Kari's Law requires hotel phone systems to let anyone dial 911 directly, with no "9" or other prefix, and to alert someone on site, such as the front desk or security, when a 911 call is placed. A related federal rule under RAY BAUM'S Act also requires those calls to carry a dispatchable location (the street address plus details like the floor and room) so responders know where to go.
Why the law exists
In 2013, Kari Hunt was killed in a motel room. Her young daughter tried to call 911 four times, but the motel's phone system required dialing 9 for an outside line, so none of the calls went through. The federal law that followed carries her name. The FCC's implementing rules took effect for new systems on February 16, 2020.
Hotels sit right at the center of this law. The FCC names hotels, alongside office buildings and campuses, as typical places where multi-line telephone systems (MLTS) are installed. If your property has a PBX, a hosted phone system or any setup where many extensions share outside lines, it is an MLTS.
What Kari's Law requires
The rules break down into two obligations.
- Direct dialing. A guest or employee must be able to dial 911 from any phone on the system without a prefix, trunk-access code or extra digit. If guests dial 9 for an outside line, 911 still has to work on its own.
- On-site notification. When someone dials 911, the system must notify a central location where someone is likely to see or hear it, such as the front desk, a security office or a manager's mobile. The alert has to go out at the same time as the call and cannot delay it.
According to 911.gov, the notification should include a callback number and information about where the caller is. In practice that means a desk agent can see "911 call from Room 412" and send someone to meet responders at the right entrance and elevator.
The obligations are split. Manufacturers and vendors must ship systems that support direct dialing. The people who install, manage or operate the system, which often means the hotel and its phone vendor, must configure direct dialing and notification. The rules cover systems manufactured, imported, first sold or leased, or installed after February 16, 2020. Older systems that have not been replaced or reinstalled are generally outside Kari's Law, but any new system or major upgrade brings them in.
RAY BAUM'S Act: getting the location right
Kari's Law gets the call through. Section 506 of RAY BAUM'S Act makes sure the 911 center knows where the call came from. The FCC defines dispatchable location as the validated street address plus the extra detail, such as the floor or room number, that responders need to find the caller.
For a hotel, sending the street address alone isn't enough. A 600-room tower or a resort with several buildings needs the location to reach the room or zone. The FCC set these compliance dates for MLTS:
- Fixed devices (a wired room or desk phone that stays put): automated dispatchable location by January 6, 2021.
- Non-fixed devices on premises (softphones, tablets, mobile handsets used around the property): automated dispatchable location by January 6, 2022 where technically feasible. Otherwise the system can use a location the user updates manually, or alternative location information that meets FCC standards.
- Off-premises devices (a staff softphone used at home, for example): automated location by January 6, 2022 where technically feasible. Otherwise a manual update or enhanced location, which can be coordinate-based.
Both dates have passed, so this is a current requirement, not an upcoming one. The FCC says it will watch complaints about violations closely, and 911 centers can raise problems with the FCC's Public Safety and Homeland Security Bureau.
A quick compliance check for your property
Pick up a phone in a guest room, the lobby, the back office and the kitchen, and walk through these questions with your phone vendor or IT lead:
- Does 911 connect from every phone and device without dialing 9 first?
- Does the call come with a location that names the building, floor and room, not just the street address?
- Who gets notified when 911 is dialed, and is that person always on shift, including overnight?
- Does the notification show the room or area and a callback number?
- Does notification reach the right person if the front desk is unstaffed, for example by text or a staff mobile?
- Are tablets, softphones and mobile handsets registered to the right location, and is that kept up to date when devices move?
- Is the location data correct after renovations, room renumbering or a new wing?
- Do you test 911 routing on a schedule, coordinated with your local 911 center?
If any answer is "I'm not sure", that is the place to start. Most gaps show up at a change: a new system, a migration to cloud or VoIP, adding tablets, or room renumbering after a renovation.
See how HotelGenie handles 911 calls
HotelGenie's E911 / NG911 service sends the caller's room-level location to the 911 center, alerts staff right away by SMS, email and voice, and lets responders call the caller back. It works with phone systems on T1, PRI or SIP trunks.
Explore E911 / NG911
What this means when you replace phones
Any project that replaces or reinstalls your phone system, including a move to cloud PBX, softphones or in-room tablets, puts you under the current rules. Build 911 into the project plan from the start, not as a final check before go-live. Ask every vendor to show you, live, a test 911 call from each device type: room handset, lobby phone, tablet and staff mobile. You should see what the 911 center receives and what your staff receive.
Also look past the minimum. Optional 911 call recording, alerts to several staff at once, and location labels that name a place staff know ("Front Elevator Lobby", "Room 1104 South Tower") all help your team respond faster in the first few minutes.
This article is general information, not legal advice. Confirm your property's obligations with counsel and your local 911 authority.
Kari's Law questions
Yes. Kari's Law applies to multi-line telephone systems, and the FCC names hotels as a typical place where they are installed. It covers systems manufactured, imported, first sold or leased, or installed after February 16, 2020.
Yes, a property can keep dialing 9 for outside calls. Under Kari's Law, though, 911 must also connect on its own from every phone on the system, with no prefix or access code.
The system must alert a central location, on site or off site, where someone is likely to see or hear it, such as the front desk or security. The alert goes out at the same time as the call, and 911.gov notes it should include a callback number and the caller's location.
A dispatchable location is the validated street address of the caller plus the extra details, such as floor and room number, that responders need to find them. Under the FCC's RAY BAUM'S Act rules, fixed phones on a multi-line system had to provide it automatically by January 6, 2021, and non-fixed devices by January 6, 2022 where technically feasible.
Sources
Regulatory details are from the FCC and 911.gov. Rules can change, so check the current text before making compliance decisions.
