FCC Sounds the Alarm on Broken 9-1-1 Compliance

Two federal laws stand as critical pillars for upholding safety and emergency response efficiency in the workplace: Kari's Law and RAY BAUM'S Act. Collectively, these mandate that organizations provide direct 9-1-1 dialing and accurate caller location data to emergency responders, ensuring that help can reach those in need without delay or confusion.

Though these requirements have been in effect since 2020, compliance remains alarmingly low. Only 63.8% of organizations are able to comply with both laws, with no material growth compared to 2023's 62.7% compliance rate. In response to this persistent gap, the FCC has launched a renewed initiative to drive compliance. As Next Generation 911 (NG911) coverage expands and emergency response systems evolve, it is critical for organizations and public safety leaders to stay compliant to help avoid delayed response times and added safety risks.

NG911 transition and workplace safety

NG911 is an IP-based emergency services network that enhances 9-1-1 systems with advanced capabilities such as improved location accuracy, call routing and multimedia communications. NG911 enablement requires both communications providers and system owners, on the one hand, and public safety agencies on the other, to migrate from legacy networks to IP-based systems that can handle modern data types and provide more precise information to 9-1-1 telecommunicators at Emergency Call Centers (ECCs). This transition creates both opportunities and challenges for system owners seeking to achieve and maintain compliance while preparing for next-generation capabilities.

For system owners, NG911 offers substantial safety benefits. Enhanced location accuracy ensures that workers, guests and customers receive faster, more accurate emergency response. Next-gen capabilities improve emergency response coordination and provide first responders with better building navigation information. Plus, NG911 supports integration with incident management and physical security systems, creating a more comprehensive safety ecosystem within organizations.

Compliance requirements and noncompliance risks

The Kari's Law regulations became effective on February 17, 2020, and establishes three fundamental requirements for multi-line telephone systems (MLTSs). Organizations must enable direct dialing to 9-1-1 without requiring users to first dial a prefix such as "8" or "9" to reach an outside line. The law also mandates notification to designated personnel, such as security teams, when a 9-1-1 call is made. Finally, systems must provide a valid callback number so 9-1-1 telecommunicators can reconnect if calls are disconnected.

RAY BAUM'S Act focuses on location accuracy, requiring that MLTSs transmit "dispatchable location" information to ECCs — also called Public Safety Answering Points (PSAPs). Dispatchable location is defined as a validated street address plus additional identifying information such as suite, apartment, or room details necessary to identify the caller's precise location. The regulations took effect January 6, 2021, for fixed devices like desktop phones, and January 6, 2022, for mobile and off-premises devices.

The FCC's renewed initiative includes comprehensive documentation clarifying that these laws apply to manufacturers, vendors, installers, managers and all operators of MLTSs. Recent FAQ and guidance documents emphasize that compliance responsibility extends beyond the communications service provider to the organizations and individuals responsible for maintaining and operating these systems.

While implementation details vary by organization, the FCC’s guidance makes clear that responsibility for compliance cannot be fully outsourced and ultimately rests with the organizations that operate and manage these systems.

Kari’s Law violations carry initial fines of up to $10,000 plus additional penalties of up to $500 per day for continued non-compliance. RAY BAUM’S Act violations fall under general FCC enforcement authority, with potential for specific compliance conditions and ongoing reporting requirements.

In addition to the risk of regulatory enforcement, non-compliance creates safety hazards by failing to meet Duty of Care standards to protect workers and guests. Delayed emergency response due to location inaccuracy or access issues can result in preventable workplace safety incidents and injuries. Employees have the right to a safe workplace and can refuse to work in situations where they would be exposed to hazards.

Organizations also risk significant reputational damage from emergency response failures, including negative publicity, civil lawsuits and liability. These incidents can result in long-term loss of confidence and damage to organizational credibility.

Overcoming compliance challenges

A significant misconception persists that systems installed before the federal regulations became effective are “grandfathered.” The reality is more complex. Upgrades to "core MLTS software or hardware functions" can trigger updated compliance requirements, and some states have enacted laws that may be stricter than the FCC’s regulations.

Organizations with onsite emergency response capabilities, such as universities and secure facilities, receive specific guidance under the FCC’s MLTS FAQ. While Kari's Law doesn't require changes to existing procedures, coordination with state and local 9-1-1 authorities is recommended to ensure seamless emergency response.

Fixed devices must provide automated dispatchable location information. Non-fixed devices like wireless office phones must also provide automated location if technically feasible; otherwise, systems must allow manual location input or provide alternative coordinate-based information. Remote workers present particular challenges in this regard, requiring enhanced location information that may include latitude, longitude and vertical location data. Multi-story buildings also require specific floors and room information beyond simple street addresses.

Organizations can achieve compliance through a systematic approach beginning with assessment of their current MLTS environment and capabilities, including evaluation of all endpoints from fixed telephones to mobile and remote workers. Consider consulting legal counsel to help determine specific compliance requirements for your organization's unique situation.

Organizations using third-party cloud calling providers should request and review how those providers meet FCC location accuracy requirements, including how dispatchable location information is maintained for remote and hybrid employees.

Separately, organizations using SIP trunking services should ensure they understand how location information is generated, managed and transmitted with 9-1-1 calls.

Configuration auditing verifies that systems transmit dispatchable location information accurately and utilize provider capabilities for location tracking as endpoints change. Mobile device 9-1-1 call tracking solutions also address the growing challenge of business calls made from personal and company devices. Finally, ongoing testing and maintenance planning ensures continued compliance as systems and personnel locations evolve.

Leveraging third-party platforms to ensure compliance

Third-party 9-1-1 management platforms offer significant advantages for achieving and maintaining compliance across complex, multi-platform environments. These solutions provide real-time location tracking for both office and remote workers, reducing operational complexity while decreasing management costs. Integration capabilities with existing MLTS platforms and cloud services, including solutions like Microsoft Dynamic Emergency Calling, create seamless compliance frameworks.

Key capabilities include automated location tracking across all deployed calling platforms, proper routing of 9-1-1 calls to appropriate PSAPs based on actual user location, and central answering points for calls from unknown locations. These platforms ensure notification of appropriate personnel when 9-1-1 calls are placed and support NG911 features such as text and multimedia data transmission to emergency call centers.

Despite these advantages, current adoption remains low, with only 18.1% of organizations leveraging third-party platforms for location management. However, integration with incident response systems shows promise, with 36% of companies having adopted incident management response platforms and another 34.3% planning implementation. Among adopters, 92.9% plan to integrate these systems with 9-1-1 call management to enable automatic activation of emergency response plans.

Avoid risk by achieving compliance now 

Compliance with Kari's Law and RAY BAUM'S Act represents more than regulatory obligation. It signifies a commitment to fundamental workplace safety, civic and legal responsibilities that organizations cannot afford to ignore. The FCC's clarified guidance removes previous compliance confusion, providing clear pathways for organizations to meet their obligations while connecting to broader emergency preparedness and risk management strategies.

Proactive compliance not only avoids enforcement actions but also prepares organizations for the NG911 transition by establishing robust standards today that will support tomorrow's advanced emergency response capabilities. Organizations that delay compliance face mounting safety, legal and reputational risks in an environment where emergency preparedness has never been more critical.