What Is Kari’s Law? 911 Dialing, Notification, and Compliance

Kari’s Law is a federal statute, codified at 47 U.S.C. § 623, that requires multi-line telephone systems to let anyone dial 911 directly without first punching an access code like “9” for an outside line, and to alert someone on-site whenever a 911 call is placed. It’s named for Kari Hunt, who was killed in a Marshall, Texas motel room in 2013 while her nine-year-old daughter tried repeatedly to reach 911 from the room phone. The calls never connected because the hotel’s system required an access digit before any outside call.¹

If your organization runs a phone system with multiple stations sharing common infrastructure, the law almost certainly applies to you. Here is what it requires, who it covers, and how compliance actually works.

What the Law Requires

The statute puts obligations on two groups. Manufacturers, importers, and sellers cannot offer a multi-line telephone system in the United States unless it comes preconfigured for direct 911 dialing. Installers, managers, and operators of those systems have to configure and maintain them the same way.²

Direct 911 Dialing

Dialing 9-1-1 on any phone connected to the system must reach emergency services immediately, regardless of any prefix the system normally requires for outside calls. If external calls route through a trunk-access code, the system still has to recognize 911 as an emergency call and bypass that code.¹

On-Site Notification

Whenever someone dials 911, the system must send an alert to a central location at the building or to a designated person. FCC rules layer three conditions on top: the alert must go out at the same time as the 911 call, must not delay the call, and must be sent somewhere a person is likely to see or hear it.³

The notification itself has to carry three pieces of information: that a 911 call was made, a callback number, and whatever location information the system sends to the emergency dispatch center.¹

You have flexibility in routing that alert. It can go to an on-site security desk, a specific employee (in the building or not), or a third-party monitoring service off-site. Many organizations split the routing, sending alerts to a front desk during business hours and to an off-site service after hours.⁴

One exception matters: if the system cannot be configured to send notifications without a hardware or software upgrade, the notification obligation does not apply. This mostly protects older systems that physically lack the capability.¹

Dispatchable Location Under RAY BAUM’s Act

Kari’s Law is usually implemented alongside a companion rule from Section 506 of the RAY BAUM’s Act, which the FCC finalized in the same proceeding. RAY BAUM’s Act tackles what Kari’s Law does not: making sure dispatchers know where in a building the caller is. Telling a dispatcher a call came from a 20-story office tower is not useful. Telling them it came from the 14th floor, room 1412, is.⁵

The rule requires multi-line telephone systems to convey a “dispatchable location” with each 911 call: the street address plus whatever detail is needed to find the caller quickly, such as a floor, room, or wing. In a campus setting or a multi-story building, a street address alone doesn’t cut it.⁵

Compliance deadlines have already passed. Fixed desk phones had to provide automated dispatchable location by January 6, 2021. Devices a user can move (wireless handsets, conference phones, off-premises softphones) had until January 6, 2022.³

Who Has to Comply and When

The law reaches multi-line telephone systems in hotels, offices, schools, hospitals, government buildings, and any other setting where multiple phones share common infrastructure. If phones in the building run through a central system rather than each having an independent line, assume you’re covered.

The trigger date is February 16, 2020. Any system manufactured, imported, first sold or leased, or installed after that date is covered. Systems in place on or before that date are generally exempt.¹

That grandfather clause has a limit. A significant upgrade after February 16, 2020 can pull an older system into compliance. The FCC treats upgrades to core software or hardware as significant enough to trigger the obligation. Routine maintenance and minor patches don’t count, but substantial software upgrades or any software upgrade requiring a significant purchase do.⁶

Responsibility splits by role. Manufacturers and sellers must ship preconfigured systems. Whoever installs, manages, or operates the system has to actually configure direct dialing, notification, and location. When a system falls out of compliance, the operator is presumed responsible.⁷

Remote Workers and Off-Premises Devices

Remote work complicates this. If your phone system extends to devices employees use outside the office (softphones, laptop-based phone clients, company handsets taken home), those off-premises devices are subject to dispatchable location requirements too.⁸

