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New Zealand Vulnerable Consumers

What is the 111 Contact Code?

The Commerce Commission in New Zealand has released the new 111 Contact Code to ensure that Vulnerable Consumers have access to an appropriate means of calling 111 emergency services in the event of a power outage. In doing so, the Code requires telecommunication Retail Service Providers to supply Vulnerable Consumers with an alternative solution to contact emergency services.

Devices and technologies that are impacted during a power cut

Newer landline services such as Voice over Internet Protocol (VoIP) rely on an active working broadband service, and will not work in the event of a power failure without an independent power source. This means that if there is an outage, unless you have a backup power source, you will not be able to call emergency services using Bandwidth services.

Alternative means to call 111 emergency services

In the event of a power failure, you could rely on alternative means to contact 111 emergency services that are available to you already, such as:

  • Having access to a mobile device with adequate mobile coverage, and which we strongly recommend you keep charged up at all times; or
  • The premises where our retail fixed voice services are being used receives  landline services via another provider that are not power dependent; or
  • You have an uninterruptible power supply (i.e. a battery back-up or generator) that will allow our retail fixed voice services to continue to operate during a power failure.

Who is a Vulnerable Consumer?

You will be eligible to apply for the Vulnerable Consumer status if the two following conditions are met:

  • You are at a particular risk of needing to call 111 emergency services for health, safety or disability reasons; and
  • You have no means to contact the 111 ES line at the premise where our retail landline service is being provided, or the means you have cannot be operated for a continuous 8-hour period in the event of an outage.

You will also have to provide sufficient evidence to support that you, or the person you are applying on behalf of, are at a particular risk of requiring 111 emergency services, such as:

  • a completed Notice of Potential Medically Dependent Consumer (MDC) Status form, which include a certification from a District Health Board (DHB), Private Hospital or GP; 
  • a protection order; 
  • a letter from a health practitioner; or 
  • documentation of impairment

It is also possible for you to appoint a nominated person who we can get in touch with to verify that you are at risk of requiring 111 emergency services. Please note that the nominated person must be someone who, by virtue of their occupation, is competent to give an opinion on whether you are at particular risk of requiring the 111 emergency service. For example:

  • A health practitioner, in case you are applying under the health or disability category.
  • A police officer, a currently registered social worker, a lawyer, or a family court judge in case you have applied under the safety category.

If you qualify, Bandwidth will provide you, at no cost, with a means to call 111 emergency services in the event of a power cut. 

Which is the process to qualify as a Vulnerable Consumer?

You need to fill in the full Vulnerable Consumer application form and submit it to us together with supporting evidence by: 

  • Emailing it to [email protected]; or
  • Calling us on +32 2808 0000 (to the attention of the Compliance Team)  between 10AM and 5PM local Belgian time (CET/CEST) from Monday to Friday; or
  • Posting it to: 

Att: Compliance Team 
489 Avenue Louise
1050 Brussels, Belgium

If you are unable to fill out the application form you can contact us as per above and we will assist you. Please ensure you provide us with all the relevant information in your correspondence, including your nominated person’s contact details.

Once we receive back a completed form, we will accept or decline your application as a vulnerable customer within 10 working days. If it is declined, we will inform you of the grounds for the rejection, and if it is accepted, we will provide you with an alternative means to contact 111 emergency services that meets your particular needs.

Complaints and disputes

If you or a consumer at your premises disagree with the decision or a dispute arises about any rights or obligations under the 111 Contact Code you can file a complaint with us by sending an email to [email protected].

If you have already made a complaint directly to us related to the 111 Contact Code or an application to be a Vulnerable Consumer, and you are not happy with the resolution, or five working days have passed and nothing has been resolved, you can ask the Telecommunications Dispute Resolution Scheme (TDR) to intervene at  TDR provides a free and independent service for residential and small business customers and engages with Bandwidth to find a resolution on your behalf. Please note that the account holder can raise a dispute with the TDR on their own behalf or that of another member residing at the premises where our service is being provided.

If you cannot resolve the matter through the TDR, you can raise a complaint directly with the Commerce Commission at [email protected], or phone the Commission’s Enquiries team on 0800 943 600.