If your enterprise uses Microsoft Teams for phone calls, you operate a multi-line telephone system (MLTS). That means federal E911 regulations apply to you — specifically, Kari's Law and Section 506 of RAY BAUM's Act.
These aren't suggestions. They're federal law, enforced by the FCC. Non-compliance isn't just a regulatory risk — it's a life-safety risk. If someone dials 911 from your Teams Phone and the emergency dispatcher can't identify their location, the consequences can be fatal.
This guide explains what the laws require, how they apply to Microsoft Teams, and how to audit your compliance.
What E911 Compliance Means for Microsoft Teams
Microsoft Teams Phone is an MLTS — a multi-line telephone system. The FCC regulates MLTS under two federal laws:
Kari's Law (effective February 16, 2020) — named after Kari Hunt, who was killed by her estranged husband in a hotel room while her 9-year-old daughter tried to call 911 but couldn't connect because the hotel phone required a "9" prefix. Kari's Law requires:
- Direct 911 dialing — no prefix required. Users must be able to dial "911" and connect directly. Any system that requires "9-911" or "8-911" is non-compliant.
- On-site notification — when a 911 call is placed, a designated location (security desk, front desk, facilities office) must be notified simultaneously, so on-site personnel can assist emergency responders.
RAY BAUM's Act Section 506 (effective January 6, 2021) — requires dispatchable location for 911 calls. "Dispatchable location" means a location specific enough for emergency responders to find the caller — typically building, floor, and room or area. A civic address alone (e.g., "123 Main Street") is not sufficient for a multi-floor building. The PSAP (Public Safety Answering Point) must receive a dispatchable location with the 911 call.
For remote and mobile users, RAY BAUM's Act requires dynamic location — the location must update in real time as the user moves between networks (office, home, coffee shop, hotel).
Kari's Law Explained
Direct 911 dialing. In Teams, this is configured through emergency call routing policies. The emergency number "911" must route directly to the PSTN without any prefix or access code. Teams supports this natively — but it must be configured correctly. If your dial plan includes a rule that requires "9" for outside lines, you must ensure that "911" is exempted and routes directly.
How to check: Pick up a Teams phone (or open Teams on desktop) and dial "911". If it connects to emergency services, you're compliant. If you hear a second dial tone or get an error, you're not.
On-site notification. Teams supports on-site notification through emergency call routing policies. You configure one or more notification recipients (security desk email, SMS, or Teams channel) who are alerted when a 911 call is placed. The notification includes the caller's name, number, and location.
How to check: Review your emergency call routing policy in the Teams admin center. Is a notification recipient configured? Is the notification method tested and working?
RAY BAUM's Act Section 506 Explained
Dispatchable location. Teams uses network-based location discovery to determine a caller's location. You configure network sites (buildings), subnets, and wireless BSSID mappings in the Teams admin center. When a user makes a 911 call, Teams looks up their network location and transmits it as a PIDF-LO (Presence Information Data Format Location Object) XML block to the PSAP through your SBC or emergency routing service.
PIDF-LO can include:
- Civic address (street, city, state, ZIP)
- Building name
- Floor number
- Room or area
- Additional location information (ALI)
The granularity depends on your network configuration. If you've mapped subnets to floors and rooms, Teams can transmit floor-level or room-level location. If you've only mapped to the building level, that's all the PSAP receives.
Dynamic location for remote users. When a user works from home or a remote location, Teams uses their IP address and network information to estimate location. For precise location, users can manually set their emergency address in Teams. Enterprises should educate users to update their emergency address when working remotely.
How to check: Review your network site configuration in the Teams admin center. Are all subnets mapped to physical locations? Is the granularity sufficient (floor/room, not just building)? Do remote users know how to set their emergency address?
E911 in Direct Routing vs Calling Plans
Your E911 capabilities depend on your connectivity option:
Microsoft Calling Plans: Microsoft handles E911 based on the emergency address assigned to each user. The address is typically a civic address — building level, not floor/room. Dynamic location is limited. For small offices, this may be sufficient. For large multi-floor buildings, it's not.
Operator Connect: E911 handling depends on the operator. Some operators offer dynamic location; others provide only civic address. You're dependent on the operator's E911 capabilities.
Direct Routing: Full control. You configure PIDF-LO location routing through your SBC, with network-based dynamic location in Teams. You can achieve floor-level or room-level granularity. You control the emergency call routing policy, the SBC's E911 handling, and the location database. This is the enterprise-grade approach.
For enterprises in multi-floor buildings, campuses, or distributed sites, Direct Routing gives you the E911 control you need. Calling Plans' civic-address-only E911 is insufficient for RAY BAUM's Act compliance in complex environments.
How to Audit Your E911 Compliance
A thorough E911 audit checks six areas:
1. Direct dialing configuration. Verify that "911" routes directly to emergency services without any prefix. Test with an actual 911 call (coordinated with your PSAP — call their non-emergency line and ask to test).
2. On-site notification setup. Verify that a notification recipient is configured and receives alerts when 911 is called. Test by placing a 911 test call and confirming the notification arrives.
3. Dispatchable location granularity. Review your network site and subnet mapping. Is location mapped to building level only, or floor/room level? For RAY BAUM's Act compliance in multi-floor buildings, you need at least floor-level granularity.
4. Emergency call routing policy. Verify that emergency call routing policies are correctly configured and assigned to all users. Check that the policy routes 911 calls to the correct PSTN destination through your SBC.
5. SBC PIDF-LO transmission. For Direct Routing, verify that your SBC is configured to transmit PIDF-LO location data with 911 calls. Test with your PSAP to confirm they receive the dispatchable location.
6. Remote user coverage. Verify that remote and mobile users can set their emergency address in Teams. Educate users on how to update their address when working from a new location.
Common Compliance Gaps
We see these gaps repeatedly in E911 audits:
- Prefix still required for 911. A dial plan rule from the legacy PBX era requires "9" for outside lines — and "911" isn't exempted. Users must dial "9-911", which is non-compliant.
- No on-site notification configured. The emergency call routing policy exists but no notification recipient is set up. Security desk doesn't know when 911 is called.
- Only civic address, no floor/room. Network sites are mapped to building level only. The PSAP knows the building but not the floor. In a 20-story building, that's not dispatchable.
- Remote users not covered. No policy or education for remote users. When someone dials 911 from home, Teams may transmit the corporate address — not the home address.
- SBC not configured for PIDF-LO. The SBC handles voice traffic but isn't configured to transmit location data with 911 calls. The PSAP receives the call but no dispatchable location.
Any of these gaps is a compliance failure. All of them are fixable.
Get a Free E911 Compliance Audit
We offer a free, no-obligation E911 compliance audit for enterprises using Microsoft Teams Phone. We check all six areas above and provide a written report with your compliance status, identified gaps, and a remediation roadmap.
Request your free E911 compliance audit — find your gaps before an auditor does.