Kari's Law Compliance Falls on the MLTS Manager
Kari's Law and RAY BAUM's Act require direct-dial 911 and a dispatchable location on business phone systems. Here's who is actually liable if the setup fails.
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The short version
Kari's Law and RAY BAUM'S Act are two federal rules that apply to any multi-line telephone system (MLTS), the kind of setup behind most office phone systems, hotel PBXs, and cloud phone platforms with more than one line or extension. Kari's Law requires that a call to 911 goes through with no prefix, no "9," no access code, and that someone on-site gets notified the moment that call is placed. RAY BAUM'S Act requires that same call to carry a "dispatchable location" precise enough for responders to find the caller inside the building, not just the street address on the account. Both took effect years ago, Kari's Law on February 16, 2020, RAY BAUM'S Act on a staggered schedule that finished January 6, 2022, so the compliance question for a 2026 buyer isn't whether a phone system claims to meet these rules; nearly all legally can't be sold in the U.S. if it doesn't. It's who actually configured it correctly, and, per the FCC's own liability rule, who is on the hook if it wasn't.
Why this law exists
On December 1, 2013, Kari Hunt, 31, was murdered by her estranged husband, Brad Dunn, in a room at the Baymont Inn and Suites in Marshall, Texas, in front of her three children [Texas Tribune, "After Failed 911 Call, Family Seeks Hotel Phone Change," 2014-01-23]. Her 9-year-old daughter tried to call 911 for help, commonly reported as four attempts, but the calls never went through because the hotel's phone system required dialing 9 for an outside line before dialing any number, and no one had told her that [IBTimes; ETCOG Public Safety, cross-referenced]. Her father, Hank Hunt, pushed for a fix, starting with a Texas state law that took effect in September 2016 and later a federal one bearing his daughter's name.
Congress passed Kari's Law on February 16, 2018, and the FCC's implementing rules took effect exactly two years later, on February 16, 2020 [FCC, Implementing Kari's Law and Section 506 of RAY BAUM'S Act, Report and Order, PS Docket Nos. 18-261 & 17-239, GN Docket No. 11-117]. By the time the federal law passed, at least 23 states, Texas among them, had already enacted their own MLTS 911 legislation with inconsistent requirements from state to state, which is part of why the FCC pushed for one federal floor that any business phone system in the country could be built to, instead of a different rulebook per state [FCC Report and Order, para. 6].
What Kari's Law requires
Kari's Law imposes three separate obligations, and phone system buyers usually only hear about the first. Anyone manufacturing, importing, selling, or leasing an MLTS can't sell one that requires a prefix to dial 911 [FCC Report and Order, para. 8]. Anyone installing, managing, or operating one has to configure it the same way [para. 9]. And that same operator has to configure a notification, to a front desk, security office, or any other person or organization regardless of location, that fires when a 911 call is placed, as long as the system can do that without a hardware or software upgrade [para. 10].
That third piece is the one that actually gets skipped in practice. A system can dial 911 correctly straight out of the box and still fail Kari's Law if nobody ever turns the notification on, or it's routed to an inbox nobody checks. Direct dialing is a one-time setup; notification is an ongoing configuration item that breaks quietly when staff turn over.
What RAY BAUM's Act adds
RAY BAUM'S Act works on the other end of the same call. Direct dialing gets the call through; dispatchable location tells the 911 center where to send help once it's there. The FCC defines it as "the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party" [FCC Fact Sheet, Implementing Kari's Law and Section 506 of RAY BAUM'S Act, PS Docket Nos. 18-261, 17-239 & GN Docket No. 11-117, released 2019-07-11]. A billing address covering an entire office isn't enough once a building has more than one floor or suite.
The rollout wasn't a single date. Fixed phones, the desk phone that never moves, had to carry an automated dispatchable location by January 6, 2021. Non-fixed devices on the same premises, laptops and softphones that move between desks or conference rooms, got an extra year, until January 6, 2022, and only "when technically feasible." Devices used off-premises, an employee's laptop at home or in a coffee shop, got that same January 6, 2022 date with the same "if technically feasible" qualifier [Wiley Rein client alert, "FCC Announces Compliance Dates for New E911 Rules Applicable to Multi-Line Telephone Systems and VoIP Providers," cross-referenced against Bandwidth and RAYBAUMsAct.com industry compliance summaries]. That fixed-versus-non-fixed-versus-off-premises distinction is exactly what a generic "we support E911" line on a pricing page glosses over, and it's why a remote-heavy team's actual compliance picture can look different from an office-bound one running the identical phone system.
Who's on the hook
The FCC didn't leave liability as an open question. If an MLTS fails to comply, the rule adopted in the same order presumes the MLTS manager, not the number's originating carrier, not necessarily the software vendor, bears responsibility for that failure "at least in part," unless the manager can rebut that by showing it met its own obligations [FCC Report and Order, para. 107]. In practice, that's whoever inside the business actually configures and runs the phone system: an office manager, an IT lead, or an outsourced MSP, not automatically the VoIP company whose logo is on the invoice.
The penalties sit in general FCC enforcement law, not a number written into Kari's Law itself. The statute enforces through Title V of the Communications Act, "except that section 501 applies only to the extent that such section provides for the punishment of a fine" [FCC Report and Order, footnote 272], which caps a fine at $10,000 per violation with no imprisonment [47 U.S.C. § 501]. A separate provision covers a continuing violation: up to $500 for every day the noncompliance continues [47 U.S.C. § 502]. Kari's Law also explicitly preserves state authority over the same issue, so a business in one of the 20-plus states with its own MLTS 911 law can face state-level exposure layered on top of the federal one [FCC Report and Order, para. 11].
