# US emergency calling regulatory requirements Canonical: https://warmtransfer.net/knowledge/e911-us-regulatory Last verified: 2026-09-16 Kari's Law Act of 2017 (Public Law 115-127, approved 16 February 2018) amends the Communications Act of 1934 to require multi-line telephone systems to permit a user to dial 911 directly without an additional digit, code, prefix or postfix[^12]. Section 506 of RAY BAUM'S Act, signed on 23 March 2018 as part of the Consolidated Appropriations Act of 2018, required the Commission to conclude a proceeding by 23 September 2019 on rules to ensure that dispatchable location is conveyed with a 911 call regardless of the technological platform, including calls from multi-line telephone systems[^9]. ## Who the rules apply to 47 CFR part 9 subpart F applies to these parties and systems[^4]: - A person manufacturing, importing, selling or leasing multi-line telephone systems[^4]. - A person installing, managing or operating multi-line telephone systems[^4]. - Any multi-line telephone system manufactured, imported, offered for first sale or lease, first sold or leased, or installed after 16 February 2020[^4]. Section 9.17(b) also gives 16 February 2020 as the compliance date for the subpart[^4]. In FCC 19-76, the Commission finds that multi-line telephone system manufacturers, importers, sellers, lessors, installers, operators and managers are subject to its jurisdiction[^5]. It also finds that they fall within the statutory definition of "other emergency communications provider"[^5]. The order requires them to configure systems to ensure delivery of 911 emergency information to public safety answering points[^5]. ## Direct dialing 47 CFR 9.16 requires a multi-line telephone system to be configured so that a user can directly initiate a call to 911 from any station equipped with dialing facilities[^2]. The user must not have to dial any additional digit, code, prefix or post-fix to do so[^2]. This includes any trunk-access code such as the digit 9, regardless of whether the user must dial such a digit for other calls[^2]. The rule places this requirement separately on manufacturers, importers, sellers and lessors, and on installers, managers and operators[^2]. ## Notification 47 CFR 9.16(b)(2) requires a multi-line telephone system to be configured to send notification when a 911 call is made[^6]. The notification can go to a central location at the facility or to another person or organisation regardless of location[^6]. This requirement applies only where the system can be configured to send notification without an improvement to its hardware or software[^6]. The rule sets 3 conditions on the notification[^6]: - It must be initiated contemporaneously with the 911 call where technically feasible[^6]. - It must not delay the call to 911[^6]. - It must be sent to a location where someone is likely to see or hear it[^6]. In FCC 19-76, the Commission records that Kari's Law requires a multi-line telephone system to support notification when an end user makes a 911 call, but does not specify what information the notification must provide[^7]. The same order records that the proposed definition of MLTS Notification required, at minimum, the following[^7]: - The fact that a 911 call has been made[^7]. - A valid callback number[^7]. - The information about the caller's location that the system conveys to the public safety answering point[^7]. ## Dispatchable location deadlines 47 CFR 9.16(b)(3) sets 3 dispatchable location deadlines for multi-line telephone systems[^11]: - **On-premises fixed telephone:** must provide automated dispatchable location no later than 6 January 2021[^11]. - **On-premises non-fixed device:** must comply no later than 6 January 2022[^11]. It must provide automated dispatchable location when technically feasible[^11]. Otherwise, it must provide dispatchable location based on end user manual update, or alternative location information as defined in section 9.3[^11]. - **Off-premises device:** must comply no later than 6 January 2022[^11]. It must provide automatic dispatchable location if technically feasible[^11]. Otherwise, it must provide end user manual update, or enhanced location information, which may be coordinate-based[^11]. 47 CFR 9.11(b) applies its interconnected Voice over Internet Protocol E911 requirements on or after 6 January 2021 for fixed services and on or after 6 January 2022 for non-fixed services[^1]. These are the same 2 dates the multi-line telephone system rules use for on-premises fixed telephones and for non-fixed and off-premises devices[^1]. See also [Dispatchable location and nomadic user handling](https://warmtransfer.net/knowledge/dispatchable-location). ## Phase terminology In the field, phase designations occur 62 times across 47 CFR part 9 in total[^8]. In the field, these designations occur 0 times within subpart F, the multi-line telephone system subpart[^8]. In the field, phase language in part 9 describes the wireless enhanced 911 location obligations of commercial mobile radio service providers instead[^8]. Cisco states that RAY BAUM'S Act Phase 2 began in January 2022[^14]. Cisco also states that RAY BAUM'S Act Phase 2 requires emergency calls to send a correct dispatch address for non-fixed devices and for nomadic users[^14]. ## Responsibility and enforcement 47 CFR 9.17(a) states that if a system does not comply with section 9.16(b), the person engaged in the business of managing the multi-line telephone system is presumed to be responsible[^3]. Under 9.17(a), the direct dialing and notification rules are enforced under title V of the Communications Act, with section 501 applying only for a fine[^3]. A person alleging a violation may file a complaint under sections 1.711 through 1.737[^3]. 