---
title: "Kari's Law, RAY BAUM'S Act and VoIP E911 Explained | PBXflex"
description: "What Kari's Law and RAY BAUM'S Act require of an office phone system, what the FCC's E911 rules require of a VoIP provider, and a small-office checklist."
url: "https://www.pbxflex.com/guides/karis-law-ray-baums-act-e911"
---

# Kari's Law, RAY BAUM'S Act and E911: what a small office must do

By the PBXflex team. Updated October 17, 2026.

## The short answer

Kari's Law requires that anyone can dial 911 from an office phone system with no "9" or other prefix, and that the system notifies someone on site when a 911 call is made. Section 506 of RAY BAUM'S Act requires the call to carry a "dispatchable location": the street address plus the suite, floor or room. Both apply to multi-line phone systems installed after February 16, 2020, and the duties fall on whoever installs, manages or operates the system, which can include the business itself. FCC rules also require every VoIP provider to offer 911, collect each customer's location, and warn that VoIP 911 may not work without power and internet. On PBXflex, the E911 address is set per extension.

## Why these laws exist

In 2013, Kari Hunt was killed in a motel room in
Marshall, Texas. Her nine-year-old daughter tried to call 911 from the room
phone four times. The calls never went through, because the motel's phone
system needed a 9 before any outside number, and she did not know that.

Congress passed Kari's Law in 2018. The same year, Section 506 of RAY BAUM'S
Act asked the FCC to make sure 911 calls carry a location that responders can
act on. In August 2019 the FCC adopted the rules that put both into effect.
They are in Part 9 of the FCC's rules.

## Which phone systems the rules cover

Both laws apply to a **multi-line telephone system**, or MLTS. The FCC
describes these as the systems typically found in office buildings, campuses
and hotels: one system, many phones. A cloud PBX serving an office is one. So
is an on-premises PBX or key system.

The rules are forward-looking. They apply to a system that was manufactured,
imported, offered for first sale or lease, first sold or leased, or installed
**after February 16, 2020**. A system installed on or before that date is
exempt from the federal rules, though the law leaves state authority over
emergency communications in place.

The duties fall on two groups:

- **Manufacturers, importers, sellers and lessors** of the system.
- **Installers, managers and operators** of the system.

A business that runs its own phone system is a manager or operator of it.
That is why the rules matter to an office, not only to phone vendors.

## Kari's Law: direct dialing and notification

Kari's Law has two requirements. Both took effect on February 16, 2020.

### Direct dialing

A user must be able to dial 911 from any phone on the system **without any
prefix, code or post-fix**, including a trunk-access digit such as 9, even if
the system requires that digit for other outside calls.

For the system's maker and seller, that means shipping it pre-configured so
that, properly installed, 9-1-1 just works. For the installer, manager and
operator, it means keeping it configured that way.

### Notification

When a 911 call is made, the system must send a notification to a central
location on site, or to a person or organization anywhere, where someone is
likely to see or hear it. The point is to help first responders get into the
building and find the caller.

The notification must:

- be sent at the same time as the 911 call, where technically feasible;
- not delay the 911 call; and
- include that a 911 call was made, a valid callback number, and the
  location information the system sends to the 911 center, where feasible.

The FCC's examples of a notification are an on-screen message with an alarm
on a security desk computer, a text message to a phone, or an email to an
administrator.

This duty applies only if the system can be configured to notify **without an
improvement to its hardware or software**. A system that can do it must be
set up to do it.

## RAY BAUM'S Act: dispatchable location

Section 506 of RAY BAUM'S Act is about where the call comes from.

A **dispatchable location** is the validated street address of the caller,
plus the additional information, such as suite, apartment, floor or room,
needed to find them. "123 Main Street" is not enough for a six-story
building. "123 Main Street, Suite 410" is.