What phone vendors actually do differently
Every VoIP provider selling into the U.S. market says it "supports" Kari's Law and RAY BAUM'S Act; the compliance dates passed years ago, so anyone still selling MLTS hardware or hosted lines has had to clear that bar. What differs is how much of the configuration burden the vendor actually carries versus leaves to the buyer.
RingCentral built Enhanced Nomadic 911 into its MVP platform: when an employee's laptop connects to a new network, the app prompts them to confirm or update their location, and an IT admin can pre-load up to 70,000 known networks and locations, offices, branches, home addresses, so staff stop seeing that prompt every time, while individual employees can save up to 20 of their own frequent locations [ringcentral.com blog, "RAY BAUM's Act compliance with RingCentral MVP location awareness," updated 2025-03-13]. Dialpad takes a different technical approach: indoors, it maps the wireless access points a device connects to, a method the company compares to cell-tower triangulation, to narrow location down to a specific floor; outdoors, it falls back to the device's latitude and longitude [dialpad.com blog, "What is E911?," accessed 2026-09-10]. Both solve the same RAY BAUM'S Act problem, where is this person right now, not where did we bill them last, but they put different weight on what an IT admin has to pre-configure versus what the app resolves live.
Nextiva's own E911 blog post is a useful cautionary example rather than a differentiator: it lists notifying on-site security staff as a RAY BAUM'S Act requirement, when the FCC's own order attributes that specific obligation to Kari's Law and reserves RAY BAUM'S Act for the location piece [nextiva.com blog, "E911: What Is It & How Does It Affect My Business?," accessed 2026-09-10, compared against FCC Report and Order paras. 10, 137]. The mix-up doesn't mean Nextiva's system fails to do either thing, both requirements are old enough that any current MLTS vendor almost certainly satisfies both. It's a reminder that even a vendor's own compliance page can blur which law requires what, so a buyer relying on a sales page to understand its own obligations, rather than to confirm the vendor met its own, is reading the wrong document.
What to check before signing
None of this requires a lawyer, and most of it takes fifteen minutes on a test line. Dial 911 from an extension that isn't the main desk phone, hang up before it connects or use the provider's test mode if one exists, and confirm no prefix is needed. Ask whoever manages the notification list whether it still points to an actual person; phone numbers and job titles change, and a stale distribution list is a common way this quietly breaks. Pull up the address the system would report for a 911 call from your least-used conference room or the branch office nobody talks about, and compare it to the building's actual floor and suite; if it just shows the company's mailing address, that's the RAY BAUM's Act gap. And put in writing, in the contract or a service description, who is responsible for keeping it configured as the office adds lines, moves desks, or shifts to more remote work, because the FCC's default answer is the MLTS manager, not the vendor, unless you agreed otherwise.
This checklist runs alongside, not instead of, the call recording consent rules that apply to the same phone lines, and the caller ID authentication piece covers a completely different kind of compliance risk on the same system. Kari's Law, dispatchable location, call recording consent, and caller ID attestation are four separate checklists that happen to apply to the same business phone line.
FAQ
Where does Kari's Law stop and where does RAY BAUM's Act pick up?
One handles getting through, the other handles being found. Direct-dial access plus the internal alert that someone dialed emergency services is the first statute's job; making sure the dispatcher actually knows which room to send help to belongs to the second [FCC, PS Docket No. 18-261, 2019].
Does this apply to a 5-person office with one shared VoIP number?
The FCC's definition of a covered system is broad enough to reach a small cloud phone setup the moment it has an auto attendant, a shared extension, or more than one handset tied to the account, not just enterprise PBX hardware. A single line with no menu options and nothing else attached to it generally falls outside the definition [FCC, PS Docket No. 18-261, 2019].
If my VoIP vendor says it's Kari's Law compliant, am I automatically compliant too?
Not automatically. A failure defaults to being charged against whoever actually runs the system day to day, and that presumption only shifts if the operator can document its own side was handled [FCC, para. 107]. A compliant platform still needs the notification turned on, pointed at a real person, and the location record kept current as the office changes.
What happens if a location moves and nobody updates the address?
Whatever a device or network was last told about where it sits is what a dispatcher sees, regardless of where the phone is actually sitting that day. A team that opens a new floor or lets someone dial in from a coffee shop without refreshing that record risks first responders showing up at an address nobody's at anymore, the exact failure mode the dispatchable-location rule was written to prevent [FCC, para. 137].
Can a state require something stricter than the federal law?
Yes. The federal statute leaves room for state and local rules on the same subject as long as they don't conflict with it [FCC, para. 11], and more than twenty states had passed comparable rules covering the same MLTS gap before Washington acted. Check the local rule instead of assuming the federal floor is the only one that applies.
Is there an actual penalty for non-compliance, or is this mostly theoretical?
A per-violation fine of up to $10,000 sits in 47 U.S.C. § 501, with an added per-day charge of up to $500 for a violation that keeps going under § 502; imprisonment is off the table here by design [FCC, footnote 272]. Named enforcement cases citing this specific statute are hard to find in public record, but the exposure on paper is real, and it starts with whoever runs the system.