The Federal Communications Commission (FCC or Commission) has issued a Notice of Proposed Rulemaking (NPRM) seeking comment on proposed direct dial and notification rules governing calls to 911 made from multi-line telephone systems (MLTS) and dispatchable location requirements for 911 calls from MLTS, fixed telephony providers, interconnected Voice over Internet Protocol (VoIP) providers, and other services.*

Bottom Line: The proposed rules would potentially require many large businesses and organizations to incur significant expense in order to comply. If adopted, the proposed rules would go into effect on February 16, 2020.


MLTS include legacy PBX, Centrex, and Key Telephone systems, Internet Protocol (IP)-based systems, and hybrid systems.** MLTS serve employees, residents, and guests of businesses and educational facilities, including office buildings, corporate parks, hotels, college campuses, and planned community developments. Emergency calls from MLTS stations generally only provide public safety answering point (PSAPs) the telephone or circuit number of the system’s outgoing trunk, and not the emergency caller’s individual station number, so PSAPs often find they are unable to locate the origin of an MLTS emergency call. The FCC’s enhanced 911 (E911) rules currently do not apply to MLTS. In 2003, the Commission considered applying E911 requirement to MLTS, but deferred to the states to address this issue, while reserving the option of acting in the event that states do not. To date, 23 states have enacted legislation that requires organizations over a certain size or purchasing a new PBX/MLTS system to implement E911 on the system.

The President recently signed into law two statutes addressing these issues: (1) Kari’s Law Act of 2017 (Kari’s Law), which requires implementation of direct 911 dialing and on-site notification capabilities in MLTS, and (2) Section 506 of RAY BAUM’S Act (RAY BAUMS’S Act), which requires the FCC by September 23, 2019 to conclude a proceeding to consider adopting rules to “ensure that the dispatchable location is conveyed with a 9-1-1 call, regardless of the technological platform used and including with calls from [MLTS].” Kari’s law applies to any person engaged in the business of manufacturing, importing, selling, or leasing MLTS, as well as any person engaged in the business of installing, managing, or operating MLTS. Under this law, such systems may not be installed, managed or operated unless 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. Anyone installing, managing or operating such a system must also configure the system to provide a notification to a central location at the facility where the system is installed or to another person or organization regardless of location, if the system can be configured to provide the notification without an improvement to the hardware or software of the system. Kari’s Law will apply to any MLTS manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020.


Direct Dialing and Notification for MLTS

Direct Dialing

The NPRM proposes direct dialing requirements that track the obligations in Kari’s Law. These requirements would apply to persons engaged in the business of manufacturing, importing, selling, or leasing MLTS, as well as persons engaged in the business of installing, managing, or operating MLTS.


The NPRM proposes, consistent with Kari’s Law, to require that a person engaged in the business of installing, managing or operating MLTS to configure it to provide a notification that a 911 call has been placed by a caller on the MLTS system. As proposed, the system configuration “must provide for the notification to be transmitted to a central location at the facility where the system is installed or to another person or organization regardless of location, if the system is able to be configured to provide the notification without an improvement to the hardware or software of the system.” This notification is intended to benefit callers, emergency responders, and MLTS management and staff by reducing confusion and speeding response time. Among other benefits of on-site notification, include enabling internal responders to confirm and assist the person who dialed 911 and provide notice that first responders are on the way, and allowing preparations to be made, including ensuring that access doors are unlocked, elevators are available, and hallways are unobstructed.

The Commission tentatively concluded that notifications contain at a minimum the following information: (1) the fact that a 911 call has been made; (2) a valid callback number; and (3) the information about the caller’s location that the MLTS conveys to the PSAP with the 911 call. The NPRM proposes to require that MLTS be configured so that notification is contemporaneous with the 911 call and seeks comment on whether there should be requirements relating to location, configuration, or staffing of notification destination points. It asks whether a destination point should be a location that is normally staffed or a location where on-site staff are likely to see or hear the notification. The Commission seeks comment on the costs of various options for implementing the notification requirement of Kari’s Law, noting that it does not believe Congress intended to impose staffing or monitoring requirements that would “impose unreasonable costs or limit the flexibility of MLTS installers, managers, and operators to develop efficient and cost-effective notification solutions that are appropriate to the technology they use, such as visual alerts on monitors, audible alarms, text messages, and/or email.” Rather than requiring staffing or monitoring, the Commission believes that allowing notifications to be directed to the points where they are likely to be seen or heard by existing staff achieves its goals “at a negligible cost above what an MLTS manager would already spend when purchasing an MLTS.”

Compliance Date

The proposed compliance date for regulations adopted in this proceeding is February 16, 2020.