The FCC set two deadlines for multi-line systems, depending on the device:

| Device | Deadline | What it must send |
| --- | --- | --- |
| On-premises, fixed (a desk phone that stays put) | January 6, 2021 | Automated dispatchable location |
| On-premises, non-fixed (a softphone or cordless handset used around the building) | January 6, 2022 | Automated dispatchable location if technically feasible; otherwise a location the user updates, or alternative location information that identifies the address and approximate in-building location, including floor level in large buildings |
| Off-premises (a laptop or mobile app used away from the office) | January 6, 2022 | Automated dispatchable location if technically feasible; otherwise a location the user updates, or the best available location that can be obtained at reasonable cost |

The same two groups are responsible. A maker may not sell a system that
cannot do this once properly installed. An installer may not install one that
is not configured to be programmed with and convey the location. A manager or
operator may not run one that does not convey it.

For a small office the practical point is simple. Every phone, including a
softphone on a laptop, needs an address on file that would get an ambulance
to the right door, and that address has to change when the phone does.

## What the FCC requires of your VoIP provider

Separately from Kari's Law and RAY BAUM'S Act, the FCC's E911 rules bind every
**interconnected VoIP** provider: a service that lets you call and be called on
the ordinary phone network over the internet, which is what a cloud PBX is.
The rules are in 47 CFR § 9.11. In the FCC's consumer-guide summary, a
provider must:

- provide 911 to every customer as a standard, mandatory feature, with no
  opt-out;
- obtain the customer's physical location before service starts, and give
  the customer one or more easy ways to update it when it changes;
- send every 911 call, with a callback number and the registered location,
  to the right 911 center;
- make sure customers clearly understand any limits on their 911 service,
  and distribute warning labels to place on or near the equipment where 911
  may be limited or unavailable;
- obtain and keep each customer's acknowledgement that they understand
  those limits.

The rule itself (§ 9.11(b)) adds the dates: these location duties apply from
January 6, 2021 for fixed services and January 6, 2022 for non-fixed services.
For a non-fixed service, which can be used from more than one place, the
provider must either deliver an automated dispatchable location where
technically feasible, or rely on a **Registered Location** that the customer
gave before service began and can update at will, or provide alternative
location information, or route the call to a national emergency call center.

The limits the rule says customers must be told about include moving the
equipment to a new place, a broadband failure, loss of electrical power, and
delays in getting the location into the 911 database.

## The limits of VoIP 911, and what to do about them

The FCC's consumer guide is blunt about where VoIP 911 can fail:

- A call may reach the wrong 911 center, or an administrative line that is
  not staffed after hours, if the registered location is stale.
- A call may connect but not carry the number or location automatically.
- The service may not work in a power cut, or when the internet is down or
  overloaded.

Its advice is the same for any office:

1. Give your provider an accurate physical address, with suite or floor.
2. Know how to update it, and update it promptly when anything moves.
3. Understand the limits of your 911 service and tell the people who use the
   phones, including visitors and anyone who covers the front desk.
4. Keep a backup: a charged mobile phone, a battery for the network
   equipment, or a traditional line.

## A checklist for a small office

Work through this once, then again whenever the office changes.

| Step | What to check |
| --- | --- |
| Direct dialing | 9-1-1 works from every phone and softphone with no prefix. Do not test by dialing 911 without arranging it with your local 911 center first. |
| Notification | If your system can send a 911 notification without new hardware or software, it is switched on and goes somewhere a person will see or hear it. |
| Address on every phone | Each phone, including laptop and mobile apps, has a street address with suite, floor or room. |
| Moves | Someone owns updating addresses when a person changes desks, moves offices or starts working from home. |
| Staff | People who use the phones know that VoIP 911 depends on power and internet, and know where the backup phone is. |
| Labels | The warning labels your provider supplied are on or near the equipment. |
| Record | Keep a note of when you checked, so the next person can see it. |

## How this works on PBXflex

On PBXflex, the E911 address is registered **per extension**, in the app.
Each person's [extension](https://www.pbxflex.com/features/user-phone-extension) carries its own
address, so a desk phone in suite 410 and a colleague working from home can
each have the address responders need. When someone changes desks, moves
offices or starts working from home, update that extension's E911 address.

