Kari’s Law & RAY BAUM’S Act: Business Phone Compliance Guide (2026)

Kari’s Law requires business phone systems to dial 911 with no “9” first and to alert someone when a 911 call is made. RAY BAUM’S Act adds one more rule: every 911 call must send a location that responders can use.

Both laws cover VoIP and cloud systems installed after February 16, 2020. This guide gives the rules, dates, penalties and a six-step checklist. Rules checked on [date].

This guide is general information, not legal advice.

What is Kari’s Law?

Kari’s Law is a federal law that requires direct 911 dialing and on-site notification on multi-line phone systems. It is named after Kari Hunt.

• Why it exists: in 2013, Kari Hunt was killed in a motel room in Texas. Her nine-year-old daughter tried to call 911 four times. Each call failed, because the motel phone system needed a “9” to reach an outside line.
• Enacted: February 16, 2018.
• FCC rules adopted: August 2019, effective January 6, 2020.
• Compliance date: February 16, 2020, for systems made, imported, sold, leased or installed after that date.

The law targets a simple problem. In an emergency, people dial 911, not 9-911. A child, a guest or a new employee should never need to know how the office phones work to reach help.

What Kari’s Law requires

Kari’s Law requirements come down to two rules for every MLTS: direct dialing and notification.

Direct dialing

Users must be able to dial 911 with no prefix or access code, such as “9.”

• Direct dial 911: a user picks up any phone on the system, dials 911 and reaches the 911 center (the PSAP).
• 9-911 can still work: many systems accept both 911 and 9-911, so staff with old habits still get through.
• Every device counts: desk phones, conference phones, lobby phones, cordless handsets and softphones on the system.

Notification

The system must alert a central point, on-site or off-site, where someone is likely to see or hear the alert.

• Who gets it: a front desk, a security desk, an office manager or an on-call group.
• How it arrives: email, SMS, a phone call or an on-screen alert.
• What it includes: the callback number and the caller’s location, so the person who gets the alert can guide responders to the right room.

Notification does not replace the 911 call. It makes sure that someone inside the building knows help is on the way and can meet responders at the door.

Who must comply with Kari’s Law?

The law applies to the companies that make, sell, install and run multi-line phone systems. That covers most businesses with more than one phone line.

• Manufacturers and vendors of MLTS equipment and software.
• Installers who set up the system.
• Managers and operators, which means the business that runs the phones day to day.
• Common MLTS users: offices, hotels, schools, hospitals, clinics, universities and government buildings.
• Small businesses: included. There is no size exemption.

Shared buildings need extra care. In a hotel, a coworking space or a medical building with many suites, the notification should go to someone who can reach the caller’s room fast, such as the front desk or building security, and the location must name the exact room or suite.

Does it apply to VoIP and cloud phone systems?

Yes. An MLTS is any system of more than one line that shares an outside connection, and the rules apply whatever the technology. Hosted VoIP, cloud PBX and on-site IP PBX systems are all covered, as long as they were sold or installed after February 16, 2020.

What about systems installed before February 16, 2020?

The rules are forward-looking. They do not apply to an MLTS that was made, sold, leased or installed on or before February 16, 2020. But a legacy system is not a safe place to stay:

• Upgrades and replacements after that date must comply.
• Moves and adds can count as new installations. [EDITOR: confirm with a compliance reviewer.]
• Liability still exists if a 911 call fails.

If your system is older than 2020, the simplest fix is to test direct dialing and set up notification anyway.

RAY BAUM’S Act and dispatchable location

RAY BAUM’S Act (Section 506) requires every 911 call from a business phone system to send a dispatchable location to the 911 center. This closes the gap that Kari’s Law leaves open: reaching 911 is only half the job if responders cannot find the caller.

What is a dispatchable location?

A dispatchable location is the validated street address of the caller plus the extra details responders need, such as the floor, suite or room number. “123 Main Street” is not enough in a 10-story building. “123 Main Street, Floor 4, Suite 410” is.

Compliance dates by device type

Here is what a good location record looks like for each type of device:

Alternative and enhanced location information means coordinate-based data that is good enough to identify the address and, on premises, the floor. The rule favors dispatchable location, and the other options are allowed only when that is not technically feasible.

How a compliant MLTS 911 call works

Here is what should happen, step by step, when someone dials 911 from a compliant business phone system:

1. The caller dials 911. No prefix is needed, from any phone or softphone on the system.
2. The system routes the call to the 911 center that serves the caller’s location, not the location of the company headquarters.
3. The location goes with the call. The PSAP receives the dispatchable location (address plus floor or room) and a callback number.
4. The alert goes out. At the same moment, the system notifies the front desk, security or an on-call contact by email, SMS or screen alert.
5. Someone meets responders. The person who got the alert unlocks doors, holds the elevator and guides responders to the right room.
6. The callback number works. If the call drops, the 911 center can call straight back to the caller, not to a main line or an auto attendant.

Each step depends on a setting in the phone system. If one is wrong, the chain breaks, which is why testing matters.

Kari’s Law vs RAY BAUM’S Act

Kari’s Law makes sure the call connects and someone on site knows. RAY BAUM’S Act makes sure responders know where to go.

Most businesses meet both laws with the same project, because the same phone system settings control dialing, alerts and location.

Penalties for non-compliance

Kari’s Law penalties can be heavy. Fines can reach $10,000, plus daily penalties for each day the system stays out of compliance (often reported as $500 per day). [EDITOR: confirm the amounts against the statute and FCC forfeiture rules, not only vendor sources.]

• FCC action: the FCC reviews complaints about 911 failures on business phone systems.
• Reports from 911 centers: PSAPs can report problems through the FCC’s Public Safety Support Center.
• Civil liability: a failed 911 call can lead to a lawsuit, whatever the fine.

