Resources · E911 and MLTS compliance
Most organizations assume the answer is no because the phone system predates the rules. The exemption is narrower than that, and the decision logic is short enough to work through in a few minutes.
Two things make this harder than it should be. The first is that the obligation follows the organization operating the phone system rather than the vendor who installed it — so the party carrying the exposure is frequently not the party who made the technical decisions.
The second is that the date test is not simply about when the system was bought. A system installed before the cutoff can still be brought into scope by a later upgrade, which is how organizations that believe they are exempt discover otherwise.
What follows is the FCC's own decision logic, reproduced without interpretation. Work through it in order.
The decision logic
Are you the manager, operator, or installer of a multi-line telephone system (MLTS)?
FCC MLTS rules do not apply.*
Continue to next question ↓
Was it installed after 2/16/2020?
Skip to "Rules apply" below ↓
Continue to next question ↓
The MLTS may be exempt as a legacy system. Has there been an upgrade to its hardware or software since 2/16/2020?
Continue to "Rules apply" below ↓
FCC MLTS rules do not apply to legacy MLTS; check state law.
Rules apply
* Certain rules still apply to MLTS manufacturers, importers, sellers, and lessors.
** Notification obligations may not apply in all circumstances — see FCC MLTS rules.
Three obligations attach. They are separate requirements and meeting one does not satisfy another.
The first two are configuration questions with binary answers. The third is the one that causes trouble, because dispatchable location is a validated street address plus floor or suite detail under RAY BAUM'S Act §506, phased in by device type under 47 CFR §9.16 — and it is a maintained state rather than a setting.
Two caveats are worth holding onto. Where the federal MLTS rules do not reach a legacy system, certain rules still apply to manufacturers, importers, sellers and lessors — so the supply chain around your system may carry obligations even where your deployment does not.
And state law may apply regardless. A federal exemption is not a general one, which is why the honest answer to “are we exempt?” usually requires checking the state as well as the statute.
Before commissioning anything, these four usually establish whether you have a documentation problem, a configuration problem or a governance problem.
If the answer to the third question is a street address with no floor detail, the system is probably meeting Kari's Law and failing RAY BAUM'S Act. That is the most common position we find, and it is not obvious from a configuration screen.
Related
Full lifecycle — assessment, deployment, PSAP testing and annual governance. The multi-site gap assessment is free.
ResourcesWhat each statute requires, how they differ, and why dispatchable location is the one most organizations fail.
ResourcesCompliance degrades through moves, adds and changes. This is the governance cycle that prevents it.
The free multi-site assessment reviews your position across every site under both statutes. There is no scoped project attached — if you are compliant, you will be told so.