Kari's Law: What Business Phone Systems Must Do

Kari's Law requires business phone systems with multiple lines to let anyone dial 911 directly, without a prefix such as 9, and to notify someone at the business (like a front desk or administrator) when a 911 call is made. It applies to multi-line telephone systems manufactured, sold, leased or installed after February 16, 2020, and covers the companies that make, sell, install, manage and operate them.

If your business uses a phone system with more than one user, it almost certainly applies to you.

Why the law exists

The FCC's page on multi-line telephone system 911 rules tells the story. Kari Hunt was killed by her estranged husband in a motel room in Marshall, Texas in 2013. Her 9-year-old daughter tried four times to call 911 from the room phone, but the call never went through, because the motel's system required dialing 9 first for an outside line. Congress passed Kari's Law in 2018, and the FCC adopted rules implementing it, along with Section 506 of RAY BAUM'S Act, in August 2019.

What a multi-line telephone system is

An MLTS is a phone system with multiple lines or stations, typical of offices, campuses, hotels and other enterprises. That includes on-premises PBX systems and cloud-hosted business phone systems where several users share a system. A single-line home phone is not an MLTS; a five-person office on a cloud phone platform generally is.

The two core requirements

1. Direct dialing

Under 47 CFR § 9.16, MLTS must be configured so that a user can call 911 "without dialing any additional digit, code, prefix, or post-fix, including any trunk-access code such as the digit 9." Systems can still require 9 for other calls. Dialing 911 must work by itself.

2. On-site notification

MLTS must be configured to notify a central location, at the facility or elsewhere, when someone dials 911, if the system can do this without hardware or software upgrades. The FCC says the notification must:

• Be initiated at the same time as the 911 call, when technically feasible
• Not delay the 911 call
• Go somewhere someone is likely to see or hear it

At minimum, the notification includes the fact that 911 was called, a valid callback number, and the location information sent to the 911 center (unless technically infeasible).

The purpose is practical. Someone at the business can meet responders at the door, unlock a gate, or direct them to the right floor.

Who is responsible

Kari's Law spreads responsibility across the chain.

Role	Obligation
Manufacturers, importers, sellers, lessors	Sell systems pre-configured for direct 911 dialing
Installers	Install systems configured for direct dialing
Managers and operators	Operate systems that support direct dialing and configure notification

For a business using a cloud phone service, the provider usually handles the system configuration, and the business typically controls who receives notifications. Both sides should make sure it is set up.

Compliance dates

According to the FCC:

Date	What took effect
February 16, 2020	Kari's Law effective; covers systems manufactured, imported, offered, sold, leased or installed after this date
February 17, 2020	FCC compliance date for direct dialing and notification
January 6, 2021	Dispatchable location from on-premises fixed devices (RAY BAUM'S Act rules)
January 6, 2022	Dispatchable location or alternatives from non-fixed and off-premises devices

The location rules are covered in RAY BAUM'S Act dispatchable location.

Legacy systems

The rules do not reach systems manufactured, imported, offered, sold, leased or installed on or before February 16, 2020. But "legacy" status ends when you replace the system or install a new one. If your office still runs an older PBX that requires 9 for 911, you are not violating Kari's Law, but you are carrying the exact risk the law was written to remove. Updating the dial plan is often a simple change.

How to check your system

Do not test by dialing 911. Instead:

1. Ask your provider or installer to confirm in writing that 911 can be dialed directly from every station, with and without any outside-line prefix.
2. Review the dial plan for anything that intercepts "911" or requires a prefix.
3. Confirm who receives 911 notifications and how (email, text, on-screen alert).
4. Check that notifications include the callback number and location.
5. Confirm notifications go to someone present during all hours staff are on site.

Notification setup tips

• Use more than one channel, such as email and text.
• Send to a role that is always staffed, not one person who may be on vacation.
• Include the person who manages building access, if different.
• After hours, route notifications to whoever is on call.
• Review the list when staff change.

Common gaps in small offices

Small businesses rarely ignore 911 on purpose. The gaps tend to be quieter:

• The notification goes to the owner's personal email, which nobody else sees, and the owner is not on site.
• Desk phones from an old system are still plugged in somewhere, such as a break room or warehouse, with the old dial plan.
• A receptionist console has a speed dial labeled "911" that actually dials an internal extension.
• Softphones on laptops are used away from the office while the registered address still points at the office.
• New hires are never told that calling 911 from the business phone alerts the front desk, so they also call the front desk and lose time.

Walk the office once a year with this list. It takes ten minutes.

Compliance checklist

• 911 dials directly from every phone and softphone
• No prefix required for 911
• Notifications configured to a staffed point
• Notifications include callback number and location
• Notifications do not delay the 911 call
• Dispatchable location registered for each location
• Staff told how 911 works on your system

For how VoIP 911 works more broadly, including when it can fail, read E911 for VoIP business phones.

Enforcement

The FCC says it monitors complaints about violations of these 911 rules. Consumers can file through the FCC Consumer Complaint Center, and 911 centers can raise issues through the FCC's Public Safety Support Center. Beyond regulatory risk, the real cost of non-compliance is a delayed emergency response at your workplace.

Kari's Law and Callata

On Callata you dial 911 directly, with no prefix. When anyone on your account dials 911, Callata emails the account owner and can also text a number you choose, so someone at your business knows help was called; Callata's 911 disclosure cites Kari's Law for this. Each account registers a dispatchable address including suite or floor, which is sent to the dispatcher with your business number. Set the address in Admin under Numbers & 911. Callata is $99 a month for up to five users, plus $20 for each additional user, with E911 on every number. Sign up.