The larger cost is not the fine. It is a 911 call that does not connect, or a responder who goes to the wrong floor.

Kari’s Law compliance checklist

You can handle both laws and E911 compliance in one project. Follow these six steps and repeat the tests on a schedule.

1. List every phone and device. Include desk phones, conference phones, cordless handsets, softphones on laptops and mobile apps. Note where each fixed device sits: building, floor and room. Include lobby phones, elevator phones and fax lines, which are easy to forget.
2. Test direct dialing. From a sample of devices, confirm that 911 connects with no prefix, and that 9-911 still works if your staff use it. Use a test procedure agreed with your local 911 center, or your provider’s test line, so you do not tie up emergency lines. If you must place a live test call, call the non-emergency line first, then tell the dispatcher it is a test.
3. Set up notifications. Choose who gets the alert (front desk, security, office manager) and how (email, SMS, screen pop). Add a backup recipient for nights and weekends. For several sites, send each site’s alerts to a person at that site.
4. Check the callback number and location for each device. Every device should send a callback number that reaches the caller, and a location that matches where it is.
5. Set dispatchable locations. Add the floor, suite or room for every fixed device. For non-fixed devices, set up a way for users to confirm or update their location.
6. Test on a schedule and keep records. Test after every move, add or change, and at least once a year. Keep a log of tests, locations and alert recipients. This log is your proof of E911 compliance if the FCC or a lawyer ever asks.

Kari’s Law for remote and hybrid workers

Remote and hybrid staff use non-fixed devices, so their location must follow them. A softphone on a laptop can be at home on Monday, at a client site on Tuesday and in the office on Wednesday.

• Softphones count: a softphone or mobile app connected to the business phone system is part of the MLTS.
• Location must update: the phone system should ask the user to confirm the location when the device connects from a new network, or detect it automatically.
• Home offices need a real address: the user should enter the full address, including apartment or unit number.
• Notification still applies: a 911 call from a home office should still alert the central point, so the company knows an employee called for help.
• Tell your provider when phones move: when a desk phone moves to a new room or site, update its registered location the same day.

A typical location update on a softphone works like this:

1. The user opens the softphone app on a new network.
2. The app detects the change and asks the user to confirm the address.
3. The user picks a saved address or enters a new one, with the unit number.
4. The provider validates the address and stores it for 911 routing.

Train remote staff once and remind them often. A location that is six months out of date is almost as bad as no location.

What to ask your phone provider

Your provider does most of the technical work, but you are still responsible as the operator. Ask these questions in writing:

1. Does every device on our system dial 911 with no prefix?
2. How are 911 notifications sent, and can we choose the recipients per location?
3. How do you store and send dispatchable location for fixed devices?
4. How do softphones and remote users update their location?
5. How do we test 911 without calling the emergency line, and how often should we test?
6. What happens to 911 location records when we add a site or move a phone?

Multi-location businesses should also ask how the provider manages location records across sites. Each office needs its own validated address and floor details, and alerts should go to the right person at the right site.

At Vivant, our Business Phone System includes E-911 that routes emergency calls with the correct address for responders, and our team updates 911 records when you report a moved phone. For businesses with several offices, all locations sit in one portal, so each site’s addresses and alert contacts are managed in one place. [EDITOR: confirm Vivant’s support for direct dialing, notification recipients, dispatchable location per device and remote-user location updates before publishing.] See the Vivant FAQ or our business phone system page. [EDITOR: confirm URL.]

FAQ

Does Kari’s Law apply to small businesses?

Yes. The law has no size exemption. Any business that runs a multi-line phone system made, sold or installed after February 16, 2020 must support direct 911 dialing and notification. Most small business VoIP systems fall under the rule.

When did Kari’s Law go into effect?

The law was enacted on February 16, 2018. The FCC adopted its rules in August 2019, and the compliance date for new systems was February 16, 2020. The RAY BAUM’S Act location rules followed on January 6, 2021 and January 6, 2022.

Does Kari’s Law apply to VoIP?

Yes. The rules cover multi-line telephone systems whatever the technology, so hosted VoIP, cloud PBX and IP PBX systems sold or installed after February 16, 2020 must comply. Your provider should confirm how its system handles direct dialing, notification and location.

Can 911 find remote employees?

It can, if the location is set up. For off-premises softphones, RAY BAUM’S Act requires a dispatchable location when feasible, or a manually updated or enhanced location. Remote staff must confirm their address when they work from a new place.

Do we need to test 911 on our phone system?

The rules do not set a test schedule, but testing is the only way to know the system works. Test after every install, move or change, and at least once a year. Use your provider’s test line or a procedure agreed with your local 911 center.

Does Kari’s Law apply to hotels?

Yes, for phone systems installed after February 16, 2020. Hotels were the reason for the law. Guests must be able to dial 911 from the room phone with no prefix, and the front desk or security must get an alert with the room number.

Does my old phone system have to comply?

The rules do not apply to systems made, sold, leased or installed on or before February 16, 2020. Replacements and upgrades after that date must comply. Testing direct dialing and setting up alerts on an older system is still a good idea.

Bottom line

Kari’s Law and RAY BAUM’S Act ask three things of every business phone system: dial 911 directly, alert someone on site, and send a location responders can use. Most businesses meet all three in one project: list the devices, test dialing, set up alerts, add dispatchable locations and test again after every change.

If you run more than one office, choose a provider that manages 911 locations and alerts for every site in one place. Talk to Vivant about a business phone system with E-911 built in.

About the author

Kiani M

CTO at Vivant

Kiani leads the tech side of Vivant, choosing and designing the networks, phone systems and security that keep our customers connected.

Owns more spare routers than any one person reasonably should.