Understanding 911 compliance requirements

In the United States, companies are subject to regulations issued by federal, state and local authorities. At the federal level, two key laws are Kari's Law and RAY BAUM's Act.

Kari's Law, in force for multiline phone systems manufactured or installed after Feb. 16, 2020, requires that covered multiline phone systems let users call emergency services without having to first punch in a prefix, such as an 8 or 9, to reach an outside line. It also requires that appropriate personnel, such as on-site security, are notified whenever a 911 call is made.

Additionally, it mandates that 911 calls sent to an emergency call center (ECC) or a public safety answering point (PSAP) must include a valid callback number to enable the operator to reach the original caller if the call is lost.

But for older systems, compliance can often be a gray area depending on the system's age, when it was last updated and the scale of the update. The Federal Communications Commission (FCC), for its part, said it considers upgrades to core multiline hardware or software systems to be sufficient enough to place these systems under the oversight of its regulations. To minimize risk, companies should consult with appropriate legal counsel.

RAY BAUM'S Act mandates that calls placed to 911 provide a dispatchable location, which the FCC defines as a "validated street address of the 911 calling party, plus additional information, such as suite, apartment or similar information necessary to adequately identify the location of the caller."

In cases where building access is restricted, it's critical that front-desk security personnel are aware that a 911 call was placed from within the building and can identify the caller's actual location.

911 compliance lags

Unfortunately, not every company adheres to regulations. According to Metrigy's "Employee Engagement Optimization: 2025" study of 400 companies, just 64% of organizations with offices in the U.S complied with both Kari's Law and RAY BAUM's Act. This number has remained virtually unchanged over the last several years.

Reasons for not following the laws vary, but are usually attributable to a lack of understanding and a view that older systems are grandfathered in and thus compliant. In addition, some organizations don't invest in the resources needed to properly evaluate and ensure compliance, or they may be unfamiliar with state and local requirements, including Alyssa's Law. Now on the books in 11 states, Alyssa's Law requires school districts to install panic alarms within all public school buildings that can be activated in the event of an emergency.

Achieving 911 compliance

Fortunately, both unified communications (UC) vendors, as well as third-party software suppliers, offer tools to provide compliance and manage employee location and 911 call routing. These range from apps that track employee location in real time to those that ensure that location information is shared both with on-site personnel and ECC/PSAP operators.

In cases where a 911 caller's location can't be pinpointed, the software typically routes the call to a national call center that attempts to determine the caller's location before contacting the appropriate ECC.

Preparing for Next Generation 911

UC providers are also actively supporting Next Generation 911 (NG911). Here, endpoints learn their location from network components or other devices and then send that information along with the 911 call. Emerging NG911 capabilities include text-to-911, where available, and the ability to share information with first responders, such as exit locations, elevators and even security camera footage.

For remote workers, most services require users to configure a dispatchable location. The UC software validates the address is correct and prompts users to update their locations when it detects a change in the network environment.

The reality for companies trying to ensure 911 compliance is that most 911 calls are placed from personal or company-provided cellular phones.

Mobility continues as a pain point

The reality for companies trying to ensure 911 compliance is that most 911 calls are placed from personal or company-provided cellular phones. In these cases, because the call isn't handled by the enterprise phone system or UC as a service (UCaaS) provider, there may be no way to transmit accurate caller location or to notify on-site personnel that an emergency call has been placed.

Some 911 management providers can link personal or company-provided cellphones to office locations, but these products aren't widely deployed. Metrigy found that only 18% of companies use third-party platforms for 911 call and location management.

Services such as Cisco Webex Go and Microsoft Teams Phone Mobile can connect a cellphone's native dialer with a company's UCaaS environment, but emergency calling capabilities can vary by carrier, country, configuration and device type. IT teams should verify whether these services can transmit dispatchable location, route calls to the appropriate ECC/PSAP and notify on-site personnel before treating them as part of a 911 compliance strategy. Again, it's best to consult legal counsel to determine risk.

Education, tools can help

To help reduce 911 compliance challenges and make it possible to navigate 911 in a hybrid work environment, consider the following steps:

• Ensure compliance with appropriate federal, state and local laws.
• If you are still relying on older systems, evaluate the need to make them comply with Kari's Law and RAY BAUM'S Act.
• Deploy available 911 management tools from your UC providers, supplementing them with third-party specialty tools as needed.
• Determine and address the risk of mobile 911 calls.
• Educate users about how 911 calls are handled across all work locations.

Irwin Lazar is president and principal analyst at Metrigy, where he leads coverage on the digital workplace. His research focus includes unified communications, VoIP, video conferencing and team collaboration.