E9-1-1 Compliance Challenges: Why Some Enterprises Keep Falling Behind

The Federal Communications Commission (FCC) enacted Kari’s Law and RAY BAUM’S Act to enable direct dial to 9-1-1 without prefixes, provide real-time notification to onsite personnel when 9-1-1 is dialed, and deliver precise dispatchable location information to emergency responders. But despite these mandates, a surprising number of enterprises still aren't fully compliant.

According to Metrigy’s 2023-2024 Workplace Collaboration study, only 62.7% of U.S.-based organizations reported full compliance with both Kari’s Law and RAY BAUM’S Act. We covered this and other data points in our joint whitepaper, “Why Duty of Care Requires a Proactive 9-1-1 Strategy.”

For those who are not compliant, perhaps they misunderstood the requirements, assumed their legacy systems were grandfathered in, or just hadn’t prioritized action. Let’s explore these and other reasons, as well as the implications of non-compliance, and how to resolve this dilemma.

The Compliance Gap: What's Holding Enterprises Back? 

Despite regulations being in place for several years now, there are various reasons why organizations remain non-compliant.

1. Lack of Awareness or Clarity

Some organizations incorrectly believe that older systems installed before the compliance deadlines are completely exempt in perpetuity — or at least as long as they have that same MLTS. It’s sometimes referred to as the “grandfather clause.”

In July 2025, the FCC released new information emphasizing the importance of compliance, including a blog post, fact sheet, and FAQ. These pieces shed more light on how Kari’s Law applies in the grandfather clause situation. While it’s true that some MLTS were exempt at the time based on manufacture or install dates, subsequent upgrades can trigger coverage by Kari’s Law. In fact, the FAQ states that any “upgrades to core MLTS software or hardware functions are considered to be of sufficient magnitude to bring an MLTS within the scope of the statute and rules.”

Other organizations simply don’t understand the technical and legal nuances of "dispatchable location" or onsite notification requirements. The FAQ explains the difference between fixed/non-fixed and on-premises/off-premises MLTS devices and how RAY BAUM’S Act applies to each. It also touches on what information should be included in notifications.

2. Complex IT Environments

As Metrigy noted in our joint whitepaper, today's calling infrastructure is more fragmented than ever:

• • 30% of enterprises now rely on cloud-based UCaaS platforms
  • Nearly 45% of in-office workers use hot-desking arrangements
  • Over 50% of employees work remotely at least part of the time

Without the proper solution, this mix of on-premises systems, mobile softphones, and cloud services creates a logistical headache for ensuring proper 9-1-1 call routing and location tracking — and consequently leaves companies exposed to the risks of non-compliance.

3. Lack of Ownership Across Departments

For some, compliance can fall through the cracks because it doesn’t fit neatly into a single team’s charter. IT, security, legal, and facilities teams may all play a role, but without a central owner, it’s easy for the issue to get deprioritized — until something goes wrong.

4. Inconsistent Vendor Capabilities

Not all telephony providers support dynamic location tracking or compliant call routing out of the box. Metrigy reports that only 16.1% of organizations have adopted third-party 9-1-1 management platforms to close these gaps. Most rely solely on tools provided by their UC vendors, which often fall short in hybrid environments.

5. Underestimating the Risk
   
   Each of the following risks are considerable on their own, but combined they pose a significant liability:
   
   
   • The potential for human harm, due to delayed or misrouted emergency responses
   • Legal and financial exposure, including FCC fines (up to $10,000 plus $500/day under Kari’s Law)
   • Reputational damage following a preventable emergency mishap

Why Comply? More Than Just a Legal Obligation

Beyond regulatory compliance, ensuring proper 9-1-1 access is a moral responsibility falling under an organization’s Duty of Care — an employer’s obligation to take reasonable steps to protect employees and visitors from harm. The conversation shouldn’t begin after an incident occurs. Non-compliance with Kari’s Law or RAY BAUM’S Act can result in fines, lawsuits, and insurance issues. Proactively addressing compliance helps limit legal exposure and protects your organization in the event of an emergency.

But at its core, compliance is about people. When an employee dials 9-1-1, they expect help to arrive — fast and accurately. Compliance ensures your workforce has easy access to 9-1-1 and responders know where to go and how to get in. It enables faster internal response, better incident management, and smoother collaboration with public safety agencies.

Don’t Wait for a Crisis

In an era of hybrid work, distributed teams, and mobile-first communication, 9-1-1 compliance is no longer a technical checkbox; it’s a vital part of organizational safety and business resilience.

The FCC’s recent messages about compliance demonstrate that the Commission is paying attention to the issue of non-compliance. Will it only be a matter of time until companies that have avoided compliance are scrutinized more closely?

Duty of care requires a proactive approach to 9-1-1 caller location management and call routing. That means working with trusted partners, auditing your systems, and investing in scalable solutions that protect people and reputations.

The Path Forward: Simplifying Compliance

Enterprises can overcome these challenges by adopting a robust E9-1-1 solution:

• Detect and update user location dynamically
• Route 9-1-1 calls based on current physical location — not IP address
• Support hybrid and mobile workforces seamlessly
• Notify internal stakeholders when a 9-1-1 call is made
• Ensure alignment with both current laws and emerging NG9-1-1 standards

By centralizing compliance across all locations, endpoints, and vendors, these platforms not only reduce risk, they also simplify day-to-day management for IT teams.

Intrado Can Help

Navigating compliance isn’t easy — especially when systems are complex and constantly evolving. Intrado offers E9-1-1 solutions designed to help your organization meet FCC mandates with confidence, ensuring that:

• Your users can reach help without delay
• Your 9-1-1 calls include critical location details
• Your compliance evolves with your infrastructure
  

Download the brochure to learn more or contact us to learn how Intrado can help support your E9-1-1  compliance journey.

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