Configuration · guide

Meeting Kari's Law and RAY BAUM's Act on an enterprise phone system

Enterprise MLTS

Verified 2026-09-24 · 76 sources · tier 1–2

For Voice administrators configuring enterprise calling platforms to meet US federal 911 requirements.

Enterprise multi-line telephone systems (MLTS) must enable direct 911 dialing without a prefix, deliver contemporaneous on-site notifications, and transmit a dispatchable location to the public safety answering point (PSAP) 193023. This guide details the technical configuration and verification steps required across enterprise platforms to achieve compliance 1927.

Before you start

Review applicable regulatory mandates and inventory all system components:

The Federal Communications Commission (FCC) rules define an MLTS to include network-based and premises-based setups such as VoIP, Centrex, PBX, and key telephone systems 25.
WarmTransfer's reading of the sources is that cloud calling services such as Webex Calling and Microsoft Teams Phone used by enterprises represent an MLTS subject to these rules 17.
Kari's Law applies to MLTS manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020 24.
An MLTS is defined as configured when installation settings make it fully capable of direct 911 dialing and providing MLTS notification 18.
The FCC assigns MLTS liability by conduct across installers, managers, and operators, noting that a passive owner generally avoids liability when contracting with a responsible third party and including compliance obligations 33.
Automated dispatchable locations were required for fixed on-premises MLTS devices by January 6, 2021 22. Non-fixed on-premises and off-premises devices were set a deadline of 2022-01-06 under 47 CFR 9.16(b)(3), with alternative location information allowed where automated dispatchable location is not technically feasible 62. Alternative location information must provide civic address and approximate in-building location, including floor level in large buildings 1.
Dispatchable location constitutes the validated street address plus additional details such as suite or apartment needed to identify the caller's location 20. On-premises is defined as the fixed property under the operational control of a single administrative authority 32.

What changes by situation

Pick your answers to see only your path. Nothing is sent anywhere until you make a plan.

Which calling platform places your users' 911 calls?

Do users place calls from off-premises devices?

Two questions. One permanent page you can send to your manager.

Step 1 Establish regulatory obligations and administrative ownership

Do

Document every calling platform, station, and user tier against the three statutory requirements: direct 911 dialing without prefixes 19, on-site notification 29, and dispatchable location conveyance 23. Record the manufacture, lease, purchase, or deployment date for each system to determine Kari's Law applicability 24. Identify the operating party, manager, or third-party contractual entity responsible for configuration 33.

Verify

Confirm each platform inventory record identifies an assigned operating owner and explicitly documents handling for prefixless dialing, contemporaneous alerting, and dispatchable location delivery 3323.

Rollback

Suggested rollback: Update or archive the platform inventory records to reflect baseline operational responsibility.

Step 2 Configure validated civic addresses and in-building emergency locations

Cisco Unified CM with Cisco Emergency Responder

Do

In Cisco Emergency Responder, create Emergency Response Locations (ERLs) defining areas where calls originate, and assign each ERL an Emergency Location Identification Number (ELIN) that routes to the local PSAP and supports callback 6. Populate Automatic Location Identification (ALI) details, export the ALI records, and submit them to the service provider 4. When integrating with Intrado over the Validation and Update Interface (VUI), validate civic addresses against Intrado Master Street Address Guide (MSAG) data 63.

Verify

Verify that every ERL has an assigned ELIN and valid ALI record, and confirm the service provider has validated and accepted the submitted ALI dataset 4.

Rollback

Delete or update the affected ERL in Cisco Emergency Responder and resubmit updated ALI data to the provider 4.

Webex Calling with native enhanced emergency calling

Do

Log in to the RedSky administration portal and create buildings and granular sub-locations with validated civic addresses 61. Enhanced emergency calling using RedSky is included with Webex Calling entitlements for US users 58.

Verify

Verify that all Webex Calling locations display corresponding building entries and validated civic addresses inside the RedSky portal 61.

Rollback

Suggested rollback: Remove or edit invalid civic addresses and building entries in the RedSky portal.

Microsoft Teams Phone with Calling Plans, Operator Connect, or Teams Phone Mobile

Do

In the Microsoft Teams admin center, create emergency addresses using map search to validate each address and populate geo codes 38. Re-create any emergency addresses older than a couple of years 38.

Verify

Verify in the Teams admin center that each configured emergency address displays a validated status and contains a geo code 38.

Rollback

Suggested rollback: Delete newly created emergency places or unvalidated emergency addresses in Teams admin center.

Microsoft Teams Phone with Direct Routing

Do

In the Microsoft Teams admin center or via PowerShell, configure validated emergency addresses containing geo codes 38. Address records older than a couple of years cannot be bound to network identifiers and must be re-created 38.

Verify

Confirm that every emergency address used for Direct Routing shows as validated with an assigned geo code 38.

Rollback

Suggested rollback: Remove unassigned or invalid emergency addresses and places from Teams admin center.

Step 3 Map network identifiers for dynamic location resolution

Cisco Unified CM with Cisco Emergency Responder

Do

Add access switches to Cisco Emergency Responder using SNMPv2 or SNMPv3 to enable switch-port tracking 14. Assign switch ports, wireless access points, and IP subnets to ERLs 7. Note that Emergency Responder resolves device location using this precedence order: synthetic phones, switch port, access point, IP subnet, remote server group, manual line assignment, unlocated phones, then default ERL 7.

Verify

Confirm that fixed phones resolve to specific ERLs via switch port tracking and wireless devices resolve via access point or IP subnet rather than falling back to unlocated status or the default ERL 7.

Rollback

Remove switch definitions or clear specific port, AP, and subnet mappings in Cisco Emergency Responder 7.

Webex Calling with native enhanced emergency calling

Do

In the RedSky portal, construct the network wiremap by entering wireless BSSIDs, switch chassis MAC addresses discovered via LLDP, switch ports, and IP subnets for each building 61. HELD-capable endpoints (such as Cisco MPP phones, Room/Desk/Board units, and Webex App) obtain location via dynamic network discovery, whereas non-HELD devices (such as Poly and Yealink phones) utilize a static location tied to their caller ID 53.

