E911 Compliance for Multi-Site and Remote Teams: Kari’s Law and RAY BAUM’s Act

E911 compliance looks handled until someone tests it. The phones work, the dial plan has been in place for years, and then a 911 call goes out from a home office three states away carrying the headquarters address. E911 compliance for multi-site and remote teams rests on two federal rules, both enforceable for years now, and the FCC assigns the obligation to whoever installs, manages, and operates the system. Usually that is the IT provider, not the carrier.

TL;DR

• Kari's Law covers the call: direct 911 dialing with no prefix, plus notification to a central point when 911 is dialed.
• RAY BAUM's Act Section 506 covers the location: a validated street address plus floor, suite, or room delivered to the 911 call center.
• The rules are forward-looking, covering systems sold, leased, or installed after February 16, 2020.
• Fixed devices were due January 6, 2021. Non-fixed and off-premises devices were due January 6, 2022. Every deadline has passed.
• The obligation attaches to installing, managing, and operating the system, putting the MSP inside the rule alongside the customer.

What Kari's Law and RAY BAUM's Act Actually Require

The FCC adopted both rules in August 2019 and codified them in 47 CFR Part 9. A multi-line telephone system, or MLTS, is the class of system used in offices, hotels, hospitals, and campuses, and the FCC read that definition broadly: IP-based systems, cloud hosted VoIP, traditional PBX, hybrid and key systems, even outbound-only systems, including PBXs fed by SIP trunking. The two rules do different jobs and neither satisfies the other. Kari's Law makes sure the call connects and someone on site knows. RAY BAUM's Act makes sure responders can find the caller. An organization can be compliant on the first and still exposed on the second, which is the split most audits turn up.

Why the Obligation Lands on the MSP, Not the Carrier

Most E911 content skips this, and it is the part that matters if you sell and support voice for a living. The rules do not assign these duties to the carrier. They assign them by activity. Under 47 CFR 9.16, a person engaged in the business of installing an MLTS may not install one unless it conveys dispatchable location, and a person managing or operating an MLTS may not do so unless the same is true.

Read that against how managed voice works. The MSP or white label reseller scopes the deployment, provisions the tenant, programs the dial plan, registers emergency addresses, onboards users, and owns the support queue. Those are the activities the rule names. The carrier delivers routing, the customer occupies the building, and the party doing the configuration is the one the FCC is describing.

That is not cause to hand the customer a disclaimer and walk away. It is cause to make E911 a gated step in deployment and to state in writing who owns which piece. The logic governing PSTN and numbering obligations for resellers applies here too: once you operate the service, the obligations attach whether you planned for them or not.

Why Multi-Site and Remote Teams Are the Hard Part

A single office at one street address is the easy case: register the address, verify routing, move on. The deployments that fail have several locations, a few floors, and a workforce that is partly at home, and E911 for remote workers is the piece that most often gets skipped.

The problem is architectural. In a legacy system 911 routing was physical: each line was wired to a known place, so location was a property of the copper. Dispatchable location in a VoIP environment is harder because routing is logical and a call can originate from any device anywhere. A softphone does not inherently know which building it is in, and absent configuration it reports whatever address was assigned to the account, usually headquarters. That is true across the whole unified communications stack, not just desk phones.

The consequence is a call routed to the wrong public safety answering point entirely, or one that reaches the right center with an address sending responders to the wrong building. RAY BAUM's Act addresses this by extending dispatchable location to on-premises non-fixed devices and off-premises devices, which is where nearly every remote worker sits. Voice inside Microsoft Teams deserves particular attention, since the calling layer and the location layer often get provisioned separately.

Kari's Law: Direct Dialing and Notification

Kari's Law is named for Kari Hunt, who was killed in a Texas motel room in 2013. Her nine year old daughter tried to call 911 four times and never got through, because the motel's system required dialing 9 first. Direct dialing is the simpler half of the resulting rule: a user must reach 911 from any station with dialing facilities without any additional digit, code, prefix, or post-fix, including a trunk-access code such as 9. That holds even where users dial a prefix for every other call, a distinction worth checking in older dial plans migrated forward rather than rebuilt.

The MLTS notification requirement is the half that gets missed. When 911 is dialed, the system must notify a central location, on site or off, where someone is likely to see or hear it. A security desk pop-up, an SMS, or an email to an administrator list all qualify. It must not delay the call, and should carry the callback number and location where feasible. The purpose is building entry: somebody meets responders at the door and takes them to the right floor.

On scope, the rules are forward-looking, applying to systems manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020. Anything installed before that date sits outside the federal requirement as written. That is a narrow reprieve rather than a strategy: replacing or reinstalling brings it into scope, several states impose requirements regardless of install date, and an inherited non-compliant dial plan is a conversation nobody wants after an incident.

RAY BAUM's Act and Dispatchable Location

A dispatchable location is the validated street address of the calling party plus detail such as suite, apartment, or floor needed to adequately identify where the caller is. The operative word is validated. An address typed into a portal that nobody checked against a canonical database fails at the worst possible moment. In a tower or a hospital, the street address gets responders to a lobby. The floor and room get them to the person. The rules split by device type:

• On-premises fixed devices. Desk phones at a known address must provide automatic dispatchable location. No fallback tier.
• On-premises non-fixed devices. Softphones and devices that move around the building must provide automatic dispatchable location if technically feasible, otherwise a location based on end user manual update or enhanced location information.
• Off-premises devices. The same tiered standard covers home offices and travelling users.