The [security page](https://www.pbxflex.com/security) lists what else PBXflex does with credentials,
E911 and texting rules. The 911 fees that may appear on a phone bill are
explained in the [cost guide](https://www.pbxflex.com/guides/business-phone-system-cost).

This guide summarizes public FCC rules as they read on the date shown at the
top. It is not legal advice. For your own obligations, read the sources below
or ask a lawyer.

## Questions people ask

### What is Kari's Law in plain terms?

Any phone on a multi-line phone system must reach 911 when someone dials 9-1-1, with no prefix such as 9 for an outside line. When a 911 call is made, the system must notify a central location, such as a front desk or an administrator, if it can do so without new hardware or software. It applies to systems installed after February 16, 2020.

### What is RAY BAUM'S Act Section 506?

The part of a 2018 law that led the FCC to require a "dispatchable location" with 911 calls: the validated street address plus the suite, floor, room or similar detail that gets responders to the caller. For multi-line systems, fixed desk phones had to comply by January 6, 2021 and non-fixed or off-premises devices by January 6, 2022.

### What is E911?

Enhanced 911. A 911 call that also delivers the caller's callback number and location to the 911 center. The FCC requires interconnected VoIP providers to offer it to every customer, as a condition of service.

### Does Kari's Law apply to a small business?

The duties fall on anyone who manufactures, sells, installs, manages or operates a multi-line telephone system. A business that runs its own office phone system is managing or operating one. If your system was installed on or before February 16, 2020, the federal rules do not apply to it, but state rules may.

### Does VoIP 911 work in a power cut?

Usually not. The FCC's consumer guide says VoIP service may not work during a power outage or when the internet connection fails. Keep a mobile phone charged as a backup, and tell staff.

### How do I keep E911 addresses right on PBXflex?

Each extension's E911 address is registered in the app. When someone changes desks, moves offices or starts working from home, update that extension's address.

### Is this legal advice?

No. It summarizes public FCC rules as they read on the date at the top of the page. For your own obligations, read the sources listed below or ask a lawyer.

## Sources

- [FCC, Multi-line Telephone Systems – Kari's Law and RAY BAUM'S Act 911 Direct Dialing, Notification, and Dispatchable Location Requirements](https://www.fcc.gov/mlts-911-requirements)
- [FCC, VoIP and 911 Service (consumer guide)](https://www.fcc.gov/consumers/guides/voip-and-911-service)
- [47 U.S.C. § 623, Configuration of multi-line telephone systems for direct dialing of 9-1-1 (Cornell LII)](https://www.law.cornell.edu/uscode/text/47/623)
- [47 CFR § 9.16, General obligations, direct 911 dialing, notification, and dispatchable location (Cornell LII)](https://www.law.cornell.edu/cfr/text/47/9.16)
- [47 CFR § 9.11, E911 Service (Cornell LII)](https://www.law.cornell.edu/cfr/text/47/9.11)
- [47 CFR § 9.3, Definitions (Cornell LII)](https://www.law.cornell.edu/cfr/text/47/9.3)

## Keep reading

- [How PBXflex handles credentials, E911 and texting rules](https://www.pbxflex.com/security)
- [Phone extensions on desk phone, web and mobile](https://www.pbxflex.com/features/user-phone-extension)
- [What a business phone system costs, including 911 fees](https://www.pbxflex.com/guides/business-phone-system-cost)
- [What a PBX is, and what a multi-line phone system means](https://www.pbxflex.com/guides/what-is-a-pbx)
- [Cloud PBX for small business](https://www.pbxflex.com/cloud-pbx)

## Contact

- Email: hello@pbxflex.com
- Phone: (877) 575 - 9527
- Address: 1001 Wilshire Blvd, Los Angeles, CA 90017
- Sign up: https://pbxflex.app/auth/sign-up