Resources · E911 and MLTS compliance
They are usually discussed together and satisfied separately. Most organizations that believe they are compliant have met the first and not the second.
Both statutes govern multi-line telephone systems, both are enforced through the same FCC rules, and both are typically raised in the same conversation. That makes it easy to treat them as one requirement with one fix.
They are not. One is about how a call is dialled and who is told. The other is about what the answering point learns about where the caller is. A system can do the first perfectly and fail the second completely, and that combination is common enough to be the default finding in a first assessment.
What each requires
| Kari's Law | RAY BAUM'S Act §506 | |
|---|---|---|
| Core requirement | Direct 911 dialling with no prefix or access code, plus notification to a central on-site location when a 911 call is placed | Dispatchable location delivered with every 911 call — a validated street address plus floor or suite detail |
| What it protects against | A caller who cannot reach 911 at all, or reaches it unnoticed on site | A caller who reaches 911 but cannot be found once responders arrive at the building |
| Nature of the obligation | Largely a configuration state — set correctly, it stays correct | A maintained state — it degrades as devices and departments move |
| Where it is codified | FCC MLTS rules applying to system managers, operators and installers | Phased in by device type under 47 CFR §9.16 |
| Typical failure | A legacy system that still requires a 9 to reach an outside line | A correct street address with no floor detail across a multi-storey building |
Direct dialling is a setting. Once a system is configured to route 911 without a prefix, it keeps doing that until someone deliberately changes it. Notification behaves the same way.
Dispatchable location is different in kind. It depends on a mapping between devices and physical places, and that mapping is invalidated by ordinary operational activity — a department relocating a floor, a batch of desk phones redeployed, a wing reconfigured. Nothing in the phone system flags that the location data is now wrong.
For mobile and soft-client devices the obligation is stated with an explicit feasibility test: automated dispatchable location where technically feasible, and an alternate location method where it is not. That distinction matters because a Teams or softphone estate is not exempt simply because the device moves.
Four checks separate a Kari's Law problem from a RAY BAUM'S Act problem without needing an assessment first.
The second and fourth questions are the ones that tend to go unanswered, and both point at governance rather than configuration. That is the practical difference between treating compliance as a project and treating it as a maintained state.
The obligation follows the organization managing, operating or installing the multi-line telephone system. In practice that means the exposure sits with the organization running the estate, not the integrator who configured it — which is why “our vendor handled that” is not a compliance position.
It is also why this tends to be a corporate rather than a site-level question in any multi-property estate. One decision-maker holds it, even where the configuration decisions were made building by building.
Related
Full lifecycle — assessment, deployment, PSAP testing and annual governance across every site.
ResourcesThe FCC's decision logic, reproduced without interpretation, with what each outcome obliges you to do.
ResourcesWhy dispatchable location degrades through moves, adds and changes, and the cycle that prevents it.
The free multi-site assessment reviews your position across every site under both statutes. If you are compliant, you will be told so.