E911 Compliance Deadlines

The FCC staggered deadlines by rule and device type. Kari's Law compliance was required first, with the dispatchable location dates following in two waves. All are now in the past, so there is no runway left and a new site or new remote hire is expected to be compliant on day one.

The highlighted row is the one to watch. It is the most recent deadline, it covers softphones and remote workers, and it is the requirement distributed organizations are least likely to have finished. Full rule text sits in 47 CFR Part 9 Subpart F, and the FCC keeps a plain-language MLTS 911 requirements summary worth bookmarking. Enforcement mechanics sit in 9.17, though the penalty figures circulating on vendor blogs do not trace back to FCC sources. The practical exposure for an MSP is civil: a failed call with a documented configuration gap is a liability problem, not just a compliance finding.

How to Achieve E911 Compliance Across Sites and Remote Workers

1. Confirm direct 911 dialing on every device. Test a desk phone, a softphone, and a mobile app on each tenant. Coordinate with the local public safety answering point or use your provider's test number so you are not tying up a dispatcher.
2. Enable MLTS notification and prove it fires. Configure the alert with callback number and location, then verify it arrives and does not delay the call. A notification nobody has tested should be assumed broken.
3. Register a dispatchable location for every fixed device. Map the validated street address plus floor, suite, or room, checked against the canonical database rather than a form filled in at onboarding.
4. Handle non-fixed and off-premises devices deliberately. Deliver automatic location where feasible. Otherwise prompt the user to confirm a registered address at sign-in, so it gets answered instead of dismissed.
5. Break large buildings and campuses into zones. One address for a five-floor building is not a dispatchable location in any meaningful sense. Map floors, wings, and zones.
6. Assign an owner and test on a schedule. Name someone accountable, document the configuration per site, and tie location review to the offboarding and desk-move workflows you already run, since accuracy decays through churn.
7. Layer in state requirements. Check the MLTS statute in every state where the customer has sites. Some require a separate enhanced DID or emergency location identification number for each room, suite, or building on a campus.

Emergency calling also has to survive an outage, which most compliance checklists ignore. A site that loses connectivity cannot place a 911 call at all, and correct address data does not help. Emergency number forwarding is worth configuring alongside E911, and it strengthens a managed voice SLA.

Multi-Tenant E911: Running Compliance Across a Client Base

Everything above describes one organization. An MSP with forty voice clients runs that process forty times, across forty dial plans, in however many states those clients occupy. The work does not get harder per tenant. It gets harder in aggregate, because the failure modes are silent: nothing tells you a client's remote users have been reporting the wrong address for months.

Three things make this tractable. Standardize the build, so every tenant uses the same E911 template, naming convention, and notification pattern, which turns an audit into a comparison instead of an investigation. Gate go-live on E911, treating a documented test call and signed-off location map like backup verification. Expose per-site addresses in the portal the customer already logs into, which puts the person who knows the floor plan in a position to keep it accurate.

There is also a commercial angle most partners leave on the table. Ongoing location management is recurring, documentable work: quarterly reviews, test calls, address validation, and an audit trail. That is a billable service line, not overhead, and it holds margin better than seat count, the broader pattern in the white label VoIP model. Settling the responsibility split is what makes it sellable:

Common E911 Compliance Gaps

The same handful of failures show up in nearly every audit, and none are exotic.

Where Viirtue Fits

Viirtue's hosted VoIP platform supports dispatchable location configuration so emergency services receive accurate address detail, which is what matters in multi-floor buildings, distributed offices, and hybrid teams. It carries per-location address information rather than one account-wide address, and runs on a carrier-grade voice network engineered for reliable 911 routing.

Compliance is shared, though. A platform supplies capability and routing while configuration, per-site mapping, and testing stay with the partner and the customer, so any vendor claiming to make you automatically compliant is describing a product that does not exist. What a partner should expect is tooling to do the work at scale. Mainstream UCaaS vendors hand a reseller a generic 911 toggle and a disclaimer. White label partners on Viirtue get per-location address control, an end customer portal that surfaces site data to whoever knows the floor plan, and quote-to-cash through ViiBE so a compliance service can be billed like any other line. For adjacent obligations, see the PSTN compliance guide for resellers, the UCaaS and CCaaS comparison, and the wholesale VoIP provider comparison.

This article is informational and does not constitute legal or regulatory advice. Consult qualified telecom counsel for guidance specific to your deployments, particularly on state-level MLTS requirements and liability allocation in service agreements.

E911 Compliance for Multi-Site and Remote Teams: The Bottom Line

E911 compliance for multi-site and remote teams comes down to two ideas applied with discipline. Let people dial 911 directly and tell someone on site, then make sure the call carries a validated, granular location. The complexity is not in the rules. It is in how many places a distributed organization can drift out of alignment, and in the fact that nothing surfaces that drift until an emergency does.

For MSPs that is the opportunity as much as the obligation. Standardize the build, gate go-live on a real test call, split responsibilities in writing, and review location data on a schedule. Customers rarely ask for this and consistently value it once they see what was missing. To start, confirm your sites and 911 routing with Viirtue's network readiness test, or talk to us about standing up compliant voice under your own brand through the Viirtue partner program.