For off-premises devices, the system must provide automated dispatchable location if technically feasible. When automation isn’t possible, the fallback is a manually updated location entered by the user. If neither works, the system must provide the best location data reasonably available.⁹

This is where organizations tend to have gaps. If you rolled out a cloud phone system or unified communications platform that employees use from home, the dispatchable location rules still apply. Most VoIP providers offer built-in tools that require remote users to register and periodically confirm their physical address. If the feature exists in your platform and you haven’t turned it on, you have a compliance problem.

How to Configure Your System

Compliance breaks down along the three requirements.

For direct dialing, adjust the dial plan so 9-1-1 from any station reaches emergency services with no prefix. If the system requires “9” for an outside line, make 911 bypass that. Test from multiple stations, including phones in lobbies, conference rooms, and break areas that are easy to forget.

For notification, configure the alert to fire whenever a 911 call is placed. Choose the recipient (front desk, security office, off-site monitor), include the callback number and caller location, and confirm the alert goes out simultaneously with the 911 call without slowing it down.³

For dispatchable location, program location data into the system so each phone station maps to a specific address, floor, and room. For large or multi-building sites, this is a real mapping project. Location data has to be updated whenever phones move or offices are reassigned.

Train the people who receive 911 notifications. The alert exists so someone inside can guide first responders, unlock doors, or provide immediate help. An alert nobody understands or acts on defeats the point.

Penalties for Noncompliance

The FCC enforces Kari’s Law through the forfeiture provisions of the Communications Act.¹ For most organizations running multi-line phone systems, the catch-all forfeiture cap applies: up to $25,132 per violation or per day of a continuing violation, with a ceiling of $251,325 for any single act. Common carriers face maximums of $100,000 per violation, capped at $1,000,000 per single act. These figures adjust annually for inflation.¹⁰ State and local agencies cannot waive these requirements; waiver requests go to the FCC directly.⁷

FCC fines are not the biggest financial risk. If someone is hurt or killed because the phone system blocked or delayed a 911 call, the organization operating that system faces wrongful death or negligence lawsuits that can dwarf any regulatory penalty. The Hunt family’s own wrongful death suit against the hotel where Kari was killed produced a $41 million jury verdict, and that case was decided before Kari’s Law existed. With federal law now explicitly requiring direct 911 dialing, a plaintiff’s attorney in a similar case has a stronger argument about the facility’s duty of care. Noncompliance can also create workplace safety exposure if employees cannot reach emergency services from their workstations.

State Rules Still Apply

Kari’s Law does not override state or local emergency communications rules. The statute preserves the authority of state commissions and local agencies that regulate emergency calling, as long as their requirements do not conflict with the federal law.¹ Some states impose additional testing obligations or surcharges on commercial lines. Check whether your state adds requirements beyond the federal baseline before treating FCC compliance as the end of the analysis.

1
Federal Communications Commission. Implementing Kari’s Law and Section 506 of RAY BAUM’S Act
2
Office of the Law Revision Counsel. 47 USC 623 – Kari’s Law
3
eCFR. 47 CFR 9.16 – General Obligations – Direct 911 Dialing, Notification, and Dispatchable Location
4
National 911 Program. Kari’s Law and RAY BAUM’s Act Information
5
911.gov. Dispatchable Location Requirements
6
Federal Communications Commission. Frequently Asked Questions – 911 Direct Dialing, Notification, and Dispatchable Location Requirements for Multi-Line Telephone Systems
7
Federal Register. Implementing Kari’s Law and RAY BAUM’s Act
8
eCFR. 47 CFR Part 9 – 911 Requirements
9
Federal Communications Commission. Multi-line Telephone Systems – Kari’s Law and RAY BAUM’s Act 911 Requirements
10
Federal Register. Annual Adjustment of Civil Monetary Penalties to Reflect Inflation