Kari’s Law and RAY BAUM’S Act: Requirements, Deadlines, and Penalties

Complying with Kari’s Law and Ray Baum’s Act means configuring your multi-line telephone system so that anyone can dial 911 directly without a prefix, so a designated person on-site is notified the moment a 911 call goes out, and so the call carries a specific dispatchable location to emergency dispatchers. Every compliance deadline has already passed. The FCC can fine most organizations more than $25,000 per violation per day, and a non-compliant system that delays emergency response opens the door to wrongful death and personal injury claims that typically dwarf the regulatory penalty.

The Three Things Your Phone System Must Do

Kari’s Law and Section 506 of Ray Baum’s Act together impose three technical requirements on multi-line telephone systems, known as MLTS. These are the PBX, hybrid, key, Centrex, and VoIP-based phone networks found in offices, hotels, hospitals, schools, and similar organizations.¹ If your workplace has a phone system where multiple users share outside lines, you almost certainly have an MLTS.

Direct 911 Dialing

Every phone on the system must let a user reach 911 by dialing those three digits, with no “9” or other access code first. This applies regardless of whether other outside calls require a prefix.² Legacy PBX systems commonly default to requiring a “9” for outside lines, and that setting can reappear after firmware updates or system migrations, so testing from phones on different floors and in different buildings is worth doing on a schedule rather than once.

On-Site Notification

When someone dials 911 from the system, the MLTS must automatically notify a designated person or location, such as a front desk or security office. The notification has to go out at the same time as the 911 call, cannot delay it, and must land somewhere a person is likely to see or hear it. An unmonitored email inbox does not satisfy the requirement.³

The notification must include at least three items: confirmation that a 911 call was placed, a valid callback number, and whatever location information the system sends to the 911 call center. If the system genuinely cannot provide a callback number or location data, those items may be omitted, but the notification itself is still required.³

Dispatchable Location

A 911 call must carry a “dispatchable location,” meaning the caller’s validated street address plus enough additional detail (floor, suite, room, apartment) to pinpoint where the caller actually is inside the building.¹ In a twenty-floor building with four hundred rooms, “100 Main Street” tells responders very little.

For fixed devices like desk phones that never move, the system must automatically provide dispatchable location without any action by the caller. For non-fixed devices on the same premises, such as wireless handsets that move between floors, automated dispatchable location is required when technically feasible. When it isn’t, the fallback is a manually updated location or alternative data that at least identifies the civic address and approximate in-building position, including floor level in large buildings. Off-premises MLTS devices carry the same automated-when-feasible standard, with a manual location or “enhanced location information” as the fallback.³

The dispatchable location rule reaches beyond MLTS. It also covers fixed telephone service, interconnected VoIP, Internet-based Telecommunications Relay Services, and mobile text-to-911.⁴

Who Has to Comply

The obligations run through the whole MLTS supply chain: manufacturers and importers must pre-configure systems before sale, installers must set them up correctly on deployment, and managers and operators must keep them compliant for as long as the system is in use.² For-profit businesses, government agencies, and nonprofits are all covered.¹

Deadlines Have All Passed

The direct dialing and on-site notification rules apply to any MLTS manufactured, imported, sold, leased, or installed after February 16, 2020.³ The dispatchable location requirements phased in later:

January 6, 2021: fixed, on-premises MLTS devices, fixed telephone service, and fixed interconnected VoIP had to begin providing automated dispatchable location.
January 6, 2022: non-fixed on-premises MLTS devices, off-premises MLTS devices, non-fixed interconnected VoIP, and outbound-only VoIP had to begin providing dispatchable location or an approved alternative.³

An organization that is not yet compliant is already exposed.

FCC Fines

The FCC enforces both laws under its general forfeiture authority in 47 U.S.C. § 503. Amounts are adjusted for inflation each year. The figures below reflect the 2025 schedule.⁵

Common carriers (telecommunications companies providing MLTS-related services): up to $251,322 per violation or per day of a continuing violation, capped at $2,513,215 for any single act or failure to act.
All other entities (hotels, offices, schools, hospitals, and similar operators): up to $25,132 per violation or per day of a continuing violation, capped at $188,491 for any single act or failure to act.⁶

The per-day structure is the part that hurts. An organization that leaves the “dial 9 first” default in place for months is not looking at a single fine. Each day counts as a separate violation, up to the statutory cap.

Lawsuits Are the Bigger Risk

For most operators, the FCC penalty is the smaller number. When a non-compliant phone system delays emergency response and someone is injured or killed, the organization running that system faces wrongful death and personal injury claims. Those claims do not depend on FCC action. Violation of a federal safety mandate can itself serve as evidence of negligence, and settlements and verdicts in 911-failure cases have reached into the millions of dollars.

A Practical Compliance Check

Start by dialing 911 from phones on different floors and in different buildings to confirm the call goes through without a prefix. Then look at the notification path: when a phone dials 911, does an alert reach a person who can actually unlock a door for paramedics or point them to the correct floor? A notice sent nowhere anyone watches does not meet the rule.³

For dispatchable location, map every fixed phone to a specific location in the system’s database, including floor, wing, and room. Keep the database current as phones move and offices get reassigned. For wireless handsets and other non-fixed devices, work with your vendor on the best available automated solution or set up a documented manual-update process. The standard is automated location when technically feasible and a reasonable alternative when it isn’t.³

State and Local Rules Can Add More

Kari’s Law preserves state and local authority over emergency communications so long as those rules do not conflict with federal requirements.² Several states enacted their own MLTS 911 laws, some predating the federal rules, and some add obligations such as registering multi-line systems with local 911 authorities or conducting periodic testing. Federal compliance does not automatically cover state and local requirements. Check with your state public utility commission or 911 coordinator for anything specific to your jurisdiction.

1
eCFR. 47 CFR 9.3 – Definitions
2
Office of the Law Revision Counsel. 47 USC 623 – Configuration of Multi-Line Telephone Systems for Direct Dialing of 9-1-1
3
Federal Communications Commission. Multi-line Telephone Systems – Kari’s Law and RAY BAUM’S Act 911 Direct Dialing, Notification, and Dispatchable Location Requirements
4
Federal Communications Commission. Dispatchable Location for 911 Calls from Fixed Telephony, Interconnected VoIP, TRS, and Mobile Text Service
5
Federal Register. Annual Adjustment of Civil Monetary Penalties To Reflect Inflation
6
Office of the Law Revision Counsel. 47 USC 503 – Forfeitures