Verify

Confirm network elements are correctly mapped in the RedSky wiremap and verify that non-HELD phones have static locations tied to their caller ID 6153.

Rollback

Suggested rollback: Remove or update incorrect wiremap subnets, BSSIDs, or switch port entries in the RedSky portal.

Microsoft Teams Phone with Calling Plans, Operator Connect, or Teams Phone Mobile

Do

Configure public egress IP addresses as trusted IP addresses in the Teams admin center 47. Populate the Location Information Service (LIS) by associating emergency locations with IP subnets, wireless access points, Ethernet switches, and switch ports 40. LIS matches client location using this precedence: wireless access point, switch/port, switch, and subnet 39. Assign an emergency calling policy with Web PSTN calling disabled to users on the Teams web client, as it does not support dynamic emergency calling 48.

Verify

Wait up to 4 hours for network settings to propagate to Teams clients 43. Suggested check: inspect client debug logs or place dynamic test calls across subnets to confirm network element resolution.

Rollback

Remove network identifiers or trusted IP addresses from the Teams admin center or PowerShell 40.

Microsoft Teams Phone with Direct Routing

Do

Define trusted IP addresses for external corporate gateways 47. Map IP subnets, wireless access points, switches, and ports to emergency locations in the LIS 40. The LIS resolves matches in order: wireless access point, switch and port, switch, then subnet 39. Ensure users of the Teams web client are prevented from dynamic dialing or have web PSTN calling disabled 48.

Verify

Allow up to 4 hours for LIS updates to propagate 43. Suggested check: verify across network boundaries that clients acquire expected LIS policies.

Rollback

Delete updated subnets, switches, ports, or trusted IP addresses from the LIS configuration 40.

Step 4 Configure prefixless 911 dialing and emergency call routing

Cisco Unified CM with Cisco Emergency Responder

Do

In Cisco Unified Communications Manager, create a 911 CTI route point in the E911 partition so Emergency Responder intercepts emergency calls 2. Build calling search space E911CSS, placing the E911 partition before the internal phones partition 5. Create translation patterns in the phones partition for 911 and 9.911 (discarding PreDot) pointing to E911CSS, ensuring users can dial 911 directly without a prefix 192116.

Verify

From a test phone in each calling search space, confirm dialing 911 reaches the CTI route point immediately without secondary dialtone 16.

Rollback

Do not remove emergency routing unless an alternate emergency pattern is active 19. Suggested rollback: revert translation pattern modifications in the call control platform.

Webex Calling with native enhanced emergency calling

Do

In Webex Control Hub, enable Enhanced Emergency Calling for the location, authorize RedSky to receive network discovery data and test calls, complete 933 test verification, and then toggle Route Emergency Calls to RedSky 52. Systems must allow direct dialing of 911 without prefix digits or trunk-access codes 19.

Verify

Verify that the emergency routing status for the location in Control Hub displays "Routing On" 52.

Rollback

In Control Hub, turn off Route Emergency Calls to RedSky for the location 52.

Microsoft Teams Phone with Calling Plans, Operator Connect, or Teams Phone Mobile

Do

Ensure that the usage location is populated on every user account assigned a Microsoft Calling Plan, Operator Connect, or Teams Phone Mobile license to enable automatic routing to emergency services 44. Confirm that users can initiate 911 calls directly without prefixes or trunk-access digits 19.

Verify

Verify that the Teams user account has a defined usage location in the admin center 44.

Rollback

Suggested rollback: Revert user usage location assignments in Teams admin center.

Microsoft Teams Phone with Direct Routing

Do

Set PidfloSupported to true on the Direct Routing Session Border Controller (SBC) using PowerShell, ensuring emergency INVITEs convey PIDF-LO location metadata 3664. Connect the SBC to an Emergency Routing Service (ERS) provider or configure an SBC-based ELIN application 36. In the Teams admin center, create an emergency call routing policy containing dial string 911 (and any supplemental masks, matching 911 rather than +911), configure the PSTN route to the emergency SBC, and assign the policy to users or network sites 4465.

Verify

Run Get-CsOnlinePSTNGateway and verify that PidfloSupported returns True 36.

Rollback

Do not disable 911 routing without maintaining an alternate emergency path 19. Revert the emergency call routing policy assignment or set PidfloSupported to false on the gateway 3644.

Step 5 Implement off-premises and nomadic location handling

Yes: remote or nomadic users place calls off premises + Cisco Unified CM with Cisco Emergency Responder

Do

Integrate Cisco Emergency Responder with an approved national E911 provider such as RedSky or Intrado 8. Create off-premises ERLs and associate them with remote IP subnets and unlocated phones 9. Configure remote users to enter and validate their physical address on the Off-Premises User page or via Cisco Jabber or Webex using MyE911 1066.

Verify

In Cisco Emergency Responder, verify that registered remote phones reflect an Off-premises status rather than unlocated 12.

Rollback

Remove off-premises ERL bindings in Cisco Emergency Responder 9.

No: all calling devices remain strictly on premises + Cisco Unified CM with Cisco Emergency Responder

Do

Document policy restrictions showing that calling endpoints cannot leave premises and softphones are disallowed off-network 32.

Verify

Suggested check: review configuration audits confirming no remote endpoints register off-premises.

Rollback

Suggested rollback: Update the system applicability records if off-premises endpoints are later permitted.

Yes: remote or nomadic users place calls off premises + Webex Calling with native enhanced emergency calling

Do

Enable nomadic E911 so Webex App users on untracked off-premises networks are prompted to enter and confirm a dispatchable civic address 54. Instruct users that Webex App ignores VPN interfaces during emergency location discovery 60. Inform organizational leadership that emergency calls lacking valid location resolution are routed to an emergency relay call center and billed to the customer 59.

