In late July 2025, the FCC released a new fact sheet, FAQ, and blog by Public Safety and Homeland Security Bureau Chief Zenji Nakazawa — all aimed at clearing up persistent confusion around Enhanced 9-1-1 (E9-1-1) compliance obligations for multi-line telephone systems (MLTS). The message is clear: there’s no such thing as being “grandfathered in” forever. If your organization is operating an MLTS, even one installed years ago, compliance with Kari’s Law and RAY BAUM’S Act may already be required due to upgrades, reconfigurations, or how your system handles 9-1-1 calls.
Think your legacy system is off the hook? This blog clarifies the FCC’s guidance, who it applies to, and how to steer clear of costly compliance mistakes.
The FCC Is Cracking Down on E9-1-1 Misconceptions
A major theme coming out of the FCC’s action is this: compliance is not optional, and your MLTS system may be subject to these rules, even if it was installed before Kari’s Law or RAY BAUM’S Act took effect.
Whether you're a school district with an aging PBX, a hospital that just upgraded to cloud-based VoIP, or a hotel that added new extensions last year — this applies to you. The latest guidance reinforces that:
- There is no indefinite grandfathering for legacy MLTS systems.
- System changes such as upgrades, platform migrations, or even expanding coverage can trigger compliance obligations.
- The duty of care falls on any organization that operates an MLTS system to ensure that users can reach 9-1-1 directly and that calls include an accurate dispatchable location.
Key Takeaways from the FCC's Updated Guidance
Who Must Comply?
According to the FCC’s fact sheet and FAQs, any entity that operates an MLTS — including businesses, government agencies, schools, and healthcare providers — are subject to E9-1-1 rules once their system is “newly installed, manufactured, imported, offered for sale or lease, or sold or leased after February 16, 2020.”
However, even older systems must comply if they’ve been significantly upgraded or reconfigured. These could include:
- Switching to a cloud-based or hybrid platform
- Adding a new site or location
- Replacing key components like call servers or gateways
- Making configuration changes that alter how 9-1-1 is routed
Essentially, if your MLTS doesn’t look or behave exactly like it did pre-2020, it likely triggers compliance requirements.
Dispelling the “Grandfathered” Myth
Chief Nakazawa directly addresses this in his blog:
“Let me be clear: systems are not grandfathered in perpetuity. Many entities that initially thought they were exempt may no longer be.”
This misunderstanding has led to dangerous gaps in 9-1-1 availability. Whether due to confusion, outdated assumptions, or unclear vendor messaging, some organizations believe they don’t have to provide direct 9-1-1 dialing or dispatchable location. The FCC’s new materials aim to shut down that line of thinking.
What Does “Compliance” Actually Mean?
Under Kari’s Law, MLTS systems must:
- Allow users to dial 9-1-1 directly, without a prefix (like “9” for an outside line)
- Send a notification to a front desk, security office, or other appropriate location when someone calls 9-1-1
Under RAY BAUM’S Act, MLTS systems must:
- Transmit a “dispatchable location” with each 9-1-1 call. This includes street address, floor number, suite or room number, etc.
- Ensure the caller location is accurate, actionable, and updated as users move or systems change
The FCC reemphasizes that these are not “best practices” or “nice to haves” — they are requirements.
What Triggers New Compliance Obligations?
The FAQs outline several examples of when compliance may become mandatory:
- Transitioning from legacy PBX to VoIP or Unified Communications
- Expanding to new buildings or campuses
- Adding mobile endpoints or softphones that move across locations
- Replacing outdated on-prem systems with cloud-managed infrastructure
If your telecom environment has evolved, your compliance status likely has too.
What Should MLTS Operators Do Now?
- Conduct a Compliance Review
Evaluate your MLTS platform and determine whether it has undergone changes since 2020 that could trigger E911 obligations.
- Work With a Compliant Provider
Ensure your provider supports direct dialing, 9-1-1 notifications, and dynamic dispatchable location—especially across mobile, hybrid, or cloud-based systems.
- Educate Your Internal Teams
Facilities, IT, and safety personnel all play a role in and have responsibility for 9-1-1 readiness. Make sure everyone understands what’s required.
- Test Your 911 Functionality Regularly
The FCC encourages MLTS operators to work with their local public safety answering point (PSAP) to test call routing and location accuracy.
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
Contact us to learn how Intrado can help support your E9-1-1 compliance journey.
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