with forfeitures that start around $10,000 per violation plus continuing daily penalties. Beyond the FCC, consider the civil liability exposure if an emergency call from your office fails or misroutes because of a system you configured. Compliance here is one of the cheapest insurance policies your business can buy.

Who is responsible — you or your provider?

Both. The law reaches manufacturers, installers, and the businesses that operate the systems. A compliant provider handles the plumbing: routing 911 calls with location data, validating addresses against the 911 database, generating notifications. But your business owns the accuracy of the data — assigning locations to phones, keeping suite numbers current, and training whoever receives the notifications. An audit takes an afternoon: inventory your devices, check each one's registered location, place a coordinated test, and document the results.

How fvoip handles E911

E911 service is included on every fvoip plan — Essential, Professional, and Enterprise — at no extra charge, and we don't add regulatory recovery surcharges on top. Direct 911 dialing works out of the box on desk phones and on our mobile and desktop apps, dispatchable location is managed per device, and 911 notifications can be delivered to the people you designate. If you're replacing an older PBX that predates these rules, our free migration help covers moving your numbers and setting up compliant 911 locations as part of onboarding, and provisioned desk phones arrive with their location records ready to verify.

One caution as you shop: some legacy PBX installations still in service were sold before February 2020 and have never been updated. "We've always done it this way" is not a defense the FCC recognizes. If your system requires dialing 9 for an outside line before 911, or sends only your street address with emergency calls, the compliance gap is already open — close it before it matters.