E911, Kari's Law, and Ray Baum for VoIP Resellers

Kari's Law and Ray Baum's Act have been in force for years, but 2025 saw the FCC start issuing meaningful penalties. Any VoIP provider still treating E911 as a checkbox needs to close the gap before an incident, not after. The regulations exist because a real person died unable to reach 911 from a hotel phone, and enforcement has caught up with that history.

Kari's Law requires that any multi line telephone system allow direct dialing of 911 without a prefix. In practice this means your default dial plan cannot force users to dial nine or any other digit before 911. Test this on every customer install and document it. A customer who has to dial nine one one one is not compliant, and neither are you.

Kari's Law also requires notification. When someone dials 911 from the customer system, a designated contact at the customer, typically front desk, security, or a manager, must be notified in real time. This can be an email, a text, a screen pop, or a call to a central number. It cannot be a report the next day. The whole point is that someone at the location can go find the person who needed help.

Ray Baum's Act requires that a dispatchable location be delivered to the 911 call taker. Street address alone is not enough for anything larger than a single office. Suite numbers, floor numbers, and building identifiers all need to reach the public safety answering point. For a multi story customer, floor level location matters. For campus environments, building identifiers matter.

The hard case is remote workers. When a softphone user in Denver dials 911 from a laptop, the call cannot be delivered to a Chicago dispatcher just because the DID is a Chicago number. Your platform must prompt the user to confirm their current location, or use a device level solution that updates dynamically based on network location. Every serious UCaaS platform now supports this, but the configuration is up to you.

Practical implementation. Require every new user to set a home dispatchable location during onboarding. Prompt for a location confirmation every time the softphone starts from a new network. For hoteling desks, use station discovery based on the LAN or the desk phone MAC address. Do not ship a softphone that has no location and hope the user figures it out.

Document the customer notification path. Who gets notified when 911 is dialed, how, and what is the escalation if that person does not respond. Put it in the customer welcome kit and revisit it at every quarterly business review. Personnel changes at the customer are the most common source of compliance drift, and only you will catch them if you look.

Train your support team on what compliance looks like. Half of the real world violations happen because a support tech disabled a feature to solve an unrelated ticket. If your team does not understand which settings are compliance critical, they will eventually turn one off. Tag compliance settings in your provisioning platform so a warning appears before anyone changes them.

None of this is optional and none of it is expensive to do correctly from day one. The cost of doing it wrong is measured in FCC forfeitures and, in the worst case, a customer employee who did not get help when they needed it. Treat compliance as a product feature, price it into your service, and never apologize for prioritizing it.