For years, many organizations assumed that if their phone system predated Kari’s Law or the RAY BAUM’s Act, they were in the clear. But recent FCC guidance makes it clear: there’s no permanent grandfathering of older multi-line telephone systems (MLTS).
If your system has been updated, reconfigured, or expanded since February 16, 2020, there’s a strong chance you’re now required to comply with the same emergency calling rules as new systems.
Why Compliance Matters
When someone dials 911, there’s no room for error. Lives depend on calls going through quickly, reaching the right Public Safety Answering Point (PSAP), and delivering accurate location details. That’s why the FCC continues to emphasize compliance for all organizations, regardless of system age.
Failure to meet requirements under Kari’s Law or the RAY BAUM’s Act can put employees, students, or visitors at risk — and expose organizations to liability.
What the Rules Require
Kari’s Law:
- Users must be able to dial 911 directly without an extension or prefix.
- The system must send a real-time notification to on-site personnel (like security or a front desk) whenever a 911 call is placed.
RAY BAUM’S Act:
- Every 911 call must include a dispatchable location — not just a street address, but additional details like floor, suite, or room number to help responders reach the caller quickly.
What Triggers Compliance
Even if your system was originally installed before 2020, certain changes can bring it under FCC requirements:
- Moving from a PBX to a VoIP or cloud-based system
- Expanding into new campuses, floors, or buildings
- Deploying softphones, mobile clients, or hybrid work solutions
- Replacing call servers, gateways, or other key infrastructure
- Making significant configuration changes that affect call routing
If your organization has made any of these updates, compliance is no longer optional.
Next Steps for Organizations
- Review your system – Identify whether your MLTS has been modified since February 2020.
- Validate 911 capabilities – Confirm that your platform supports direct dialing, automatic notifications, and accurate location delivery.
- Educate your team – IT, facilities, and safety staff should all understand how 911 works on your network.
- Test and monitor – Work with PSAPs to regularly confirm your system routes correctly and provides the right information.
Key Takeaway
FCC rules around Kari’s Law and the RAY BAUM’s Act aren’t just compliance checkboxes — they’re about saving lives. If your phone system has evolved in the past few years, don’t assume it’s exempt. Take steps now to ensure every 911 call from your organization reaches the right responders, with the right information, every time.
At 9Line, we help organizations navigate these requirements and implement solutions that protect what matters most: people.