Kari's Law and RAY BAUM'S Act: What Offices Must Do

Kari's Law compliance comes down to two obligations, and the RAY BAUM'S Act adds a third. A multi-line phone system must let anyone dial 911 directly with no prefix, must notify someone on site when 911 is dialed, and must deliver a dispatchable location — a street address plus the detail that gets responders to the right door.

We implemented all three in Signal rather than reading about them, so this is written from the configuration side. Where the rule ends and your responsibility begins is the part most summaries skip.

What does Kari's Law require?

Two things, both about the moment someone dials.

Direct dialing. A multi-line telephone system must connect a call to 911 without requiring a prefix, access code, or any other digit first. It may still allow 9-911 to work — and it should — but 911 alone must be enough.

Notification. When 911 is dialed, the system must notify a central location on site, or an off-site location where someone is likely to see or hear it. It has to identify that a 911 call was made, provide a callback number, and convey the caller's location to the extent the system can.

The law is named for Kari Hunt, who was killed in a Texas motel room in 2013 while her nine-year-old daughter dialed 911 four times. The calls never connected, because the motel's system required a 9 first and nobody had told the guests. That history explains the rule: it is not about capability in the abstract, but about whether a person under stress who has never read a placard can reach help by dialing the number everyone already knows.

Kari's Law took effect on February 16, 2020, and applies to systems manufactured, imported, offered for first sale or lease, first sold or leased, or installed after that date.

What does the RAY BAUM'S Act require?

Section 506 requires that a dispatchable location be conveyed with a 911 call — the street address plus additional information such as suite, floor, or room number sufficient to identify the caller's location.

An address alone is often not enough. A 911 call from a four-story medical building tells responders which building, then they lose four minutes finding which practice. The obligations phased in on two dates:

The second RAY BAUM'S date catches modern offices. "Non-fixed" covers a softphone on a laptop and a desk phone someone moved — devices whose location the system cannot infer from a wall jack. Remote and hybrid teams need a deliberate answer rather than an assumption.

Does Kari's Law apply to a small office?

Yes. There is no employee-count exemption, and a five-person office running a cloud phone system is a multi-line telephone system for the purposes of the rule.

The common misreading is that these are hotel and campus regulations. They came out of a hotel incident, but the rules apply to multi-line systems generally — dental practices, law firms, contractors, and clinics included. The second is that a cloud provider handles all of it invisibly. The dispatchable location part, it does not — not without you.

Who is responsible for 911 compliance, the provider or the business?

Both, on split lines. The provider builds the capability; the business supplies and maintains the location data that makes it accurate.

What we own:

• 911 dials directly on every extension, with no prefix, never gated by dialing permissions — an extension blocked from long distance and international still reaches 911, 988, 711, and 933.
• The on-site notification fires when 911 is dialed, to the destination the account configures.
• Each phone number and each location carries a registered E911 address, validated before it is accepted.

What you own:

• The real address of each location, with suite and floor detail.
• Where the 911 notification goes — a person actually on site, not a shared inbox nobody reads.
• Updating the record when a phone moves, a suite number changes, or someone starts working from home.

That last item is the one that goes stale. An E911 address is not automatic and does not follow a handset carried to a new building. E911 locations covers registration, and E911 address problems covers correction.

What happens if you dial 9 before 911?

On a correctly configured system, it works — and 911 by itself works too. Both patterns should reach the same place.

The failure mode the law was written against is a system where 9-911 is the only pattern that connects and 911 alone returns an error, a reorder tone, or silence. Every visitor and most new employees hit that wall at the worst moment.

Test it. Dialing 933 reaches a recording that reads back the number and the registered address your carrier holds, verifying the location half without calling a dispatcher. For the direct-dial half, coordinate a test 911 call with your PSAP's non-emergency line. Our post on the codes your phone system must support covers all four.

The three failure modes we see

Almost every non-compliant small office fails in one of these ways, and none announce themselves:

1. A stale address. The office moved, expanded into the next suite, or renumbered, and the E911 record still points at the old door. Nothing in daily operation reveals this. A 933 call does.
2. A notification nobody receives. The alert goes to an address belonging to an office manager who left, or a shared mailbox nobody watches. The requirement is that someone likely to see or hear it gets it.
3. Remote and roaming phones. A softphone on a laptop, or a desk phone taken home, still carries the address of the office it was registered at. This is the case the January 2022 phase-in was written for. Our post on E911 for remote employees covers the options.

A fourth is not a configuration problem at all: during an internet outage, a VoIP phone cannot reach 911. Every office should identify a cell phone as the fallback and say so out loud to staff.

What to do this month

1. Dial 911 from one handset — not 9-911 — with your PSAP's non-emergency line notified in advance, and confirm what address they see.
2. Dial 933 from each location and confirm the read-back matches the door, including the suite.
3. Check who receives the 911 notification and confirm that person is in the building on a normal day.
4. List every non-fixed device and confirm each address matches where it sits.
5. Put "update E911" in your offboarding and office-move checklists.

Frequently asked questions

What does Kari's Law require?

Two things: 911 must dial directly with no prefix or access code, and the system must notify a central on-site location, or an off-site location where someone is likely to see or hear it. The notification must identify that a 911 call occurred, give a callback number, and convey location information.

What does the RAY BAUM'S Act require?

Section 506 requires a dispatchable location with every 911 call — a validated street address plus the suite, floor, or room detail needed to find the caller. It applied to fixed multi-line systems on January 6, 2021, and to non-fixed systems and interconnected VoIP on January 6, 2022.

Does Kari's Law apply to a small office?

Yes. The rules cover multi-line telephone systems generally, with no small-business exemption. A five-person dental practice with extensions on a shared trunk is in scope exactly as a hotel is, and the obligations attach to systems installed after February 16, 2020.

Who is responsible for 911 compliance, the provider or the business?

Split. The provider must make 911 dial directly, send the notification, and carry a dispatchable location. The business must supply validated addresses for each location and number, choose a notification destination someone monitors, and update all of it when phones or offices move.

What happens if you dial 9 before 911?

On a compliant system it connects, and so does dialing 911 alone. The prohibited configuration is one where only the prefixed pattern works. Verify by dialing 933 to hear the address on file, and coordinate any live 911 test with your PSAP's non-emergency line first.

If you are not certain what address your handsets would hand a dispatcher, that is a fifteen-minute check with a definite answer. Tell us how many locations and remote phones you have and we will walk the registrations with you.