Verify

Place a test user on an off-network connection, open Webex App, enter a civic address when prompted, and dial 933 to confirm the IVR reads back the entered location 5450.

Rollback

Suggested rollback: Have the user update or clear the saved nomadic address within the Webex App settings.

No: all calling devices remain strictly on premises + Webex Calling with native enhanced emergency calling

Do

Document policy restrictions showing that calling endpoints cannot leave premises and softphones are disallowed off-network 32.

Verify

Suggested check: review configuration audits confirming no remote endpoints register off-premises.

Rollback

Suggested rollback: Update the system applicability records if off-premises endpoints are later permitted.

Yes: remote or nomadic users place calls off premises + Microsoft Teams Phone with Calling Plans, Operator Connect, or Teams Phone Mobile

Do

Enable External location lookup mode in the Teams emergency calling policy to allow remote users on Windows and macOS desktop clients to configure emergency addresses 3749. Note that Teams mobile supports automatic detection only, while Teams desk phones do not support remote manual entry 49. Note that manually entered, unconfirmed, or static addresses are routed to a screening center before PSAP transfer 45.

Verify

On a remote desktop client, confirm that Teams prompts the user to enter or confirm an address, then place a 933 test call to confirm whether the bot indicates the call routes directly or is screened 34.

Rollback

Set External location lookup mode to disabled in the Teams emergency calling policy 37.

No: all calling devices remain strictly on premises + Microsoft Teams Phone with Calling Plans, Operator Connect, or Teams Phone Mobile

Do

Document policy restrictions showing that calling endpoints cannot leave premises and softphones are disallowed off-network 32.

Verify

Suggested check: review configuration audits confirming no remote endpoints register off-premises.

Rollback

Suggested rollback: Update the system applicability records if off-premises endpoints are later permitted.

Yes: remote or nomadic users place calls off premises + Microsoft Teams Phone with Direct Routing

Do

Enable External location lookup mode in the emergency calling policy for remote users on Teams desktop clients 3749. Verify that your Emergency Routing Service provider supports screened call delivery for unconfirmed or manual addresses 4567.

Verify

Suggested check: Dial your emergency routing provider's designated test service from an off-premises desktop client to verify location reporting and screening behavior.

Rollback

Disable External location lookup mode in the custom emergency calling policy 37.

No: all calling devices remain strictly on premises + Microsoft Teams Phone with Direct Routing

Do

Document policy restrictions showing that calling endpoints cannot leave premises and softphones are disallowed off-network 32.

Verify

Suggested check: review configuration audits confirming no remote endpoints register off-premises.

Rollback

Suggested rollback: Update the system applicability records if off-premises endpoints are later permitted.

Step 6 Configure contemporaneous on-site emergency notifications

Cisco Unified CM with Cisco Emergency Responder

Do

In Cisco Emergency Responder, configure on-site security personnel definitions for each ERL, selecting delivery via phone call, web alert, email, or text alert 11. Alerts must initiate contemporaneously with the 911 call without introducing call delay 30.

Verify

Trigger a test notification and verify that the alert contains the calling extension, caller display name, ERL, and call timestamp 3.

Rollback

Suggested rollback: Remove or reassign on-site security personnel contacts associated with the ERL in the emergency management application.

Webex Calling with native enhanced emergency calling

Do

In Webex Control Hub, toggle on emergency call notifications at the organization level or per location, specifying recipient email addresses 55. In the RedSky portal, configure notification distribution to designated email and SMS recipients 57.

Verify

Verify that a generated Webex email alert contains the call timestamp, dialed digits, user name, extension, user phone number, and location name and main address 56. Confirm the RedSky notification reaches the configured email and SMS recipients 57.

Rollback

Toggle off emergency call notifications in Control Hub or remove configured email recipients 55.

Microsoft Teams Phone with Calling Plans, Operator Connect, or Teams Phone Mobile

Do

In the Teams emergency calling policy, configure notification settings for an emergency number by selecting notification only, conferenced in muted, or conferenced in unmuted 42. Specify the users or distribution groups to receive the Teams alert chat, and optionally define a PSTN dial-out number for conferenced modes 42. Assign the policy to network sites, noting site-level assignments override user-level policies 46.

Verify

Confirm in Teams admin center that the targeted network site reflects the assigned emergency calling policy with configured notification recipients 4642.

Rollback

Revert the notification mode or remove designated chat users from the emergency calling policy in Teams admin center 42.

Microsoft Teams Phone with Direct Routing

Do

In the Teams emergency calling policy, configure notification for an emergency number to send notification only, conference in muted, or conference in unmuted, assigning notification recipients via Teams chat or PSTN bridge numbers 42. Assign the policy directly to network sites to ensure site-level precedence 46.

Verify

Inspect the emergency calling policy applied to the network site to confirm notification recipients are designated 4642.

Rollback

Update the custom emergency calling policy to disable notifications or remove chat recipients 42.

Step 7 Configure PSAP callback numbers

Cisco Unified CM with Cisco Emergency Responder

Do

In Cisco Unified Communications Manager, create a PSAP callback CTI route point (such as 913XXXXXXXXXX) in the E911 partition, configuring digit manipulation to strip 913 and route callbacks matching the ELIN directly to the emergency caller 13.

Verify

Place an inbound test call to the assigned ELIN from an external trunk and verify that Cisco Emergency Responder redirects the call to the extension that placed the most recent emergency call 13.

Rollback

Suggested rollback: Modify or remove the PSAP callback CTI route point in the call control system.

Webex Calling with native enhanced emergency calling

Do

In Webex Control Hub, configure the Emergency Callback Number (ECBN) for each user to their direct phone number, or configure the location's default ECBN or another assigned number within that location 51.

Verify

Place a 933 test call from a provisioned phone and verify that the IVR announces the caller ID and currently known address 50.

Rollback

Modify the ECBN setting in Control Hub back to the location default 51.

