The Kari's Law requirements for business phone systems are federal, they apply to organizations of any size, and the compliance deadlines have already passed. If your business uses a multi-line telephone system (MLTS), meaning any setup with more than one extension, you are responsible for meeting them today.
The law is named after Kari Hunt, who was killed in a hotel room while her daughter tried repeatedly to call 911. The hotel's phone system required dialing '9' first to reach an outside line. The call never connected. That single failure in a phone system's configuration is now against federal law, and the rules cover hotels, small businesses, schools, clinics, and government offices alike.
What Kari's Law Requires and Who It Applies To
Kari's Law sets two concrete requirements for any MLTS manufactured, imported, sold, or installed on or after February 17, 2020. First, any user must be able to dial 911 directly, with no prefix, no access code, and no dialing '9' before the number. Second, whenever a 911 call is placed, the system must send a notification that includes the fact that a 911 call was made, a valid callback number, and the caller's location.
That notification destination can be a front desk, a security station, or an off-site service such as an answering service or monitoring company. The FCC rule requires the notification to reach a location, on-site or off-site, where someone is likely to see or hear it in real time. Routing it to an unmanned desk or a voicemail box does not meet this standard, and neither does sending it to a location that is only staffed during some hours.
The MLTS manager, the person or company responsible for day-to-day operation of the system, is presumed responsible for compliance and faces FCC enforcement under Title V of the Communications Act if the system falls short. A common mistake is assuming this only affects large enterprises. A small medical office with a handful of extensions on a hosted VoIP platform is covered just as much as a large call center.
RAY BAUM'S Act: The Dispatchable Location Rule Explained
Section 506 of RAY BAUM'S Act directed the FCC to require that a dispatchable location be automatically sent to the PSAP (the 911 call center) with every MLTS 911 call. Dispatchable location means the validated street address of the calling party, plus additional information such as suite, floor, or room number, enough for first responders to find the caller within a building.
Your system may already route 911 calls to the correct PSAP, but dispatchable location is a separate and additional requirement. It tells the dispatcher exactly which room or suite to enter, not just which building to approach. Many systems that route calls correctly still fail to transmit the floor or suite data that first responders need.
The compliance deadline for on-premises fixed devices was January 6, 2021. For on-premises non-fixed devices and off-premises devices, the deadline was January 6, 2022. Both have passed. Every covered system must comply now.
For a small, single-floor business, a street address alone may provide first responders all the information they need to quickly locate the caller. For a multi-story building or a campus with multiple suites, floor and room number are required where technically feasible. If your system sends only the building's main address to the PSAP, it may not be enough for your location.
How Traditional PBX Systems Commonly Fail Both Rules
Older PBX and key systems were designed to save trunk lines, not to comply with 911 law. The factory default on many of these systems routes external calls through a trunk access code, dial 9 then the number. That default blocks direct 911 dialing, and many businesses have never changed it because no one flagged it during setup.
The dispatchable location problem is often worse. Legacy on-premises systems typically send the building's main listed number to the PSAP, with no indication of which floor or extension placed the call. In a multi-story building, that is not enough to guide first responders quickly to the right person.
Systems installed on or before February 16, 2020 are grandfathered and not legally required to comply. But legally exempt is not the same as safe. The FCC encourages voluntary upgrades because older systems still put callers at risk. A legal exemption will not change the outcome if a call fails to connect. If you are weighing an upgrade, read about legacy phone infrastructure in your building that may be part of the same picture.
What Your Hosted VoIP Vendor Handles vs. What You Configure
Hosted and cloud VoIP platforms can be fully compliant, but the MLTS manager cannot assume they are configured correctly from day one. A modern hosted VoIP phone system from a reputable provider will support direct 911 dialing and dispatchable location transmission by design. What the vendor cannot do is verify that the location data in your admin portal is accurate and current.
Every extension in your hosted platform has an emergency address on record. If you moved offices, added a floor, or changed suite numbers and never updated those records, the address the PSAP receives is wrong. Review those records at least annually and after any move or reconfiguration. The MLTS manager, not the vendor, is responsible for that data.
On-site notification is also a configuration task. You need to designate a destination that a person is actually likely to see or hear during business hours. An off-site answering service or monitoring company can satisfy this requirement just as well as a front desk. Sending the alert to a general voicemail box or a location no one monitors in real time does not.
Remote Workers and Softphones: The Gap Most Businesses Overlook
If your team uses softphone apps on laptops or mobile devices, common with any hosted VoIP platform, those devices fall under the non-fixed and off-premises category. The dispatchable location for a remote worker is not your office address. It is wherever that person is working when they place the 911 call.
Most hosted platforms let employees set and update their current emergency address in a user portal. That only works if employees know it exists and keep it updated. A common gap is an organization that set home addresses during initial rollout and never revisited those records after employees moved or shifted to hybrid schedules at different locations.
Test every device type on your platform, not just desk phones. Working with a managed IT provider to audit softphone and mobile app configurations is often the fastest way to close this gap. A system that handles desk phones correctly but fails on the mobile app is still a compliance problem for every user on that app.
Compliance Checklist: Test, Document, and Repeat
Work through this list and keep a written record of your results. If your system fails any step, the path forward depends on what you have, whether a portal configuration change, a firmware update, or a replacement if the hardware cannot support dispatchable location at all.
- Test direct 911 dialing from every extension type. Pick one desk phone, one softphone on a laptop, and one mobile app. Dial 911 and confirm the call connects without a prefix. Coordinate with your local PSAP before testing, as most have a process for non-emergency test calls.
- Verify the dispatchable location for each extension type. Check your admin portal or ask your provider what address is transmitted with a 911 call from each device. For multi-floor or multi-suite locations, confirm that floor and room are included where technically feasible.
- Check your notification destination. Confirm the alert reaches a person who is likely to see or hear it in real time. A front desk, security station, or off-site answering service can all qualify. A voicemail box or an unmanned location does not.
- Audit remote and hybrid worker location records. Pull the emergency address list from your admin portal and confirm every remote or hybrid employee's address is current.
- Confirm your system's installation date. If your MLTS was installed on or after February 17, 2020, compliance is legally required now. If it predates that, document the installation date and weigh the life-safety risk of leaving an older system in place.
- Document everything. Record the test date, who ran it, which devices were tested, the addresses transmitted, and the notification destination. Update this record after any system change, office move, or new extension added.
If you find gaps and are not sure whether your current system can address them, start by asking your provider directly what configuration changes are available. If a full replacement makes sense, read about keeping your existing numbers when you switch systems before starting the process. And if aging copper lines feed your current MLTS, replacing those lines and upgrading to a compliant platform can often happen at the same time.
If you want a second set of eyes on your current setup or help finding a platform that fits your budget and meets these requirements, book a free 15-minute call with Joshua. No sales pitch, just a direct conversation about what your system actually needs.