47 CFR 9.17(c) states that the direct dialing and notification rules are not intended to alter the authority of state commissions or other state or local agencies with jurisdiction over emergency communications[^10]. That preservation applies where the exercise of that authority is not inconsistent with the subpart[^10]. See also [Meeting Kari's Law and RAY BAUM's Act on an enterprise phone system](https://warmtransfer.net/knowledge/kari-ray-baum-compliance). ## Cisco's stated approach to notification Cisco states that to comply with Public Law 115-127, known as Kari's Law, any call to emergency services made from within the organisation must generate an email notification[^13]. Cisco's documentation describes how this email notification behaves in Control Hub[^15]: - It is disabled by default[^15]. - It must be turned on at organisation level before an individual location can turn it on[^15]. - It is sent from a do-not-reply address that cannot be edited[^15]. - It is sent in English only, and translation is not supported[^15]. See also [Webex Calling enhanced emergency calling](https://warmtransfer.net/knowledge/webex-calling-emergency-calling). ## Applicability Applies to: Cisco multi-line telephone systems, Federal Communications Commission multi-line telephone systems, and Cisco Webex Calling. Deployments: multi-tenant. Sources checked 2026-09-16. The subpart F rules cover multi-line telephone systems manufactured, imported, offered for first sale or lease, first sold or leased, or installed after 16 February 2020[^4]. ## What remains uncertain Which United States states impose MLTS 911 requirements beyond the federal rules is not covered by the sources below. What validation of a street address means, and who performs it, is not covered by the sources below. Whether any order after FCC 19-76 changed the MLTS rules is not covered by the sources below. How an organisation establishes that its system cannot be configured to notify without a hardware or software improvement is not covered by the sources below. Whether Cisco's email notification is the only way it can satisfy 9.16(b)(2) is not covered by the sources below. ## Sources [^1]: 47 CFR 9.11(b) applies its interconnected Voice over Internet Protocol E911 requirements on or after 6 January 2021 for fixed services and on or after 6 January 2022 for non-fixed services, the same 2 dates the multi-line telephone system rules use for on-premises fixed telephones and for non-fixed and off-premises devices. Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR 9.11(b). Checked 2026-09-16. [^2]: 47 CFR 9.16 requires a multi-line telephone system to be configured so that a user may directly initiate a call to 911 from any station equipped with dialing facilities without dialing any additional digit code prefix or post-fix, including any trunk-access code such as the digit 9, regardless of whether the user is required to dial such a digit for other calls, and places that requirement separately on manufacturers importers sellers and lessors and on installers managers and operators. Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR 9.16(a)(1) and 9.16(b)(1). Checked 2026-09-16. [^3]: 47 CFR 9.17(a) states that in the event of noncompliance with section 9.16(b) the person engaged in the business of managing the multi-line telephone system is presumed to be responsible, that the direct dialing and notification rules are enforced under title V of the Communications Act with section 501 applying only for a fine, and that a person alleging a violation may file a complaint under sections 1.711 through 1.737. Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR 9.17(a). Checked 2026-09-16. [^4]: 47 CFR part 9 subpart F applies to a person manufacturing importing selling or leasing multi-line telephone systems, to a person installing managing or operating them, and to any multi-line telephone system manufactured imported offered for first sale or lease first sold or leased or installed after 16 February 2020, which section 9.17(b) also gives as the compliance date for the subpart. Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR 9.15 and 9.17(b). Checked 2026-09-16. [^5]: In FCC 19-76 the Commission finds that multi-line telephone system manufacturers importers sellers lessors installers operators and managers are subject to its jurisdiction and fall within the statutory definition of other emergency communications provider, and requires them to configure systems to ensure delivery of 911 emergency information to public safety answering points. Source: [FCC 19-76 — Implementing Kari's Law and Section 506 of RAY BAUM'S Act, Report and Order, PS Docket No. 18-261](https://docs.fcc.gov/public/attachments/FCC-19-76A1.pdf), FCC 19-76 paragraph 169. Checked 2026-09-16. [^6]: 47 CFR 9.16(b)(2) requires a multi-line telephone system to be configured to provide notification to a central location at the facility or to another person or organisation regardless of location, only where the system can be configured to do so without an improvement to its hardware or software, and imposes 3 conditions: the notification must be initiated contemporaneously with the 911 call where technically feasible, must not delay the call to 911, and must be sent to a location where someone is likely to see or hear it. Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR 9.16(b)(2). Checked 2026-09-16. [^7]: In FCC 19-76 the Commission records that Kari's Law requires a multi-line telephone system to support notification when an end user makes a 911 call but does not specify what information the notification must provide, and that the proposed definition of MLTS Notification required at minimum the fact that a 911 call has been made, a valid callback number, and the information about the caller's location that the system conveys to the public safety answering point. Source: [FCC 19-76 — Implementing Kari's Law and Section 506 of RAY BAUM'S Act, Report and Order, PS Docket No. 18-261](https://docs.fcc.gov/public/attachments/FCC-19-76A1.pdf), FCC 19-76 paragraphs 18 and 19. Checked 2026-09-16. [^8]: The phase designations Phase 1 Phase 2 Phase I and Phase II occur 62 times across 47 CFR part 9 in total, as 23 occurrences of Phase 1, 17 of Phase 2, 4 of Phase I and 18 of Phase II, and 0 times within subpart F, the multi-line telephone system subpart, where phase language describes the wireless enhanced 911 location obligations of commercial mobile radio service providers instead (field report). Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR part 9 subpart F compared against the rest of part 9. Checked 2026-09-16. [^9]: Section 506 of RAY BAUM'S Act, signed on 23 March 2018 as part of the Consolidated Appropriations Act of 2018, required the Commission to conclude a proceeding to consider adopting rules ensuring that dispatchable location is conveyed with a 911 call regardless of the technological platform used and including calls from multi-line telephone systems, by 23 September 2019. Source: [FCC 19-76 — Implementing Kari's Law and Section 506 of RAY BAUM'S Act, Report and Order, PS Docket No. 18-261](https://docs.fcc.gov/public/attachments/FCC-19-76A1.pdf), FCC 19-76 paragraph 12. Checked 2026-09-16. [^10]: 47 CFR 9.17(c) states that nothing in the direct dialing and notification rules is intended to alter the authority of state commissions or other state or local agencies with jurisdiction over emergency communications where the exercise of that authority is not inconsistent with the subpart. Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR 9.17(c). Checked 2026-09-16. [^11]: 47 CFR 9.16(b)(3) sets 3 dispatchable location deadlines for multi-line telephone systems: an on-premises fixed telephone shall provide automated dispatchable location no later than 6 January 2021; an on-premises non-fixed device shall no later than 6 January 2022 provide automated dispatchable location when technically feasible and otherwise dispatchable location based on end user manual update or alternative location information as defined in section 9.3; and an off-premises device shall no later than 6 January 2022 provide automatic dispatchable location if technically feasible and otherwise end user manual update or enhanced location information which may be coordinate-based. Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR 9.16(b)(3)(i) to (iii). Checked 2026-09-16. [^12]: Kari's Law Act of 2017 is Public Law 115-127, approved 16 February 2018, and amends the Communications Act of 1934 to require multi-line telephone systems to permit a user to dial 911 directly without an additional digit, code, prefix or postfix. Source: [Kari's Law Act of 2017, Public Law 115-127](https://www.govinfo.gov/app/details/PLAW-115publ127), public law title and approval date on the govinfo record. Checked 2026-09-04. [^13]: Cisco states that to comply with Public Law 115-127, known as Kari's Law, any call made from within the organisation to emergency services must generate an email notification. Source: [Enhanced Emergency Calling for Webex Calling](https://help.webex.com/en-us/article/av6oo3/Enhanced-Emergency-Calling-for-Webex-Calling), Notification requirements. Checked 2026-09-04. [^14]: Cisco states that RAY BAUM'S Act Phase 2 began in January 2022 and requires emergency calls to send a correct dispatch address for non-fixed devices and for nomadic users. Source: [Enhanced Emergency Calling for Webex Calling](https://help.webex.com/en-us/article/av6oo3/Enhanced-Emergency-Calling-for-Webex-Calling), Nomadic E911 Service. Checked 2026-09-04. [^15]: The emergency call notification email that Cisco publishes to follow Public Law 115-127, known as Kari's Law, is disabled by default in Control Hub, must be turned on at organisation level before an individual location can turn it on, and is sent from a non-editable do-not-reply address in English only with no translation supported. Source: [Configure emergency call notifications in Control Hub](https://help.webex.com/en-us/article/nj0abhbb/Configure-Emergency-Call-Notifications-in-Control-Hub), Emergency call notification details, and Allow individual locations to turn on emergency notifications. Checked 2026-09-16.