Kari's Law and RAY BAUM'S Act: VoIP Compliance for Small Business 2026

The history that made the laws necessary

Kari's Law is named after Kari Hunt Dunn, killed in a Texas hotel room in 2013. Her young daughter tried four times to dial 9-1-1 from the hotel phone and could not get through because the hotel PBX required dialing 9 first to reach an outside line. The daughter, like millions of children, had been taught to dial 9-1-1 in an emergency without the prefix. The call never connected.

The legislative response was Kari's Law, signed in 2018 and codified at 47 CFR 9.10. It mandates that any multi-line telephone system (MLTS, which includes most business phone systems) must let users dial 9-1-1 directly. The rule applies to systems installed, manufactured, imported or sold after 16 February 2020.

RAY BAUM'S Act (the acronym stands for Repack Airwaves Yielding Better Access for Users of Modern Services Act, named for FCC veteran Ray Baum) followed similar logic. The problem it addressed: 9-1-1 calls from large office buildings reached responders with only the street address, leaving them to find the right floor and room. RAY BAUM'S Act Section 506 requires dispatchable location: street address plus sufficient sub-address detail to locate the caller within the building. Codified at 47 CFR 9.16, effective January 2021 for fixed devices and January 2022 for non-fixed devices.

What "multi-line telephone system" includes

The FCC's definition of multi-line telephone system covers cloud VoIP serving any business with multiple users. Specifically: any system that aggregates extensions behind a common business identity. RingCentral, 8x8, Nextiva, Dialpad, Vonage, Microsoft Teams Phone, Zoom Phone, Ooma Office, OpenPhone, Grasshopper, all qualify as MLTS for the purposes of these rules.

Solo VoIP (one user, one number) is technically not MLTS but the practical compliance posture is the same. The cost of compliance is essentially zero for solo because modern VoIP allows direct 9-1-1 by default and the single business address is the dispatchable location. For multi-user MLTS the compliance work is real but routine.

Old key systems with PBX prefix-dial requirements are the failure mode the laws addressed. Most cloud VoIP installed after 2020 was designed compliant out of the box. Legacy on-premise PBXes are where compliance issues hide.

Kari's Law: the direct-dial test

The Kari's Law compliance test is simple: from any phone connected to your VoIP, can you dial 9-1-1 directly without first dialing 9, 8, 7, or any other prefix? If yes, you are compliant on this point. If no, your system must be reconfigured.

Test method: pick up any phone, dial 9-1-1, then immediately hang up before the call goes through. Verify in the VoIP admin console that the call attempt was logged. If the call attempt was rejected ("user must dial 9 first"), the system is non-compliant and needs immediate reconfiguration.

The rule also requires that the system notify a designated person (typically the office manager) when 9-1-1 is dialed. This notification can be via email, SMS, or a desk-phone screen pop. The notification supports situational awareness so non-emergency staff can prepare to help responders.

RAY BAUM'S Act: dispatchable location configuration

Dispatchable location means the validated street address plus additional information needed to find the caller: floor, suite, room, cube. For a single-floor 5-person office, the street address may be sufficient. For a multi-floor office building or a campus with multiple buildings, sub-address detail is required.

The configuration work in the VoIP admin console: register each office location with full street address, geocoded coordinates and any required sub-address. Map extensions to locations (extension 100 is suite 350, extensions 200-205 are the conference rooms on floor 4). For desk-phone deployments, the MAC-address-to-location mapping is automatic; for softphone deployments on laptops, the location is whatever the user has set most recently.

The complication is mobile workers. A salesperson working from a hotel room is not at the registered office address. Most VoIP vendors handle this by prompting the user at app launch to confirm or update their current address. Some require manual update from the user; some use device GPS to suggest a location. Document the policy your team should follow.

Vendor-specific compliance status

All tier-one VoIP vendors handle Kari's Law and RAY BAUM'S Act compliance through their admin console wizards. The user-facing experience varies but the compliance result is similar.

RingCentral, 8x8, Nextiva and Dialpad all run an E911 setup wizard at account provisioning that captures dispatchable location for each registered device. The wizard prompts for updates if extension locations change. Vonage, Microsoft Teams Phone, Zoom Phone, OpenPhone and Ooma similarly handle the configuration through their admin consoles. Grasshopper is solo-focused and the compliance burden is just the one business address.

Your administrative obligation is to actually run the wizard, validate the addresses entered are correct, and update them when offices move. The FCC enforcement model rests on the assumption that the business has documented its compliance posture. Reference: the FCC 911 compliance overview.

Remote work and the location update challenge

RAY BAUM'S Act non-fixed device rules took effect January 2022 specifically to address remote work. The intent is that a softphone user calling 9-1-1 from a home office reaches responders at the home address, not the registered business address.

Implementation patterns vary. RingCentral and Nextiva prompt at app launch ("you are at: [last known address]. Update?"). Dialpad uses a confirmed home-office geofence and falls back to manual entry off-fence. Microsoft Teams Phone uses the Microsoft 365 Locations admin centre with per-user or per-network location.

For your team the practical guidance is: when working from a non-office location for any extended period, update your VoIP profile's dispatchable location. The 30-second update means that if you call 9-1-1 from that location, responders reach the right place. This is a small but real shift in personal practice that distributed teams should formalise in an onboarding checklist.

Frequently asked questions