The 111 Contact Code

The 111 Contact Code ensures that venerable users who are more likely to need to contact 111, and who have a phone service that doesn’t work in a power failure, and have no means to contact the 111 emergency service. Digital Island is committed to the health and safety of its customers, and has collaborated with the New Zealand Commerce Commission and the New Zealand Telecommunications Forum to establish this code.

Services provided by Digital Island that may not function during a power failure

The following telephony services provided by Digital Island may not function during a power failure at the customer premises, unless that premises has backup power such as an uninterruptible power supply and/or generator:

  • Telepo Cloud PBX
  • Cloud Contact Center Services
  • SIP phone lines
  • Cloud Calling for Microsoft Teams
  • Voice Now

Devices that may not function during a power failure

The following physical devices may not function during a power failure:

  • Deskphones and DECT handsets
  • Softphones installed on a computer (eg Telepo app)
  • PABX Systems

In addition, the following hardware that the above equipment relies on to provide power and/or data communications may not function during a power failure:

  • UFB/Fibre ONTs
  • Routers
  • Switches (With or without Power over Ethernet)

Alternative means of contacting emergency services during a power failure

We recommend keeping a charged mobile phone on hand to dial 111 emergency services in the event of an emergency. If you do not have unrestricted access to a mobile phone, then you may be eligible to register as a vulnerable consumer by following the process below.

Criteria for becoming registered as a “Vulnerable Consumer”

To be covered by the 111 Contact Code and apply to become registered as a “Vulnerable Consumer”, a person must

  • be at particular risk of requiring the 111 emergency service (either now or sometime in the near future) due to health, safety or disability reasons; and
  • in the event of a power failure, not have a means to contact the 111 emergency service at the customer premises that can work for a continuous 8-hour period i.e. a mobile phone.

How the process works

If you feel you or someone at your company qualifies to be registered as a vulnerable consumer, please fill out the form below or contact Digital Island. Once you have downloaded the form and sent it to us at, with subject “Vulnerable Customer Application”, your application will be considered and we will contact you to discuss your application further.



If your application is approved, Digital Island will provide your premises an appropriate means of contacting the 111 emergency service in the event of a power failure at your premises for a minimum of 8 hours during a power failure. This equipment will be provided free of charge, and we will check every 12 months to ensure it remains necessary and fit for purpose.

No telecommunications provider in New Zealand is permitted to deny or cease offering retail landline services to a customer on the basis that they know or suspect that a customer may be a vulnerable consumer.