Appendix C — E911 Compliance

Why this matters

When someone dials 911 from a phone on your platform, the platform routes the call to the right Public Safety Answering Point (PSAP) based on the registered service address for that number. Two pieces of US federal law govern this:

• Kari's Law (2020) — multi-line phone systems must allow direct 911 dialing without a prefix code (e.g., dialing 911, not 9-911). The platform handles this automatically; you don't configure anything.
• Ray Baum's Act (2021) — every phone number capable of dialing 911 must have a "dispatchable location" registered. A dispatchable location is more than a city/state — it's a street address, often including suite/floor information, that 911 can dispatch responders to.

Non-compliance is a federal violation. FCC fines can reach $10,000 per violation per day.

What you have to do

For every DID assigned to a tenant:

• A valid, current physical street address in the US
• That address must be registered with the platform (which we then submit to the 911 routing database)
• Address must be updated when the tenant moves locations or changes the physical site for any number

For multi-location tenants: each location's DIDs must have that location's address. A 5-office company with 50 DIDs split across 5 buildings = 50 DIDs configured with 5 different addresses.

Where to register addresses

Two places, depending on workflow:

Per-DID, in the DID Inventory

Numbers → DID Inventory → click Edit on a DID → fill the E911 section → save.

Use this when you're setting up DIDs one or two at a time.

Bulk via "Apply to All"

Numbers → DID Inventory → select multiple DIDs (checkboxes) → Bulk E911 Update → enter one address → confirm.

Use this when a tenant gets a batch of 20 numbers all for the same office.

From the partner-level E911 page

Settings → E911 (in some menu layouts; alternately under Numbers menu).

Shows every DID's E911 status across all your tenants. Filter by "Not Set" to find non-compliant numbers quickly. Critical to check this regularly.

E911 statuses

• Registered — address is on file and active. 911 calls will route correctly.
• Pending — address submitted, waiting for the 911 database to confirm. Usually clears within 1 hour. During this window, calls still try to route but may fail.
• Failed — address didn't validate. Usually a typo or a non-existent address. Fix the address and re-save.
• Not Set — no address on file. 911 calls from this number will fail. This is the dangerous one.

What a "valid" address looks like

• Real US street address with a building number
• Real city / state / ZIP
• For commercial buildings: include suite number, floor, or unit. "1234 Main St, Suite 200, Anytown, AR 72211" is much better than "1234 Main St, Anytown, AR 72211" because dispatchers can find the right floor.
• PO Boxes don't work. PSAPs can't dispatch to a PO Box.
• Virtual offices and registered agents don't work. The address must be where someone actually is when they call 911.
• No commas or special characters in city. Use "Saint Louis" not "St. Louis"; use "OFallon" not "O'Fallon" (some PSAPs reject the apostrophe).

What happens on a 911 call

1. Caller on a registered DID dials 911 from a softphone or desk phone
2. Platform recognizes the call and routes it to the 911 service provider
3. 911 service provider looks up the dispatchable location associated with that DID
4. Call connects to the PSAP that serves that location
5. Caller's name (CNAM) and address are displayed to the 911 dispatcher

If the DID isn't registered, the call fails or routes to a national emergency line that asks the caller for their address — defeating the purpose of E911.

What happens on a 911 call from a non-registered number

The call may:

• Fail outright (silent — caller hears nothing, or just dial tone, or "all circuits busy")
• Route to a default location (often your platform's default, which is wrong for the actual caller)
• Reach a PSAP but in the wrong jurisdiction (delays response)

Any of these can be life-threatening. Take this seriously.

Multi-location tenants

If your tenant has multiple sites:

• Each DID's E911 address should match the physical location where calls from that DID actually originate
• For mobile workers (softphones used from home), use the worker's home address
• For traveling workers, use the tenant's primary office address as a default — and tell the worker to use a real cellular phone for emergencies (not the softphone)

For tenants who are spread out, consider asking them to assign a "home DID" per worker so each worker's outbound caller ID is consistent and the E911 address matches their actual location.

Updating addresses when tenants move

When a tenant moves offices:

1. Get the new address from them
2. Bulk-update all their DIDs to the new address (DID Inventory → multi-select → Bulk E911 Update)
3. Verify status flips back to "Registered" within an hour
4. Notify the tenant the migration is complete

Don't forget. Old address means 911 dispatched to an empty office.

Emergency relocation indicator

Some softphones and desk phones support a "current location" indicator that overrides the registered DID location for the current call. Useful when a worker travels with their softphone. Configuration is per-phone-model and outside the scope of this manual — see your phone's documentation.

Where to get more information

• FCC E911 page — https://www.fcc.gov/general/9-1-1-and-e9-1-1-services
• FCC Kari's Law overview — https://www.fcc.gov/mlts-911-requirements
• FCC Ray Baum's Act overview — https://www.fcc.gov/multi-line-telephone-systems-mlts-direct-9-1-1-dialing

When in doubt, register the address. The penalty for over-registering is zero. The penalty for under-registering is potentially fatal.