Photo of Wesley K. Wright

Earlier this month, the FCC released a Report and Order that implements the direct dialing and notification requirements of Kari’s Law and adopted rules requiring a dispatchable location to be conveyed with 911 calls from certain Multi-Line Telephone Systems (MLTS), pursuant to RAY BAUM’s Act.

These rules will take effect over the next few years and will apply to MLTS systems owned and operated by a wide range of industries, from large industrial companies to hotels, Fortune 100 companies to small startups. The Commission interpreted the definition of “MLTS” as broadly as possible to include IP-based telephone systems, VoIP, and outbound-only calling systems, among others.

Kari’s Law

Kari’s Law applies to manufacturers, sellers, and operators of MLTS equipment, and consists of two main provisions: direct dialing and notification.

The direct dialing provision requires all MLTS systems manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020 to be pre-configured so that a user may directly dial 911 without having to dial a prefix (e.g. the number “9”) to reach an outside line.

The notification provision mandates that all such MLTS systems must be configured to provide a notification to a central location, such as a front desk or security office, when a 911 call is made, as long as it can be done without an improvement to the hardware or software of the system. This notification can be provided to a location at the facility where the system is installed, or to another person or organization offsite.


RAY BAUM’s Act generally requires MLTS and other 911-capable services to convey a dispatchable location to Public Safety Answering Points (PSAP) when 911 calls are placed. A “dispatchable location” is the street address of the calling party, and any additional information necessary to adequately identify the location of the calling party (e.g. office number, suite number, room number, etc.). These obligations apply to the same entities subject to the direct dialing and notification requirements of Kari’s Law, excluding legacy services because they are forward-looking.

In line with the Commission’s goal of providing first responders with the dispatchable location of an emergency caller regardless of how the caller reaches 911, the adopted rules apply to several different technologies. These technologies include fixed and non-fixed MLTS devices, fixed telephony systems, and Voice over Internet Protocol (VoIP) systems.

Providers of fixed devices and services must automatically deliver a dispatchable location with any 911 calls originating from their equipment, while providers of non-fixed devices and services must do so when it is technically feasible. Providers of non-fixed VoIP and outbound-only VoIP systems have the additional option of providing alternative location information when delivering a dispatchable location is not feasible.

For more information, please contact Wes Wright, Keller and Heckman LLP, 1001 G Street NW, Washington, DC 20001; 202-434-4239; e-mail: