911 on Business VoIP and Office Phone Systems: Kari's Law and RAY BAUM'S Act
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How we wrote this: A plain-English summary of FCC consumer and public-safety pages (linked below). It is general information, not legal advice. The FCC itself notes that its summaries don't replace the rule text in 47 CFR Part 9. If you install or manage a phone system for others, read the FCC fact sheet and the rules.
Moving a business to VoIP or a cloud phone system changes how 911 works. A traditional landline is tied to one street address. An internet phone can be used anywhere. Two federal laws, plus FCC rules for VoIP providers, set out what has to happen when someone dials 911.
If you use interconnected VoIP
The FCC's VoIP and 911 guide says providers of interconnected VoIP (service that can call regular phone numbers) must:
- Provide 911 to all customers as a mandatory feature. You can't opt out.
- Get your physical location before service starts, and give you easy ways to update it.
- Send 911 calls, with a callback number and your registered location, to the right emergency call center.
- Explain any limits, provide warning labels for equipment, and get your acknowledgment of those limits.
The same guide lists what can still go wrong. A call may reach the wrong 911 center, or arrive without your number or location. VoIP may not work during a power or internet outage. Its tips for subscribers:
- Register an accurate address with your provider, and update it every time a phone or softphone moves. This includes employees working from home.
- Know your provider's update procedure and any 911 limits.
- Tell staff and visitors about any limits.
- Plan for outages. The FCC suggests a backup power supply, a traditional line or a mobile phone. Our UPS sizing guide covers keeping a modem, router and phone powered.
If you have a multi-line phone system: Kari's Law
The FCC's MLTS 911 page explains that Kari's Law covers multi-line telephone systems (MLTS), "typically found in enterprises such as office buildings, campuses, and hotels". It applies to systems manufactured, imported, sold, leased or installed after February 16, 2020. Two requirements apply:
- Direct dialing. A user must be able to dial 911 without a prefix such as 9, even if other outside calls need one. Installers, managers and operators must make sure the system is set up this way.
- Notification. When someone dials 911, the system must alert a central point where someone is likely to see or hear it. That could be a front desk screen with an alarm, a text or an email. The alert must include the fact that a 911 call was made, a callback number and the location sent to 911, where technically feasible. It must not delay the call.
The law is named for Kari Hunt. Her daughter tried to call 911 four times from a motel phone that required dialing 9 first.
RAY BAUM'S Act: dispatchable location
Under Section 506 of RAY BAUM'S Act, 911 calls must carry a dispatchable location: a validated street address plus details such as suite or floor. Per the FCC page, the compliance dates for MLTS were:
| Device type | Deadline | Requirement |
|---|---|---|
| On-premises, fixed desk phones | Jan. 6, 2021 | Automated dispatchable location |
| On-premises, non-fixed devices (e.g., softphones moving around a building) | Jan. 6, 2022 | Automated if technically feasible; otherwise a manually updated location or alternative location information (including floor in large buildings) |
| Off-premises devices (e.g., remote workers) | Jan. 6, 2022 | Automated if technically feasible; otherwise a manually updated location or best-available enhanced location |
A quick checklist for a small office
- Ask your provider how 911 is set up on your account and which address each line or user is registered to.
- Confirm with your installer or provider that every phone and softphone is configured to dial 911 without any prefix.
- Turn on 911 notifications and send them to someone who is actually there, or to a phone that's monitored.
- Check that every phone's registered location includes the suite and floor.
- Ask remote staff to update their location whenever they move. If your app prompts for this, make sure they know what it means.
If you're choosing a provider now, our guides to phone system options and porting your number cover the rest. If an AI receptionist will answer your calls, Autonomous Receptionist's guide to testing an AI receptionist suggests checks to run before going live.