Kari's Law and RAY BAUM's Act have been on the books since 2018, and the FCC's rules for business phone systems have applied since 2020. What has been limited is visibility into how well those rules are actually being followed. A bill that just passed the House is a step toward changing that, but it's often described as more than it is.
On April 21, 2026, the House passed H.R. 5201, the Kari's Law Reporting Act, by a vote of 405–5 (House roll call 127). As of October 2026, the bill is with the Senate Commerce Committee and is not yet law. As passed by the House, it would direct the FCC to publish a report within 180 days of enactment on how well multi-line telephone system (MLTS) manufacturers and vendors are complying with Kari's Law, including the obstacles they face and the FCC's recommendations (bill text).
In other words, the report is about the companies that make and sell phone systems. It doesn't direct the FCC to audit the organizations that run them. But it asks the same core questions every organization should already be able to answer: can users dial 911 directly, without a prefix, and does someone on site get notified when they do?
If you manage an enterprise communications environment, that makes this a good moment to check your own answers.
What the Bill Would and Wouldn't Do
The bill doesn't create new requirements. Direct dialing and notification have been required since February 16, 2020, for systems installed after that date, and the FCC's dispatchable location rules followed in 2021 and 2022 (FCC). What the bill adds is a public look at how well the equipment side of the market has kept up.
To date, the FCC's most visible 911 enforcement has involved carriers and 911 outages rather than individual organizations running their own phone systems. A public report on vendor compliance wouldn't change your obligations, but it would put more attention on whether the systems in the field actually meet them.
That attention matters. If the report finds widespread gaps in the systems vendors sold, it becomes harder for any organization running one of those systems to argue that the problem was unknown.
Why This Matters More Than You Might Think
It's tempting to view an oversight bill as bureaucratic housekeeping — just another report that lands on a shelf. But the context around this legislation suggests otherwise.
The bill passed 405–5. That kind of margin signals that emergency communications is one of the few areas with broad agreement in Congress. If the bill becomes law and the FCC's report shows widespread problems, expect pressure for follow-up action.
Where Compliance Breaks Down in Practice
The challenge for most organizations isn't a lack of awareness that these laws exist — it's the gap between initial configuration and ongoing reality.
When Kari's Law and RAY BAUM's Act first took effect, many organizations updated their phone systems to meet the baseline requirements. But enterprise communications environments don't stay static. Consider what's changed in your organization since you last verified your 911 configuration:
Office moves and renovations. If your team relocated floors, buildings, or campuses, the dispatchable location data tied to those endpoints may still point to the old address. A 911 call from the third floor that routes responders to the first floor isn't compliant — and it's dangerous.
Hybrid and remote work. Employees dialing from softphones at home, in coworking spaces, or on the road present a location data challenge that traditional MLTS configurations weren't designed to handle. If your system can't dynamically update location based on where the call actually originates, you have a gap.
Device and platform changes. Migrations to cloud calling platforms, new handset deployments, or the addition of Microsoft Teams or Webex calling can introduce 911 routing issues if emergency calling wasn't part of the migration plan. We see this regularly — organizations upgrade their communications stack and inherit a compliance gap they didn't know existed.
Shared and flexible workspaces. Hot-desking and hoteling mean that the person sitting at a given extension today isn't the same person who was there yesterday — and the location data needs to reflect where the call is happening, not where the device was originally registered.
Each of these scenarios is a real-world failure point, and none of them depends on what a federal report says. They're the gaps that show up during an actual 911 call.
Why Not Wait for the Report?
The bill still has to pass the Senate and be signed, and the report would come six months after that. Waiting for it means waiting on a timeline no one controls.
More importantly, the rules already apply. An organization that finds and fixes its gaps now is protected whether or not the bill becomes law, and whatever the eventual report says.
What to Do Right Now
If your organization operates an MLTS — whether that's a traditional PBX, a cloud calling platform, or a hybrid environment — here's where to focus:
Test your 911 call path. Use 933 for quick checks of the address and callback number on file, and schedule live test calls with your 911 center to confirm calls actually route correctly. Our guide to 911 testing with 933 and live test calls covers both. Don't assume the configuration from two years ago still holds.
Verify dispatchable location data. Walk your locations. Confirm that every floor, wing, and building has accurate location records tied to the endpoints deployed there. Pay special attention to any spaces that have been reconfigured since your last compliance review.
Address remote and mobile endpoints. If employees place calls through your corporate phone system from outside your facilities, the FCC's rules call for automated dispatchable location where technically feasible, and otherwise a manually updated location or the best available location (47 CFR 9.16). This is one of the most commonly overlooked gaps.
Review your notification workflow. Kari's Law requires on-site notification when a 911 call is placed. Confirm that your notification system is active, reaches the right people (security, front desk, facilities), and works across all call scenarios — including after-hours calls.
Document everything. A record of your testing, findings, and fixes is your evidence of due diligence, whatever happens with the bill.
Frequently asked questions
What is the Kari's Law Reporting Act (H.R. 5201)?
The Kari's Law Reporting Act is a bill the U.S. House passed 405 to 5 on April 21, 2026. It would direct the FCC to publish a report within 180 days of enactment on how well multi-line telephone system (MLTS) manufacturers and vendors comply with Kari's Law. As of October 2026, it is with the Senate Commerce Committee and is not yet law.
Does the Kari's Law Reporting Act create new 911 requirements for businesses?
No. The bill creates no new requirements and doesn't direct the FCC to audit organizations that run phone systems. Direct 911 dialing and on-site notification have been required since February 16, 2020, for systems installed after that date, and the FCC's dispatchable location rules followed in 2021 and 2022.
Why does 911 compliance break down after the initial setup?
Enterprise phone environments keep changing. Office moves and renovations, hybrid and remote work, migrations to cloud calling platforms such as Microsoft Teams or Webex, and hot-desking all change where 911 calls originate, while the location data tied to each device often stays the same.
How can an organization check its 911 compliance today?
Test the 911 call path with 933 and scheduled live test calls, verify dispatchable location data for every floor, wing, and building, cover remote and mobile endpoints, confirm the on-site notification reaches the right people after hours too, and document the results.
The Bottom Line
The Kari's Law Reporting Act isn't a new set of rules, and it isn't an audit of your organization. It's a sign that Congress wants to know whether the existing rules are being met. For enterprise organizations, the question isn't whether your systems should be compliant. That's been settled law for years. The question is whether they actually are, right now, across every endpoint and every location.
The organizations that can answer that question with confidence are in good shape no matter what the report eventually says. The ones that can't should start working on it today.
Need to know where you stand? Schedule a call with the 9Line team. We'll walk through your calling environment, identify compliance gaps, and help you build a plan to close them.
Related: Kari's Law and RAY BAUM's Act: The Plain-English Guide