Microsoft Teams Phone with Calling Plans, Operator Connect, or Teams Phone Mobile

Do

Assign a valid Direct Inward Dial (DID) phone number to every Teams Phone user and common-area phone to serve as a callable emergency callback number 34.

Verify

Place a 933 test call and confirm that the automated bot announces the caller's assigned telephone number 34.

Rollback

Suggested rollback: Reassign or clear the user phone number assignment in the Teams admin center.

Microsoft Teams Phone with Direct Routing

Do

Configure callback routing on the SBC or within the Emergency Routing Service provider profile to route return calls on the ELIN back to the originating station 3668.

Verify

Suggested check: Verify callback routing through the ERSP test portal or test numbers.

Rollback

Suggested rollback: Revert ELIN mapping configurations on the SBC or ERSP administration portal.

Step 8 Validate emergency calling and location data without dialing 911

Cisco Unified CM with Cisco Emergency Responder

Do

Configure test ERLs and synthetic phones in Cisco Emergency Responder to validate location mapping without triggering live calls to the PSAP 15.

Verify

Verify that the synthetic test phone resolves to the designated test ERL and that on-site security alerts trigger with expected extension and location metadata 153.

Rollback

Delete synthetic test phones and temporary test ERL configurations in Cisco Emergency Responder 15.

Webex Calling with native enhanced emergency calling

Do

Place test calls to 933 from each device type (including MPP desk phones, Webex App desktop, and room endpoints) across all local network subnets 52.

Verify

Confirm that the 933 IVR announces the caller ID and currently known address 50.

Rollback

Suggested rollback: No rollback required for completed test calls.

Microsoft Teams Phone with Calling Plans, Operator Connect, or Teams Phone Mobile

Do

Configure dial string 933 within the custom Teams emergency calling policy, ensuring it is configured without security desk notification so test calls do not alert emergency personnel 35. Place a 933 test call from a client on each network tier 34.

Verify

Verify that the 933 automated service reads back the calling line ID, the precise emergency address, and indicates whether calls route directly or require screening 34.

Rollback

Suggested rollback: Remove or modify the test dial string in the Teams emergency calling policy.

Microsoft Teams Phone with Direct Routing

Do

Coordinate emergency test dialing directly through your certified Emergency Routing Service provider, as Teams Direct Routing does not route to Microsoft's native 933 test bot 3469.

Verify

Suggested check: Confirm via ERSP test logs or test service callbacks that the transmitted PIDF-LO address correctly reflects the dispatchable location.

Rollback

Suggested rollback: Close test sessions with the ERSP.

Step 9 Maintain location databases after moves, adds, and changes

Cisco Unified CM with Cisco Emergency Responder

Do

Export and resubmit ALI data to your telecommunications provider whenever an ELIN or ERL civic address changes 4. Periodically audit unlocated phone reports in Emergency Responder 12.

Verify

Verify that no active enterprise phones remain in the unlocated list or resolve to the default ERL without operational justification 712.

Rollback

Suggested rollback: Resubmit corrected ALI export files to the provider.

Webex Calling with native enhanced emergency calling

Do

Update the RedSky portal wiremap whenever network subnets, switches, or wireless access points are added or changed 61. Ensure non-HELD devices are updated administratively if moved 53.

Verify

Before turning on routing of 911 calls to RedSky, place 933 test calls, and repeat them to verify the caller ID and known address 7050.

Rollback

Suggested rollback: Revert modified wiremap entries in the RedSky portal.

Microsoft Teams Phone with Calling Plans, Operator Connect, or Teams Phone Mobile

Do

Update LIS subnets, switches, ports, and BSSIDs whenever internal enterprise network routing or switching hardware changes 40. Re-create emergency addresses that have aged more than a couple of years 38.

Verify

Allow up to 4 hours for replication, then place 933 verification calls from modified segments 4334.

Rollback

Suggested rollback: Revert LIS network identifier mappings in Teams admin center.

Microsoft Teams Phone with Direct Routing

Do

Update LIS network records when switching or subnet boundaries change, and re-create emergency addresses that have aged more than a couple of years 4038.

Verify

Allow up to 4 hours for propagation across Teams clients 43. Suggested check: verify address resolution via ERSP test facilities.

Rollback

Suggested rollback: Revert modified LIS entries in Teams admin center or PowerShell.

Applicability

Applies to: n MLTS (47 CFR Part 9), Cisco Unified CM with Emergency Responder, Cisco Emergency Responder, MLTS (cloud calling), n MLTS (FCC 19-76), n MLTS (47 USC 623), Microsoft Teams Phone, Microsoft Teams Phone Direct Routing, Cisco Webex Calling, and MLTS. Deployments: on-premises, hybrid, and multi-tenant. Sources checked 2026-09-24. The evidence covers the United States and its territories 2371. Teams Direct Routing certified emergency providers include Bandwidth Dynamic Location Routing, Intrado Emergency Routing Service, and Inteliquent 7273. WarmTransfer's reading of the sources is that deploying RedSky behind Teams Direct Routing operates outside Microsoft's certified ERS list and may lead Microsoft to reject support cases 7475. Canadian Direct Routing emergency calls are screened nationally before PSAP transfer 76.

What remains uncertain

The rules do not address state-specific MLTS statutory additions, and state 911 laws are not covered by the sources below. Recordkeeping obligations and enforcement penalties are not covered by the sources below. The applicability of dispatchable location requirements to MLTS systems installed prior to 2021 is not covered by the sources below. Dedicated Instance dial plan specifics, Webex Calling outside-dial-digit configurations, and Unified CM operation without Emergency Responder are not covered by the sources below. Whether the "technically infeasible" exception for notification content remains codified in current federal rules is not covered by the sources below.

