E911 Address Registration for AI Numbers in 2026: Kari's Law and Ray Baum's Act Compliance

E911 compliance is the regulatory layer that AI voice deployments most often miss. Kari's Law took effect February 16 2020 and applies to every multi-line telephone system. Ray Baum's Act took effect January 6 2022 and adds dispatchable location requirements. Together they impose direct-dial 911, on-site notification, and street-address-plus-floor-plus-room precision. FCC fines start at $10k per violation per day, plus potential criminal liability if a 911 failure causes harm.

Background

Kari's Law is named for Kari Hunt, who was killed in a hotel room in 2013 because her daughter could not dial 911 directly (the hotel system required pressing 9 first). The law mandates two things on multi-line telephone systems (MLTS): direct dial of 911 with no prefix required, and on-site notification (front desk, security) when 911 is dialed.

Ray Baum's Act adds the dispatchable location requirement: when 911 is called from a fixed location, the system must convey the street address plus floor plus room number to the PSAP (Public Safety Answering Point). For non-fixed VoIP (mobile soft phones, traveling employees), the user must be able to update their location.

For AI voice deployments specifically, the question is whether the AI agent itself counts as an MLTS user. The answer is yes - if your AI handles inbound or outbound on a number that could conceivably be used for emergency dialing, that number needs a registered address. Pure inbound AI receptionists where the caller is on the PSTN are usually exempt; AI agents that dial out from a fixed business address are not.

Architecture

flowchart TD
    A[Provision DID for business] --> B[Register dispatchable location]
    B --> C[Street + floor + room]
    C --> D{User type?}
    D -->|Fixed AI agent| E[Static location registered]
    D -->|Mobile soft phone| F[User updates location on use]
    E --> G[911 call from DID]
    F --> G
    G --> H[Carrier transmits location to PSAP]
    H --> I[On-site notification triggered]
    I --> J[First responders dispatched]

The on-site notification piece is the operational hook: when 911 is dialed from a configured DID, the system has to alert a designated contact (front desk, security office) at the same time it places the 911 call.

CallSphere implementation

CallSphere registers dispatchable location for every tenant DID at provisioning time. Our onboarding flow (one of 90+ tools) collects street address, floor, and room information; we pass it to Twilio's Emergency Address API and tag the DID with the resulting Address SID. For tenants on Scale ($1499/mo, 10 numbers) with multiple physical locations, we register one address per DID and route 911 calls accordingly. On-site notification is implemented via a webhook that fires when the AI bridge sees a 911 dial - the webhook can ring a designated phone, send an SMS, or hit a Slack channel. Across all six verticals (Healthcare AI, Real Estate AI, Sales Calling AI, Salon AI, IT Helpdesk AI, After-Hours AI) the pattern is the same. Our 115+ DB tables include an emergency_addresses table with full audit trail. HIPAA + SOC 2 controls cover the address metadata. The 22% affiliate program credits Scale upgrades when tenants expand to multiple locations.

Build steps

1. Collect street address, floor, and room for every business location at tenant onboarding.
2. Submit to your carrier's Emergency Address API (Twilio: /v2/Addresses and /v2/EmergencyAddresses).
3. Tag each DID with the resulting Address SID; route based on the originating user.
4. Implement on-site notification: webhook that fires when 911 is dialed; ring the front desk or security.
5. For mobile soft phones, build a user-prompted location update flow ("Where are you right now?" before allowing 911).
6. Audit quarterly: pull the address-to-DID map, verify against your physical locations, fix drift.
7. Document the runbook for an actual 911 event: who gets paged, how is the AI agent paused, how is the post-incident report filed.
8. Train tenant admins on the legal scope; lawyers in your supply chain should sign off on the policy.

FAQ

Does Kari's Law apply to a single-line AI receptionist? Strictly, Kari's Law applies to multi-line systems. A single-line receptionist is generally exempt from the direct-dial requirement, but Ray Baum's Act dispatchable location still applies if the line is fixed.

What are the FCC fines? Up to $10k per violation per day. A 911 failure that causes harm can also trigger criminal liability for the operator.

How does dispatchable location work for traveling employees? For non-fixed users, the location must be updatable by the user. Common pattern: prompt the user to confirm location every X hours or every shift; allow override on the soft phone UI.

Does Twilio handle E911 by default? Twilio enables E911 only when you explicitly register an Emergency Address against a DID. Without registration, 911 calls from that DID will fail or route to the wrong PSAP.

Can AI agents themselves dial 911? Technically yes; practically no, in 2026. Most AI voice deployments hard-block 911 dial from the AI side and only allow human users to trigger it. CallSphere blocks 911 dial from AI agents by default.

Sources

• E911 Kari's Law and Ray Baum's Act Compliance - GCTI
• VoIP 911 and E911 Guide 2026 - IPComms
• Kari's Law and Ray Baum's Act - 911.gov
• FCC Dispatchable Location for 911 Calls
• Bandwidth E911 Regulations Guide

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