Transitional Issues

The FCC seeks comment on whether to require MLTS installers, operators, and managers to notify callers how to dial 911 from grandfathered systems (e.g., by placing a sticker adjacent to or non-complaint MLTS devices).


The NPRM seeks comment on which entities should bear responsibility for violations of the proposed rules. The Commission proposes to apply a presumption that the MLTS manager bears ultimate responsibility for compliance with the proposed rules implementing Kari’s Law.

Cost/Benefit Analysis

The Commission states that most MLTS systems already are configured to meet the direct dialing and notification requirements of Kari’s Law, but seeks comment on the number of MLTS systems currently deployed that do not allow direct dialing of 911 and/or cannot be configured to provide notification of 911 calls to an MLTS manager. The Commission tentatively concluded that there will be no immediate costs or benefits associated with meeting the proposed requirements, but for systems coming into service after February 16, 2020, the FCC asked for comment on the costs and benefits of compliance. With respect to notification, the NPRM tentatively concludes that the costs of implementing the proposed requirements will not exceed the value of their benefits.

Dispatchable Location for MLTS and Other 911-Capable Communications Services

RAY BAUMS’S Act directs the FCC to consider rules requiring the conveyance of dispatchable location with 911 calls “regardless of the technological platform used.” Based on this directive, the NPRM considers adoption of dispatchable location requirements for MLTS and other 911-capable services.***


The FCC proposes to prohibit the manufacture, import, sale, or leasing of MLTS in the United States unless the system is pre-configured such that, when properly installed, the dispatchable location of the call will be conveyed to the PSAP with 911 calls. The Commission also proposes to prohibit the installation, management, or operation of MLTS in the United States unless the system is configured so that dispatchable location is conveyed to the PSAP with 911 calls.

The statute defines “dispatchable location” as “the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party.” The mobile E911 definition of dispatchable location further requires that the street address of the calling party be validated and, where possible, corroborated against other location information prior to the delivery of dispatchable location information by the commercial mobile radio service (CMRS) provider to the PSAP, and the NPRM seeks comment whether it should require similar validation for dispatchable location information associated with MLTS 911 calls.

The FCC tentatively concluded that it is feasible for 911 calls that originate from MLTS to convey dispatchable location to the appropriate PSAP, and asks whether new rules are necessary to ensure that communication service providers (such as fixed telephony, mobile carriers, and interconnected VoIP service providers) that complete 911 calls originating from MLTS convey dispatchable location. The Commission does not propose to require implementation of specific location technologies or solutions.

The NPRM seeks comment on the steps that an MLTS manage or operator must take, if any, to ensure that dispatchable location is conveyed to the PSAP, and whether it should allow alternatives to dispatchable location (e.g., x/y/z coordinates). The Commission also asks whether the National Emergency Address Database (NEAD) being developed by the major mobile carriers would assist MLTS manager and operators in providing dispatchable location and whether such managers and operators should be required to contribute to the operating costs of the NEAD as a condition of leveraging it.


The NPRM notes that there may be situations in which the value of dispatchable location to first responders is diminished due to the availability of on-site notification, and asks whether there are situations where service providers should be exempted from a dispatchable location requirement. Specifically, should providers be allowed or required to provide other types of location information such as coordinate-based information in addition to or an alternative to dispatchable location? If exemptions are allowed, the Commission asks whether it should require carriers to provide consumer disclosure regarding the limitations of their 911 capabilities.

Comments on the NPRM are due 45 days after it is published in the Federal Register, which has yet to occur. For business owners that own or operate MLTS, and for other communications service providers, there may be significant costs associated with implementation of the proposed rules. If you are interested in filing comments on the proposals in the NPRM, please contact Michael Bennet at


* Implementing Kari’s Law and Section 506 of RAY BAUM’S ACT; Inquiry Concerning 911 Access, Routing, and Location in Enterprise Communications Systems , Notice of Proposed Rulemaking, PS Docket No. 18-261; PS Docket No. 17-239, released September 26, 2018 (NPRM).

** In the NPRM, the FCC proposed to define MLTS to “include the full range of networked communications systems that serve enterprises, including circuit-switched and IP-based enterprise systems, as well as cloud-based IP technology and over-the-top applications.” The proposed definition also includes enterprise-based systems that allow outbound calls to 911 without providing a way for the PSAP to place a return call.

*** In addition to MLTS, the FCC examines four types of communications services that are currently required to provide 911 service to their customers: (1) fixed telephony; (2) mobile telecommunications; (3) interconnected VoIP service; and (4) Internet-based Telecommunications Relay Services (TRS). The NPRM also considers whether to adopt dispatchable location rules for other 911-capable services that are not currently subject to the FCC’s 911 rules.