Sources

1
Alternative location information is location information, which may be coordinate-based, sufficient to identify the caller's civic address and approximate in-building location, including floor level in large buildings.
47 CFR § 9.3 - Definitions (Cornell LII republication) · 47 CFR 9.3, definition 'Alternative location information' · Checked 2026-09-24
2
With Cisco Emergency Responder, Unified CM needs a CTI route point for the emergency number (such as 911) in the E911 partition so Emergency Responder intercepts emergency calls.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Configure Cisco Unified Communications Manager · Configure Cisco Unified Communications Manager > Create Emergency Call Route Points · Checked 2026-09-24
3
An Emergency Responder onsite alert shows the caller extension, display name, ERL and call time.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Configure Cisco Emergency Responder Onsite Alerts · Configure Cisco Emergency Responder Onsite Alerts > example alert · Checked 2026-09-24
4
Emergency Responder administrators must export ALI data to the service provider and resubmit it whenever ELIN or location information changes.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Plan for Cisco Emergency Responder · Plan for Cisco Emergency Responder > ALI data export · Checked 2026-09-24
5
In Emergency Responder's Unified CM setup the E911 partition must be listed before the phones partition in E911CSS, and phones cannot reach the E911 partition directly.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Configure Cisco Unified Communications Manager · Configure Cisco Unified Communications Manager > partitions and calling search spaces · Checked 2026-09-24
6
In Emergency Responder an ERL is the area from which an emergency call is placed, and an ELIN is a number that routes the call to the local PSAP and that the PSAP can use to call the caller back.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Plan for Cisco Emergency Responder · Plan for Cisco Emergency Responder > ERL and ELIN definitions · Checked 2026-09-24
7
Emergency Responder locates phones in precedence order: synthetic phones, switch port, access point, IP subnet, remote server group, manual line assignment, unlocated phones, then default ERL.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Plan for Cisco Emergency Responder · Plan for Cisco Emergency Responder > phone location precedence · Checked 2026-09-24
8
RedSky and Intrado are the approved national E911 service providers for Cisco Emergency Responder, as an alternative to a direct connection with the local exchange carrier.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Configure Emergency Responder and National E911 Service Provider · Configure Emergency Responder and National E911 Service Provider > overview · Checked 2026-09-24
9
To support off-premises users, Emergency Responder administrators create off-premises ERLs and assign them to IP subnets and unlocated phones.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Configure Cisco Emergency Responder · Configure Cisco Emergency Responder > Remote Teleworker and Off-Premises User - E911 · Checked 2026-09-24
10
With a national E911 provider, Emergency Responder off-premises users create a location on the Off-Premises User page (or through Jabber or Webex) and validate the address with the provider before it becomes active.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Configure Emergency Responder and National E911 Service Provider · Configure Emergency Responder and National E911 Service Provider > off-premises location · Checked 2026-09-24
11
Emergency Responder notifies onsite alert personnel assigned to an ERL by telephone call, web alert, email and text alerts.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Plan for Cisco Emergency Responder · Plan for Cisco Emergency Responder > onsite alert notification methods · Checked 2026-09-24
12
With a national E911 provider, Emergency Responder tracks each phone as On-premises, Off-premises or unlocated.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Configure Emergency Responder and National E911 Service Provider · Configure Emergency Responder and National E911 Service Provider > phone status · Checked 2026-09-24
13
Emergency Responder uses a PSAP callback CTI route point such as 913XXXXXXXXXX in the E911 partition, with 913 stripped to reveal the ELIN, to route PSAP callbacks to the emergency caller.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Configure Cisco Unified Communications Manager · Configure Cisco Unified Communications Manager > PSAP callback route point · Checked 2026-09-24
14
Emergency Responder switch-port tracking requires configuring switches in Emergency Responder with an SNMPv2 or SNMPv3 connection.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Configure Cisco Emergency Responder · Configure Cisco Emergency Responder > Emergency Responder Switch Configuration > Set Up SNMP Connection · Checked 2026-09-24
15
Emergency Responder supports test ERLs and synthetic phones, which assign an ERL by MAC address for testing.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Plan for Cisco Emergency Responder · Plan for Cisco Emergency Responder > phone location precedence (synthetic phones) · Checked 2026-09-24
16
The Emergency Responder guide uses translation patterns in the phones' partition, with calling search space E911CSS, for 911 and for 9.911 (discarding PreDot digits) so both reach the 911 route point without secondary-dialtone delay.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Configure Cisco Unified Communications Manager · Configure Cisco Unified Communications Manager > alternate emergency call number (9911) translation pattern procedure · Checked 2026-09-24
17
Because the MLTS definition names network-based VoIP and Centrex systems, a cloud calling service used by an enterprise (Webex Calling, Teams Phone) is likely an MLTS subject to these rules, and Microsoft's own documentation discusses its RAY BAUM's Act MLTS compliance.inferred
47 CFR § 9.3 - Definitions (Cornell LII republication) · 47 CFR 9.3, definition 'Multi-line telephone system or MLTS' · Checked 2026-09-24
18
Under the FCC rules an MLTS is 'configured' when its installation settings make it fully capable, when installed, of dialing 911 directly and providing MLTS notification.
47 CFR § 9.3 - Definitions (Cornell LII republication) · 47 CFR 9.3, definition 'Configured' · Checked 2026-09-24
19
A person installing, managing or operating an MLTS must configure it so a user can directly initiate a 911 call from any station without dialing any additional digit, code, prefix or post-fix, including a trunk-access code such as 9.
47 CFR § 9.16 - General obligations for MLTS (Cornell LII republication) · 47 CFR 9.16(b)(1) · Checked 2026-09-24
20
Dispatchable location means the validated street address of the calling party plus additional information such as suite or apartment needed to identify the caller's location, delivered to the PSAP with the 911 call.
47 CFR § 9.3 - Definitions (Cornell LII republication) · 47 CFR 9.3, definition 'Dispatchable location' · Checked 2026-09-24
21
The FCC allows an MLTS to support additional dialing patterns for 911, such as 9-911, only in addition to the default direct 911 dialing pattern.
Implementing Kari's Law and RAY BAUM'S Act; Inquiry Concerning 911 Access, Routing, and Location in Enterprise Communications Systems (Final rule, 84 FR 66716) · Federal Register summary, paras. 59-60 (pre-configured definition discussion) · Checked 2026-09-24
22
An on-premises fixed telephone associated with an MLTS must provide automated dispatchable location no later than January 6, 2021.
47 CFR § 9.16 - General obligations for MLTS (Cornell LII republication) · 47 CFR 9.16(b)(3)(i) · Checked 2026-09-24
23
An MLTS installer may not install a system in the United States unless it can be programmed with and convey the caller's dispatchable location to the PSAP with 911 calls.
47 CFR § 9.16 - General obligations for MLTS (Cornell LII republication) · 47 CFR 9.16(b)(3), main clause · Checked 2026-09-24
24
Kari's Law applies to MLTS manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020.
47 U.S. Code § 623 - Multi-line telephone systems (Kari's Law) · 47 USC 623, effective-date note (two years after enactment) · Checked 2026-09-24
25
The FCC's MLTS definition covers network-based and premises-based systems, naming Centrex and VoIP as well as PBX, hybrid and key telephone systems.
