The Requirements for Compliance

All companies that offer or use multi-line telephone systems (MTLS) are impacted by the law. This includes companies with one or multiple office locations, schools, universities, hospitals, hotels, warehouses, retail facilities, and financial institutions.

Depending on the physical connection type (wired or wireless) of the MLTS device used to make the call, as well as the location of the device (within the corporate brick and mortar, or remote in the public)  companies were required to meet two different implementation deadlines under RAY BAUM’S Act. Both deadlines have passed, meaning the time to get compliant is now:


By Jan. 6, 2021, companies must provide automated dispatchable locations for employees using fixed devices connected to a MLTS, such as a wired desk phone, on premise only.


The second deadline, which took effect on Jan. 6, 2022, impacts companies with employees using fixed or non-fixed devices, in both on-premises or off-premises locations associated with a MLTS. This included all device types and all locations including wireless or mobile phones on WiFi. For on-premise calls, companies remain on the hook to provide a  dispatchable location for devices, even if users had to manually enter dispatchable location details.

​For off-premise calls, companies must provide:

  • Automated dispatchable locations when possible
  • Manually-updated dispatchable locations
  • Enhanced location information — which may be coordinate-based, and must consist of the best available location utilizing any available technology, or even a combination of technologies.

Companies that cannot provide accurate dispatchable location information for both fixed and non-fixed devices may not be compliant with RAY BAUM’S Act Section 506.

Complying with the FCC’s requirements can be complex — and even more so if companies have hybrid or remote workers. But those not in RAY BAUM’S Act compliance risk endangering their employees, incurring fines or penalties, and facing wrongful death lawsuits.