Is your business compliant with Kari’s Law?

Kari’s law applies to any business equipped with a PBX or MLTS phone system, including:

  • Hospitals

  • Schools

  • Small and large companies (non-profit and for profit)

Background on Kari’s Law

On May 15, 2015, Governor Abbott signed Senate Bill 788 (Texas Kari’s Law). The law represents the culmination of efforts in the aftermath of the murder of Kari Hunt in a motel room in Marshall, Texas. Ms. Hunt’s 9-year-old daughter tried to call 9-1-1 for help four times from the motel room phone. The call never went through because she did not know to first dial “9” for an outbound line before dialing “9-1-1.” On March 1, 2016, Commission on State Emergency Communications Rule 251.16 (Direct Access to 9-1-1 Service) adopted to implement Kari’s Law went into effect.


  • Owners of multiple-line systems (MLTS) are required to ensure their phone systems are capable of dialing 9-1-1 without dialing “9” or another number for an outside line.
  • If the existing MLTS cannot be re-programmed or replaced to meet the direct access requirements, a one-year waiver form must be submitted prior to September 1 of each year.
  • Contact your MLTS provider to learn if your phone system is compliant or if a waver is needed. Most  new phones systems just need to be programmed (Not replaced), cost if any should be minimal.



On February 16, 2018, Congress enacted the federal Kari’s Law Act of 2017 (Federal Kari’s Law) requiring direct dialing 9-1-1 access and notification with respect to new MLTS. Kari’s Law Act of 2017, Pub. L. No. 115-127, 132 Stat. 326 (Feb. 16, 2018) (codified at 47 U.S.C. § 623). Federal Kari’s Law applies to a person (1) engaged in the business of manufacturing, importing, selling, or leasing MLTS; or (2) engaged in the business of installing, managing, or operating MLTS—which could include a business service user under Texas Kari’s Law.

The law and the Federal Communications Commission’s (FCC) regulations implementing the law are forward looking and apply only with respect to MLTS that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020 (see 47 C.F.R. § 9.17(b)).

Federal Kari’s Law does not alter the authority of State commissions or other State or local agencies with jurisdiction over emergency communications, if the exercise of such authority is not inconsistent with the federal law.


Effective January 6, 2020, FCC rules implementing the federal Ray Baum’s Act require MLTS to provide “dispatchable location” for each 9-1-1 call, defined as: “A location delivered to the [public safety answering point] with a 911 call that consists of the validated street address of the calling party, plus additional information such as suite, apartment or similar information necessary to adequately identify the location of the calling party.” (47 C.F.R. § 9.3As with Federal Kari’s Law, dispatchable location requirements apply to all MLTS that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020.

For fixed MLTS devices* the compliance deadline is January 6, 2021. For non-fixed MLTS devices* the deadline is January 6, 2022, if technically feasible; otherwise provide either end-user manually updated dispatchable location, or alternative 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.

The FCC afforded MLTS providers flexibility in providing alternative location information when providing dispatchable location is not feasible or cost-effective. “[S]o long as the level of detail is functionally sufficient to enable first responders to identify the location of a 911 caller in that environment. . . . In large multi-story buildings, this should normally include floor level and approximate location on the floor (e.g., building quadrant).” (Report and Order paras. 155-156.)

* “Fixed” MLTS devices are devices that connect to a single end point (e.g., a desk or office phone) and are not capable of being moved to another endpoint by the end user, although they may be capable of being moved to a different endpoint by a professional installer or network manager. “Non-fixed” MLTS devices are devices that the end user can move from one endpoint to another without assistance, and includes both on-premises and off-premises devices.

Additional information: For more information on Federal Kari’s Law and Ray Baum’s Act, please visit:


Both Texas and Federal Kari’s Laws and regulations require notification of a 9-1-1 call made from an MLTS in order to facilitate emergency response.

Texas: Texas Kari’s Law requires a business service user to configure their MLTS to provide a notification to a central location on the site of the residential or business facility from where an MLTS 9-1-1 call is made; provided the notification can be provided without an improvement to the MLTS’s hardware. The business service user is not required to have a person available at the central location to receive such notification.

Per CSEC Rule 251.16, a business service user may provide notification to an “additional location,” defined as an optional location, other than a central location, that receives notification of a 9-1-1 call that should be staffed 24×7 with personnel that can assist emergency first responders in accessing the residential or business facility from which a 9-1-1 call is made and determining the location of the 9-1-1 call, e.g., Campus Police, Security Office.

Federal: MLTS must be configured to notify a central location on-site or off-site where someone is likely to see or hear the notification. Examples of notification include conspicuous on-screen messages with audible alarms for security desk computers using a client application, text messages for smartphones, and email for administrators. Notification shall include, 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 public safety answering point (PSAP) with the call to 911; provided, however, that the notification does not have to include a callback number or location information if it is technically infeasible to provide this information (47 CFR § 9.3).

NOTE: Notwithstanding that Federal Kari’s Law’s notification requirement applies only to MLTS installed after February 16, 2020, CSEC recommends existing MLTS to be configured to provide the required notification if such can be done without an improvement to the MLTS’s hardware.

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A Message from Hank Hunt on Kari's Law