47 CFR § 9.3 - Definitions (Cornell LII republication) · 47 CFR 9.3, definition 'Multi-line telephone system or MLTS' · Checked 2026-09-24
26
From January 6, 2022 an on-premises non-fixed MLTS device must provide automated dispatchable location when technically feasible, and otherwise dispatchable location based on end-user manual update or alternative location information.
47 CFR § 9.16 - General obligations for MLTS (Cornell LII republication) · 47 CFR 9.16(b)(3)(ii) · Checked 2026-09-24
27
An MLTS notification must include the fact that a 911 call was made, a valid callback number, and the caller-location information the MLTS conveys to the PSAP.
47 CFR § 9.3 - Definitions (Cornell LII republication) · 47 CFR 9.3, definition 'MLTS notification' · Checked 2026-09-24
28
The FCC's MLTS notification definition, as adopted in 2019, excuses the callback number or location information in the notification where providing it is technically infeasible.
Implementing Kari's Law and RAY BAUM'S Act; Inquiry Concerning 911 Access, Routing, and Location in Enterprise Communications Systems (Final rule, 84 FR 66716) · Federal Register summary, para. 24 (definition of MLTS notification) · Checked 2026-09-24
29
Kari's Law requires a person managing or operating an MLTS to configure it to notify a central location at the facility, or another person or organization, when a 911 call is made, if the system can do so without an improvement to its hardware or software.
47 U.S. Code § 623 - Multi-line telephone systems (Kari's Law) · 47 USC 623(c) · Checked 2026-09-24
30
MLTS notification must be initiated at the same time as the 911 call where technically feasible, must not delay the 911 call, and must go to a location where someone is likely to see or hear it.
47 CFR § 9.16 - General obligations for MLTS (Cornell LII republication) · 47 CFR 9.16(b)(2)(i)-(iii) · Checked 2026-09-24
31
From January 6, 2022 an off-premises MLTS device must provide automatic dispatchable location if technically feasible, and otherwise dispatchable location based on end-user manual update or enhanced location information.
47 CFR § 9.16 - General obligations for MLTS (Cornell LII republication) · 47 CFR 9.16(b)(3)(iii) · Checked 2026-09-24
32
On-premises means within the fixed property, such as buildings, facilities or campus, and under the operational control of a single administrative authority.
47 CFR § 9.3 - Definitions (Cornell LII republication) · 47 CFR 9.3, definition 'On-premises' · Checked 2026-09-24
33
The FCC assigns MLTS responsibility by conduct (installer, manager, operator), and said a passive owner generally should not face liability if it contracts with a responsible third party and includes compliance requirements.
Implementing Kari's Law and RAY BAUM'S Act; Inquiry Concerning 911 Access, Routing, and Location in Enterprise Communications Systems (Final rule, 84 FR 66716) · Federal Register summary, paras. 79, 85, 88-95 · Checked 2026-09-24
34
Teams Calling Plan, Operator Connect and Teams Phone Mobile users in the US or Canada can dial 933 to reach a bot that reads back calling line ID, emergency address and whether the call would route directly or be screened; Direct Routing customers coordinate testing with their ERSP.
Configure dynamic emergency calling · Configure dynamic emergency calling > Test emergency calling · Checked 2026-09-24
35
A Teams emergency calling policy can handle the 933 test number differently so that test calls do not alert the security desk.
Configure dynamic emergency calling · Configure dynamic emergency calling > Configure emergency policies (Emergency calling policy) · Checked 2026-09-24
36
For Teams Direct Routing emergency calls, the SBC's PidfloSupported setting must be true and you must connect an Emergency Routing Service provider or configure the SBC for an ELIN application.
Configure dynamic emergency calling · Configure dynamic emergency calling > Emergency calling prerequisites for Direct Routing · Checked 2026-09-24
37
Turning on External location lookup mode in a Teams emergency calling policy lets users set their own emergency address when they are off the corporate network.
Emergency addresses for remote locations · Emergency addresses for remote locations > Enable end users to configure their emergency address · Checked 2026-09-24
38
A Teams emergency address must be validated and carry a geo code before it can be assigned to a network identifier; addresses more than a couple of years old must be re-created.
Configure dynamic emergency calling · Configure dynamic emergency calling > Assign emergency addresses · Checked 2026-09-24
39
The Teams Location Information Service matches a client's location using the first match in this order: wireless access point, Ethernet switch/port, Ethernet switch, subnet.
Configure dynamic emergency calling · Configure dynamic emergency calling > Plan for emergency calling · Checked 2026-09-24
40
Teams clients get a dynamic location only if the LIS is populated with subnets, Wi-Fi access points, switches or ports mapped to emergency locations, in Teams admin center (Locations > Networks & locations) or PowerShell.
Configure dynamic emergency calling · Configure dynamic emergency calling > Configure Location Information Service · Checked 2026-09-24
41
Teams uses emergency location in this order: admin-defined LIS address, user-confirmed address for the current network, OS-suggested address, user-entered address without service resolution, then the address statically assigned to the user's number.
Emergency addresses for remote locations · Emergency addresses for remote locations > Location precedence · Checked 2026-09-24
42
A Teams emergency calling policy sets notification per emergency number as notification only, conferenced in muted, or conferenced in unmuted, each sending a Teams chat to named users and groups, with an optional PSTN number dialled for the conferenced modes.
Manage emergency calling policies in Microsoft Teams · Manage emergency calling policies > Create a custom emergency calling policy, step 6 · Checked 2026-09-24
43
Changes to Teams network settings, such as a new address or network identifier, can take up to four hours to reach Teams clients.
Configure dynamic emergency calling · Configure dynamic emergency calling > Configure network settings · Checked 2026-09-24
44
The Teams emergency call routing policy (emergency numbers, masks and PSTN route) applies only to Direct Routing; Calling Plan, Operator Connect and Teams Phone Mobile users are enabled automatically from their usage location.
Configure dynamic emergency calling · Configure dynamic emergency calling > Configure emergency policies · Checked 2026-09-24
45
In the US, Teams sends calls with manually entered addresses, unconfirmed OS addresses, user-static addresses or no address to a screening centre before the PSAP; admin-defined dynamic addresses route directly.
Emergency addresses for remote locations · Emergency addresses for remote locations > Emergency address classification and routing (table) · Checked 2026-09-24
46
When a Teams emergency calling policy is assigned both to a network site and to a user who is at that site, the site policy takes precedence.
Manage emergency calling policies in Microsoft Teams · Manage emergency calling policies > introduction · Checked 2026-09-24
47
Teams attempts IP-based dynamic policy or location lookup only when the client's external IP matches a tenant trusted IP address, but switch/port and BSSID lookups happen regardless.
Configure dynamic emergency calling · Configure dynamic emergency calling > Configure network settings · Checked 2026-09-24
48
Teams dynamic emergency calling, including security desk notification, is not supported on the Teams web client, and Microsoft suggests a calling policy with Web PSTN calling turned off for those users.
Configure dynamic emergency calling · Configure dynamic emergency calling > Supported clients (note) · Checked 2026-09-24
49
The Teams work-from-home address experience applies to Teams desktop on Windows and Mac; Teams phones do not support it and Teams mobile supports automatic detection only.
Emergency addresses for remote locations · Emergency addresses for remote locations > Notes and restrictions · Checked 2026-09-24
50
A Webex Calling 933 test call reaches an IVR that announces the caller ID and currently known address without alerting emergency services.
Enhanced emergency calling for Webex Calling · Enhanced emergency calling for Webex Calling > 933 test calls · Checked 2026-09-24
51
