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Emergency Calling: Kari’s Law and RAY BAUM’S Act Posture

Orbit does not support emergency calling. Outbound calls to the emergency short codes — 911, 112, 999, 000 — are rejected before they reach a carrier, at every dispatch layer. If you buy Orbit CCaaS seats to replace a PSTN phone system, the legal duties that a phone system would have absorbed become yours: you must tell your end users, and you must give them another way to reach emergency services. This page is the disclosure guide — it names the statutes, states what Orbit does, and hands you the mitigation list to implement for your deployment.

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1. What the emergency-calling surface actually ships

Every outbound voice send passes one shared dial-plan matcher before billing, trunk selection, or carrier dispatch. The matcher strips formatting, international-dial prefixes, and trunk prefixes, then compares the surviving digits against the blocked short-code set: Common dial variants are normalized before comparison — bare digits, a + prefix, the NANP country code (1911, +1911, 1-911), trunk prefixes (0112, 00112, 011911), and formatting characters ((911), 9-1-1) all collapse to the same short code and are blocked. A load-bearing length guard keeps real numbers safe: a prefix is only collapsed when what remains is exactly the length of a known short code, so a legitimate number that merely starts with 1911 (for example +19115551234) passes through unchanged. There is no tenant toggle for this block, and it is not a compliance gate you can configure — it is the product’s shipped behavior at every voice dispatch point: the send-voice API, the voice-gateway dispatcher, and the Jambonz dial-plan router. The full table, the normalization rules, and the per-layer wiring are in Emergency calling.

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2. What “emergency calling is not supported” means legally

Two US statutes govern what a multi-line telephone system owes its users on an emergency dial:
  • Kari’s Law (47 U.S.C. § 623; FCC rules at 47 CFR § 9.16) — a phone must reach 911 without a prefix (“dial 9” or any access code), and the system must notify a central on-site location (a security desk, an operator console) when a 911 call is placed. Applied since February 16, 2020.
  • RAY BAUM’S Act (Section 506; FCC rules at 47 CFR § 9.16 — enforcement against the non-fixed, off-premises devices since January 6, 2022) — a 911 call must carry a dispatchable location (street address plus floor, suite, or room — enough for a responder to find the caller) automatically, without the caller stating it.
Both statutes apply to the operator of the phone system — an MLTS (multi-line telephone system) seller, installer, or operator. If you deploy Orbit CCaaS seats as the phone system for your organization or your customers, that duty lands on you, not on Orbit. And Orbit cannot currently satisfy either statute on your behalf: an Orbit softphone cannot place a 911 call at all, so there is no direct-911 dial, no on-site notification flow, and no dispatchable-location transmission — none of the three pieces can be delivered by the platform today. The posture, then: disclosure is your obligation, not a platform gate. Orbit blocks the dial and returns a stable error code (below); telling your agents, keeping a compliant fallback path per site, and posting what to do in an emergency are the tenant-owned controls that follow. If your deployment is one where the statutes apply — a contact center sold as a PSTN-phone replacement for US sites is the clearest case — ship the mitigations in the next section as part of go-live, not as a follow-up. Other jurisdictions carry analogues — Ofcom’s GRN framework in the UK, the EU’s European Electronic Communications Code — but the US pair is the pair CCaaS buyers most often walk into cold, and the mitigation shape is the same everywhere: another way to reach emergency services, disclosed prominently. None of these involve Orbit routing an emergency call — they put the duty on your deployment, where it belongs.
  • Post signage at every seat. A printed notice at each agent station: “This phone cannot dial emergency services. In an emergency, use the site landline at [location] or a mobile phone.” Signage is the cheapest disclosure and the one auditors photograph.
  • Keep a PSTN fallback line per site. One traditional landline (or a mobile-on-desk) per physical location, reachable without Orbit in the path. This is the actual emergency path — test it on your drill schedule, not at the moment of need.
  • Treat emergency-address records as metadata, not routing. You can register an emergency address and per-device dispatchable locations against an owned number (GET /numbers/{id}/emergency-address and …/emergency-address/location — see the Numbers API and Emergency address). Store them as the record of where a number sits; do not treat them as live PSAP routing. Orbit does not deliver calls to a PSAP, so an address on file is evidence for your own records, not an E911 capability.
  • Rehearse the block. The 933 drill destination at E911 emergency drill mode lets agents practise the “cannot dial 911 — use the fallback line” flow end-to-end without touching a live PSAP.
  • Disclose at onboarding. Put the limitation in agent training and your end-user terms from day one — a user who learns the block at the moment of an emergency is the failure this page exists to prevent.

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4. Detector surface — the stable error code

Your app does not need to re-derive the block. Every voice dispatch layer returns the same error, with HTTP 422:
Branch on error.code === "EMERGENCY_CALLING_NOT_SUPPORTED" — never on the human-readable message — and show the caller the fallback path (“call 911 from a regular phone”) instead of retrying. The full response shape, the masked-destination details payload, and the audit-log record the attempt writes are in the error-code section of Emergency calling.

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5. Surface this at go-live — the onboarding touchpoints

This limitation is a go-live checklist item, not a discovery item. The operational checklists already require it; this page is the legal posture behind the checkbox. Run it through both: Add these three to the sign-off a compliance owner completes before cutover: signage posted at every seat, the per-site PSTN fallback in place and tested, and the disclosure recorded for your end users. Until those are done, the deployment is not ready to carry seats that a 911 dial could come from.

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See also