Two federal laws add obligations that consumer VoIP service does not carry. Kari's Law requires that a user be able to initiate a call to 911 directly from any station equipped with dialing facilities, without an additional digit, code, or prefix such as the trunk-access digit 9, even where other outbound calls still need one [3]. It applies to a multi-line telephone system manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020 [5]. The same rule requires a notification to a central point at the facility, or to another person or organization anywhere, sent at the same time as the call, without delaying it, and to somewhere a person is likely to see or hear it [3].
What counts as a multi-line telephone system
The definition is deliberately wide, covering network-based and premises-based systems including Centrex and VoIP along with PBX, hybrid, and key telephone systems, whether the operator is a business, a government agency, or a nonprofit [2]. The FCC read it to include cloud-based technology and over-the-top applications, and to include enterprise systems that allow outbound calls to 911 without giving the 911 center a way to call back [5].
The dispatchable location deadlines by device type
Section 506 of RAY BAUM'S Act produced a schedule keyed to where the device sits. On-premises fixed telephones had to provide automated dispatchable location by January 6, 2021, while on-premises non-fixed devices had until January 6, 2022 with a fallback to manual end-user updates or alternative location information. Off-premises devices share that 2022 date, and where automatic location is not technically feasible they may rely on manual updates or on enhanced location information, which the rule allows to be coordinate-based [3].
What compliance looks like in an admin console
Microsoft Teams is a useful illustration because its model maps onto the rule almost directly. Teams keeps an emergency address, meaning the civic street address, separate from a place, meaning a floor or office number, and joins the two into an emergency location with its own identifier that gets assigned to a user or a site [6]. An address has to be marked validated before it can be assigned, and dynamic emergency calling requires a geo code on that address, which is why Microsoft advises creating addresses through the map search in the Teams admin center [6]. Dynamic emergency calling is available across Microsoft Calling Plans, Operator Connect, Teams Phone Mobile, and Direct Routing [6].