Webex Calling's emergency callback number (ECBN), used by the PSAP to call back, can be the user's own number, the location's default ECBN, or another number assigned in the same location.
Configure emergency callback number in Control Hub · Configure emergency callback number in Control Hub > ECBN options · Checked 2026-09-24
52
To turn on Webex Calling enhanced emergency calling for a location you enable it, authorise RedSky to receive network data and test calls, place 933 test calls from several device types, and only then turn on Route Emergency Calls to RedSky.
Enhanced emergency calling for Webex Calling · Enhanced emergency calling for Webex Calling > enable for a location · Checked 2026-09-24
53
In Webex Calling, HELD-capable devices (Cisco MPP phones, Room/Desk/Board and Webex App) are located by network discovery, while non-HELD phones such as Poly and Yealink use a static location tied to their caller ID.
Enhanced emergency calling for Webex Calling · Enhanced emergency calling for Webex Calling > supported devices / dispatchable location · Checked 2026-09-24
54
Webex Calling's nomadic E911 service prompts Webex App users on an off-premises network to enter a dispatch address and reuses it when they reconnect to that network.
Enhanced emergency calling for Webex Calling · Enhanced emergency calling for Webex Calling > Nomadic E911 Service · Checked 2026-09-24
55
Webex Calling emergency call notifications are off by default and are enabled in Control Hub at organisation level, optionally letting each location set its own recipient email addresses.
Configure emergency call notifications in Control Hub · Configure emergency call notifications in Control Hub > organization and location level · Checked 2026-09-24
56
A Webex Calling emergency call notification email includes call date and time, dialed number, user name and ID, extension, the user's phone number, and the location name and main address; it is English-only from a do-not-reply sender.
Configure emergency call notifications in Control Hub · Configure emergency call notifications in Control Hub > notification contents · Checked 2026-09-24
57
With RedSky enabled for Webex Calling, notifications configured in the RedSky admin portal can go to multiple email and SMS recipients.
Enhanced emergency calling for Webex Calling · Enhanced emergency calling for Webex Calling > Kari's Law notifications · Checked 2026-09-24
58
Webex Calling enhanced emergency calling uses RedSky to route 911 calls with validated location to the PSAP in the US, its territories and Canada, and is included with the Webex Calling entitlement for US users.
Enhanced emergency calling for Webex Calling · Enhanced emergency calling for Webex Calling > overview and licensing · Checked 2026-09-24
59
If RedSky cannot determine a Webex Calling caller's location, the call goes to an emergency calling relay centre and the cost is billed to the customer.
Enhanced emergency calling for Webex Calling · Enhanced emergency calling for Webex Calling > limitations (relay centre) · Checked 2026-09-24
60
Webex App on desktop ignores VPN and virtual network interfaces for emergency location, and Intrado does not support VPN-based location detection.
Enhanced emergency calling for Webex Calling · Enhanced emergency calling for Webex Calling > limitations (VPN) · Checked 2026-09-24
61
For Webex Calling network-based location, the RedSky portal is populated with buildings and civic addresses plus wireless BSSIDs, LLDP switch MACs, switch ports and IP subnets.
Enhanced emergency calling for Webex Calling · Enhanced emergency calling for Webex Calling > network discovery configuration · Checked 2026-09-24
62
47 CFR 9.16(b)(3) requires automated dispatchable location from fixed on-premises MLTS devices by 2021-01-06, and sets 2022-01-06 for non-fixed on-premises and off-premises devices, with alternative location information allowed where automation is not technically feasible.
47 CFR § 9.16 - General obligations for MLTS (Cornell LII republication) · 47 CFR 9.16(b)(3) · Checked 2026-09-24
63
CER talks to Intrado over HTTPS through the Validation and Update Interface (VUI), which validates civic addresses against Intrado's MSAG data and sends ALI records.
Cisco Emergency Responder Administration Guide, Release 12.5(1)SU8b-SU9 - Configure Emergency Responder and Intrado V9-1-1 Enterprise Services · Set Up Intrado VUI Settings; Set Up Intrado ERLs (Pre-validate from Intrado) · Checked 2026-09-24
64
Microsoft documentation states that Teams always sends location information in a PIDF-LO SIP body on emergency call INVITEs for Direct Routing.
Emergency calling for Microsoft Teams Direct Routing with Azure Communications Gateway · Overview of emergency calling; Emergency numbers and location information · Checked 2026-09-24
65
Teams clients no longer prepend '+' to emergency numbers, so Direct Routing voice routes toward an emergency provider must match 911 rather than +911.
Considerations for Direct Routing · Emergency call routing for Direct Routing, Note · Checked 2026-09-24
66
In CER 15, on-premises phones convey location through automated ERL-ELIN delivery, while off-premises location is entered by the user against the user's DID. An optional MyE911 setting integrates third-party location apps such as Webex and Jabber.
Cisco Emergency Responder Administration Guide, Release 15 and SUs - Configure Emergency Responder and National E911 Service Provider · Location conveyance and location updates notes · Checked 2026-09-24
67
With an Emergency Routing Service Provider integrated into Direct Routing, calls with a dynamically acquired location route automatically to the PSAP for that location, and calls without one are first screened to confirm the caller's location.
Considerations for Direct Routing · Emergency Routing Service Providers subsection · Checked 2026-09-24
68
With an SBC ELIN application, the SBC matches the caller's location to an ELIN record, replaces the caller's number with the ELIN, and routes to the PSAP. The ELIN records must be uploaded to the PSTN emergency database, and callbacks are reverse-substituted.
Considerations for Direct Routing · Emergency Location Identification Number applications subsection · Checked 2026-09-24
69
Direct Routing customers in the US must coordinate emergency call testing with their ERS provider; the 933 test bot is for Calling Plan, Operator Connect and Teams Phone Mobile users.
Configure dynamic emergency calling · Test emergency calling · Checked 2026-09-24
70
Cisco directs Webex Calling admins to place 933 test calls before turning on routing of 911 calls to RedSky.
Enhanced Emergency Calling for Webex Calling · Control Hub setup procedure; test call step preceding Route Emergency Calls to RedSky · Checked 2026-09-24
71
Webex Calling enhanced emergency calling with RedSky applies to the United States, its territories and Canada; locations in other countries keep using PSTN-provider emergency service.
Enhanced Emergency Calling for Webex Calling · article overview; supported regions statement · Checked 2026-09-24
72
Microsoft lists Intrado Emergency Routing Service (ERS) as a certified and supported 911 service provider for Teams Direct Routing, together with Bandwidth Dynamic Location Routing and Inteliquent.
Session Border Controllers certified for Direct Routing - Microsoft Teams · Certified SBC vendors table footnote '911 service providers' · Checked 2026-09-24
73
Microsoft's certified 911 service providers for Direct Routing are Bandwidth Dynamic Location Routing, Intrado Emergency Routing Service and Inteliquent; RedSky is not on that list.
Session Border Controllers certified for Direct Routing - Microsoft Teams · Certified SBC vendors > footnote '911 service providers' · Checked 2026-09-24
74
Using RedSky as the emergency routing provider behind Teams Direct Routing would put it outside Microsoft's certified ERS list, so Microsoft may reject related support cases.inferred
Session Border Controllers certified for Direct Routing - Microsoft Teams · Certified SBC vendors > footnote '911 service providers' · Checked 2026-09-24
75
Microsoft says it may reject support cases if a non-certified emergency services provider is used with Direct Routing.
Session Border Controllers certified for Direct Routing - Microsoft Teams · '911 service providers' footnote · Checked 2026-09-24
76
For Direct Routing in Canada, dynamic emergency location works as in the US except that all emergency calls are screened nationally before being transferred to the PSAP.
Considerations for Direct Routing · Dynamic emergency calling for Direct Routing, final paragraph · Checked 2026-09-24

