compliance
E911 and Your Business Phone System: What Kari's Law and RAY BAUM'S Act Actually Require
Most businesses think about 911 exactly once: never. It’s the feature you configure and pray nobody uses, and it gets a fraction of the attention lavished on auto-attendants and call analytics.
Two US federal laws — written after real tragedies — made that inattention a compliance problem. If your business operates a multi-line telephone system (MLTS), which includes essentially every modern cloud PBX, these rules apply to you. Here’s what they actually require, in plain English.
Kari’s Law: 911 must just work
Section titled “Kari’s Law: 911 must just work”Kari’s Law is named for Kari Hunt, who was killed in a Texas motel room in 2013. Her nine-year-old daughter tried to call 911 four times — and couldn’t get through, because the motel’s phone system required dialing “9” for an outside line first. Nobody had told her, and there was no reason a child should have needed to know.
The law, in force for phone systems installed since February 2020, has two core requirements:
- Direct dialing. Dialing 9-1-1 must work with no prefix, no access code, no “dial 9 first.” Whatever else your dial plan does, those three digits must reach emergency services.
- On-site notification. When someone dials 911 from your system, the system must notify a central location — a front desk, a security office, an admin’s screen or phone — so the people on site know an emergency call happened and can direct responders. The notification must include, at minimum, that a 911 call was made and a callback number, and it must go out at the same time as the call (without delaying it).
That second requirement is the one businesses miss. Direct dialing is usually the platform’s job; the notification needs someone at your business to be configured as the recipient. If you don’t know who receives your 911 notifications today, that’s your action item from this article.
RAY BAUM’S Act: 911 must know where you are
Section titled “RAY BAUM’S Act: 911 must know where you are”Dialing through is only half the problem — responders have to find the caller. RAY BAUM’S Act (Section 506) requires that a “dispatchable location” be delivered to the 911 call center with the call: not just a street address, but the information needed to actually reach the caller — building, floor, suite, room.
The FCC phased this in: fixed devices (a desk phone that never moves) by January 2021, and non-fixed devices — softphones, mobile apps, anything that roams — by January 2022. Non-fixed is the hard part, and it’s exactly how modern teams work: the same account rings a desk phone, a laptop app, and a mobile app, and each may be in a different place on any given day.
Practically, compliance means:
- Every phone location is registered and current. When you provision a user or move an office, the emergency address must be updated — “we moved last year and never updated 911” is a common and dangerous state.
- Detail matches the building. “123 Main St” is inadequate for a six-story building. Dispatchable location means floor and suite.
- Roaming users have a mechanism. Softphone users need a way to set or confirm their current location, because the address on file may be an office they’re not in.
Canada is not exempt
Section titled “Canada is not exempt”Canada has no Kari’s Law equivalent, but the CRTC imposes its own 9-1-1 obligations on VoIP providers — including routing to the correct emergency call center and clear subscriber notification of any 9-1-1 limitations, particularly for nomadic VoIP service, where the caller may not be at their registered address. If you operate on both sides of the border, build to the stricter standard everywhere: direct dialing, on-site notification, and accurate per-device locations are simply good safety practice regardless of jurisdiction.
The uncomfortable questions to ask
Section titled “The uncomfortable questions to ask”Whether you’re evaluating a new phone system or auditing the one you have, these five questions surface most gaps:
- Does 9-1-1 dial through directly — from every device type, including the mobile app?
- Who receives our on-site notifications, and have we tested that they actually arrive?
- What dispatchable location is on file for each user and device — and does it include floor/suite detail?
- What happens when a softphone user calls 911 from somewhere other than their registered address?
- When we onboard a user or move locations, whose job is it to update the emergency address?
The pattern worth noticing: half of these are provider responsibilities, and half are yours. A compliant platform can’t save you from stale location data nobody maintains.
How this shapes a phone system purchase
Section titled “How this shapes a phone system purchase”E911 handling is a genuine differentiator between providers, precisely because it’s invisible in the demo. With Nova, E911 service is part of the platform: emergency addresses are managed per location as part of provisioning, so the compliance questions above have owners and answers instead of shrugs. If you’re moving off an older system, a migration is also the natural moment to fix years of accumulated location drift — audit every registered address as part of the cutover, not after.
Nobody buys a phone system for its 911 handling. But it’s the one feature where “we never got around to configuring it” can cost a life — and, less importantly but more predictably, where regulators have decided that excuse is no longer acceptable.