RAY BAUM’s Act Section 506: Dispatchable Location and Deadlines

Section 506 of the RAY BAUM’s Act requires every multi-line telephone system (MLTS) to transmit a dispatchable location with every 911 call, meaning a validated street address plus enough interior detail (floor, room, suite) for responders to find the caller quickly. The FCC codified those requirements in 47 CFR Part 9, and the compliance deadlines have already passed: January 6, 2021 for fixed on-premises phones, and January 6, 2022 for non-fixed and off-premises devices.¹ If you run an MLTS today, you are expected to be compliant now, and forfeitures for violations can reach $25,132 per day.²

Who the Rule Applies To

The FCC defines a multi-line telephone system broadly. It covers any system with shared control units and telephone sets, including PBX systems, hybrid and key telephone systems, Centrex, and VoIP platforms. Government agencies, nonprofits, and for-profit businesses all fall inside the definition.³ If your phones share a common system where users dial extensions internally and share lines for outside calls, you almost certainly have an MLTS.

These systems are most common in corporate offices, hotels, hospitals, university campuses, and government buildings, but headcount is not the test. A 20-person office on a hosted VoIP platform is just as much an MLTS as a 2,000-room hotel. The technology is what triggers the rule.

What Dispatchable Location Means

A dispatchable location is the validated street address of the caller plus any additional information needed to locate them inside the building, such as suite number, floor, or room.³ How much interior detail you need depends on the building. A caller in a 40-story tower needs floor and suite. A caller in a small single-story business may need only a street address, because that alone tells responders where to go.⁴

The practical test is whether a responder who has never been to your building could find the caller quickly using only the information your system transmits. Once you have multiple floors, wings, or buildings on a campus, a street address alone is not enough.

The Deadlines by Device Type

The FCC set staggered deadlines based on how each phone is used:

Fixed on-premises phones, deadline January 6, 2021. A desk phone wired into a specific office must automatically transmit its dispatchable location with every 911 call. No manual step by the caller is permitted for these devices.⁵
Non-fixed on-premises devices, deadline January 6, 2022. Softphones on laptops, wireless handsets, and other devices that move around the building must provide automated dispatchable location when technically feasible. If automation is not possible, the system must fall back to a location the user has manually entered.⁵
Off-premises devices, deadline January 6, 2022. Remote workers using company softphones or other MLTS-connected devices from outside the office must also have their location conveyed to the PSAP. If automated tracking is not technically feasible, the system must provide location based on a manual user update, or the best coordinate-based location available at reasonable cost.¹

The phrase “when technically feasible” is not a blanket excuse. It acknowledges that a laptop on hotel Wi-Fi presents different challenges than a wired desk phone, but the fallback obligations still apply. Doing nothing is not an option the regulation contemplates.

The Legacy System Exemption

Systems manufactured, first sold or leased, or installed on or before February 16, 2020 are exempt from the dispatchable location and direct dialing requirements.¹ The moment you upgrade, replace, or install new equipment, the full set of requirements applies. Treating the exemption as permanent cover is risky; treat any future upgrade as the point at which you become subject to the rules.

Direct Dialing and On-Site Notification

Section 506 does not stand alone. The FCC combined it with Kari’s Law in a single regulation at 47 CFR 9.16, so compliance with Section 506 in practice means satisfying two additional obligations at the same time.⁶

Direct Dialing

Every MLTS must allow users to dial 911 directly without any prefix, access code, or extra digit, including the “9” that many older systems required to reach an outside line.⁷ The obligation runs two ways: manufacturers and importers cannot sell systems that are not pre-configured for direct dialing, and installers, managers, and operators cannot run a system unless it is configured this way.⁶

On-Site Notification

When someone dials 911 from an MLTS, the system must simultaneously send a notification to a central location at the facility, like a front desk or security office. The notification cannot delay the 911 call. It must include three things: the fact that a 911 call was made, a valid callback number, and the caller’s location information.¹

The alert can take different forms: a pop-up on a security desk computer, a text message, or an email. It has to go somewhere a person is likely to see or hear it. Sending it to an unmonitored inbox does not satisfy the rule.

Remote Workers Are Covered

When an employee uses a company softphone or VoIP application from a home office, that device remains part of the organization’s MLTS. If the employee dials 911 through that system, the call must deliver location information to the local PSAP, not the PSAP near company headquarters.¹

For most organizations, automated location tracking for remote workers is not technically feasible today. The practical solution is requiring employees to enter and update their home address in the phone system. Most VoIP platforms include a field for this. What matters is that employees actually do it and update it when they move or work from a different location. Building the reminder into onboarding and periodic check-ins is how you demonstrate compliance when automation is not available.

Penalties

The FCC can issue forfeiture penalties for violations of its 911 rules. Under the FCC’s general forfeiture schedule, penalties can reach $25,132 per violation or per day of a continuing violation, with a maximum of $188,491 for any single act or failure to act.² The FCC has stated it will closely monitor complaints about MLTS 911 rule violations, and both consumers and PSAPs can file complaints through the FCC’s Consumer Complaint Center or Public Safety Support Center.¹

Building owners who do not directly manage their phone systems can limit exposure by including compliance requirements in contracts with telecom vendors or managed service providers. The FCC has indicated that an owner who contracts with responsible third parties and includes compliance obligations in those agreements should not face liability under the rules.⁸ The protection requires active engagement. Not knowing your system was noncompliant will not shield you.

State Laws May Require More

The federal rules are the floor, not the ceiling. Many states enacted their own MLTS 911 laws before the federal requirements took effect, and some impose stricter obligations. State laws vary: some require station-level location data for every extension, others mandate specific configurations for residential versus business systems, and a few have had requirements on the books since the early 2000s. If your organization operates in multiple states, check each state’s rules and comply with whichever standard is more demanding. State public utility commissions or equivalent agencies typically enforce state-level obligations, while the FCC enforces the federal rules.

1
Federal Communications Commission. Multi-line Telephone Systems – Kari’s Law and RAY BAUM’s Act 911 Direct Dialing, Notification, and Dispatchable Location Requirements
2
eCFR. 47 CFR 1.80 – Forfeiture Proceedings
3
eCFR. 47 CFR 9.3 – Definitions
4
911.gov. Dispatchable Location Requirements
5
eCFR. 47 CFR Part 9 – 911 Requirements
6
eCFR. 47 CFR 9.16 – General Obligations – Direct 911 Dialing, Notification, and Dispatchable Location
7
Office of the Law Revision Counsel. 47 USC 623 – Configuration of Multi-Line Telephone Systems for Direct Dialing of 911
8
Federal Communications Commission. Implementing Kari’s Law and Section 506 of RAY BAUM’s Act