Documents

tier 1 standards and regulators

Implementing Kari's Law and RAY BAUM'S Act; Inquiry Concerning 911 Access, Routing, and Location in Enterprise Communications Systems (Final rule, 84 FR 66716)

Federal Register / Federal Communications Commission (via GovInfo) · 2019-12-05 · accessed 2026-09-24

tier 2 current vendor documentation

Cisco Emergency Responder Administration Guide, Release 12.5(1)SU8b-SU9 - Configure Emergency Responder and Intrado V9-1-1 Enterprise Services

Cisco Systems · accessed 2026-09-24

tier 2 current vendor documentation

Cisco Emergency Responder Administration Guide, Release 15 and SUs - Configure Emergency Responder and National E911 Service Provider

Cisco Systems · 2026-03-17 · accessed 2026-09-24

tier 2 current vendor documentation

Cite this page

APA

WarmTransfer. (2026, September 24). Meeting Kari's Law and RAY BAUM's Act on an enterprise phone system. WarmTransfer. https://warmtransfer.net/guides/kari-ray-baum-compliance

BibTeX

@misc{warmtransfer-kari-ray-baum-compliance,
  title  = {Meeting Kari's Law and RAY BAUM's Act on an enterprise phone system},
  author = {{WarmTransfer}},
  year   = {2026},
  url    = {https://warmtransfer.net/guides/kari-ray-baum-compliance},
  note   = {Verified 2026-09-24}
}