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Is Your Business Phone System E911 Compliant?

December 15, 2020 · Updated October 11, 2026 ·

Kari's Law and RAY BAUM'S Act, both enacted in 2018, led to FCC 911 rules for business multi-line telephone systems that took effect starting February 16, 2020. Here is what the rules require for direct 911 dialing, notifications, and dispatchable location.

Two federal laws enacted in 2018, Kari's Law and RAY BAUM'S Act, led to FCC rules that took effect starting February 16, 2020 and set 911 requirements for business multi-line telephone systems in the United States. If your organization has not yet reviewed its phone system against these requirements, now is the time to do so.

What E911 Is.

Enhanced 911 (E911) is the system used throughout North America to automatically provide location information to 911 dispatchers when an emergency call is placed. For businesses with multi-line telephone systems, including VoIP platforms and unified communications tools, the Federal Communications Commission (FCC) has established rules that go beyond simply being able to dial 911. Those rules have real legal and safety implications.

The Two Rules Your Business Must Follow.

Kari's Law and RAY BAUM'S Act are the two federal laws behind the 911 rules for business telephone systems. Kari's Law, signed on February 16, 2018, was passed in response to a tragedy in which a nine-year-old girl was unable to reach 911 directly because the hotel phone system required a prefix digit to dial out. Her mother, Kari Hunt, died before help could arrive, and the law bears her name. RAY BAUM'S Act, signed on March 23, 2018, is a broader FCC reauthorization law named for Ray Baum, a longtime staff director of the House Energy and Commerce Committee. One of its provisions directed the FCC to make sure 911 calls deliver a dispatchable location.

The FCC's rules for these laws apply to multi-line telephone systems that are manufactured, imported, sold, leased, or installed after their compliance dates. Kari's Law requirements apply to systems in that group after February 16, 2020. Dispatchable location rules followed on January 6, 2021 for fixed desk phones and on January 6, 2022 for non-fixed and off-premises devices such as softphones.

Kari's Law requires that all phones on a multi-line telephone system be capable of dialing 911 directly, without any prefix. In addition, the system must generate a notification whenever a 911 call is placed. That notification must be sent to an on-site or off-site location where someone is likely to see or hear it promptly. The notification must include confirmation that a 911 call has been made, a valid callback number, and the caller's location.

The RAY BAUM'S Act rules require a covered system to send location information to 911 dispatch centers with an emergency call. A dispatchable location consists of a validated street address along with any additional information needed to identify the specific location within a building, such as a suite number, floor, or room. Fixed desk phones must provide an automated dispatchable location. For non-fixed devices, such as a softphone on a laptop, the system must provide an automated dispatchable location when that is technically feasible. Otherwise it may rely on a location the user updates manually or on other approved location information.

Taken together, these two rules are designed to get first responders to the correct location as quickly as possible, however your employees connect to the phone system and wherever they are calling from.

Why This Matters for Modern Business Phone Systems.

As businesses have moved toward cloud-based phone systems, VoIP platforms, and mobile-first communication tools, the challenge of accurate location delivery has become more complex. A softphone running on a laptop could be used from a remote office, a home, or a hotel. A legacy phone system that was never configured for E911 compliance may route all calls through a single main address regardless of where the caller is actually located. Neither scenario meets the requirements of the RAY BAUM'S Act rules.

Non-compliance carries both legal risk and, more importantly, real safety risk for your employees. A misdirected or delayed emergency response caused by incorrect location data is not an abstract concern.

How Cyber One Solutions Can Help.

Cyber One Solutions helps businesses configure and test the phone systems we manage against Kari's Law and RAY BAUM'S Act requirements, including direct 911 dialing, on-site notifications, and location records. Our Kari's Law and RAY BAUM'S Act E911 compliance page explains what we configure and test on the systems we manage, and the boundary between our role and your carrier's. If you are unsure whether your current system is compliant, or if you are planning a phone system upgrade, contact us today to schedule a compliance assessment.