Kari's Law and RAY BAUM's Act: A Checklist for Hotel and Motel Owners

Two federal rules shape how 911 has to work on a hotel or motel phone system: Kari's Law and Section 506 of RAY BAUM's Act. Both are about the same moment. A guest picks up the room phone in an emergency, and the call needs to go through on the first try and send help to the right door.

Below is what each rule asks for, then a checklist to work through with your phone provider.

This isn't legal advice. It is a summary written for property owners. For questions about your specific obligations, talk to an attorney or contact the FCC directly.

What Kari's Law requires

The FCC's rules implementing Kari's Law took effect on February 16, 2020. They apply to multi-line telephone systems (MLTS) that are manufactured, imported, sold, leased or installed after that date. A phone system with a line in every guest room is a multi-line telephone system.

The rules ask for two things:

Direct 911 dialing. A guest has to be able to dial 911 without a prefix. No "dial 9 for an outside line" first.
Notification to a central location. When someone dials 911, the system has to alert a central location where someone is likely to see or hear it. On most properties, that means the front desk.

What RAY BAUM's Act Section 506 requires

Section 506 is about location. When a 911 call comes from a multi-line system, it has to carry a dispatchable location: the street address plus the extra detail responders need to find the caller, such as building, floor and room number.

Fixed devices, like a phone mounted in a guest room or sitting on the front desk, were covered starting January 6, 2021.
Non-fixed devices used on the premises, like a cordless or Wi-Fi handset carried by housekeeping or maintenance, were covered starting January 6, 2022.

A street address alone doesn't help much when a responder is facing a hundred motel doors. Room-level location is the point.

The checklist

Work through these with whoever runs your phone system. If you can't tick a box, ask why.

1. Direct 911 dialing from every room phone

A guest can dial 911 with no prefix from every room phone, and lobby and back office phones work the same way.
If your system still uses 9 for an outside line, dialing 9-911 also reaches 911. That is a common safeguard, not a substitute for direct dialing.

2. Front desk alert on every 911 call

When any phone dials 911, the front desk is notified right away.
The alert shows which room or extension placed the call.
There is a plan for overnight hours or times the desk is not staffed, such as a manager's phone or mobile app also receiving the alert.

3. Room-level location for every device

Each room phone sends its own dispatchable location, not just the property address.
Multi-building properties include the building in the location.
Cordless and Wi-Fi handsets used on the property have a location plan too.
When rooms are renumbered or phones are moved, the location records are updated.

4. Elevator and fire panel lines

Elevator emergency phones and fire alarm panel lines are on your list of lines that cannot go down.
Any change to those lines is coordinated with your alarm monitoring company and elevator service company.
Those lines are tested after any phone system change.

5. A coordinated test call

Call your local 911 center on its non-emergency line first. Ask how they want test calls handled and schedule a time.
Place the test from a room phone at the agreed time and tell the call-taker right away that it is a test.
Confirm the call-taker received the right room-level location.
Confirm the front desk received the alert.
Never place an unannounced test call to 911.

6. Staff training

Front desk staff know what the 911 alert looks like and what to do when it fires: send someone to the room, meet responders at the entrance, and point them the right way.
Night auditors, weekend staff and new hires get the same training, not just the day shift.

On a PJL system, direct 911 dialing, front desk notification and room-level dispatchable location are part of the setup. Hotels can keep their existing analog room phones through Grandstream gateways in the telco closet, and fire panel and elevator lines are planned into the conversion. See our hotel phone systems page or the motel phone systems page for more.

What about an older system?

The rules apply based on when a system was manufactured, imported, sold, leased or installed. If your property runs on an older system that predates them, how they apply is a question for an attorney. The practical answer is simpler. A guest who dials 911 from your room phone does not care when the system was installed, and replacing the system brings it under the rules anyway. If yours still needs "9 first," that is worth fixing.

Not sure where your property stands?

Tell us about your current system. We'll tell you what it would take to get direct 911 dialing, front desk alerts and room-level location working.

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Frequently Asked Questions

Does Kari's Law apply to my hotel or motel?

Kari's Law applies to multi-line telephone systems manufactured, imported, sold, leased or installed after February 16, 2020. A hotel or motel phone system with room phones is a multi-line telephone system, so any system put in after that date has to support direct 911 dialing and on-site notification. Ask your provider or an attorney how the rules apply to an older system.

What counts as a dispatchable location in a hotel?

A dispatchable location is the street address plus whatever extra detail responders need to find the caller, such as the building, floor and room number. For a hotel or motel, that usually means each room phone sends its own room-level location.

Can I test 911 from a room phone?

Only with the 911 center's agreement. Call your local 911 center on its non-emergency line first, ask how they want test calls handled and schedule a time. Never place an unannounced test call to 911.