It looks like MSHA intends to force the issue with mines that don't install or at least order systems.

Will MSHA issue citations for noncompliance with the PPL?

No. However, the PPL provides guidance on how MSHA will implement the MINER Act requirements for post-accident communications and electronic tracking. MSHA will issue citations for noncompliance with the MINER Act.

MSHA hasn't mentioned a precise timeline for installations except for the following: