One NZ 111 Code Breaches: $1.1 Million Fine Explained
Most people don’t think twice about dialing 111 — until the call doesn’t go through. For years, One NZ failed to meet its obligations under the 111 Contact Code, leaving vulnerable customers without guaranteed access to emergency services — a failure that led to a $1.1 million fine from the High Court and a stark reminder of what happens when customer outreach falls short.
Fine amount: $1.1 million NZD ·
Number of breaches: 10 ·
Regulator: Commerce Commission ·
Judgment date: December 1, 2025
Quick snapshot
- One NZ fined $1.1 million by the High Court (Commerce Commission).
- 10 breaches of the 111 Contact Code admitted (Commerce Commission).
- Breaches involved information disclosure, record keeping, and customer outreach failures (Commerce Commission).
- Exact list of changes One NZ will implement (One NZ).
- Whether all affected vulnerable customers have been contacted (1News).
- Potential further penalties or investigations by the Commerce Commission (Commerce Commission).
- 2021–2025: One NZ breaches the 111 Contact Code repeatedly (Commerce Commission).
- April 15, 2024: Commerce Commission files court proceedings (1News).
- December 1, 2025: High Court orders $1.1 million fine (Commerce Commission).
- One NZ says it will implement changes to compliance processes (One NZ).
- Commerce Commission continues monitoring telco compliance (Commerce Commission).
- Vulnerable customers should check their 111 access and register for priority assistance (Bill Bennett).
Six key facts, one pattern: the regulator found a systemic failure in how One NZ handled its most basic emergency obligations.
| Label | Value |
|---|---|
| Regulator | Commerce Commission |
| Date of judgment | December 1, 2025 |
| Fine amount | NZ$1,100,000 |
| Number of breaches | 10 |
| Period of breaches | 2021–2025 |
| One NZ response | Accepted penalty, implementing changes |
What is the penalty for One NZ?
How much was One NZ fined?
The High Court ordered One NZ to pay a penalty of NZ$1,100,000 after the company admitted ten breaches of the 111 Contact Code. The court also ordered One NZ to contribute NZ$100,000 toward the Commerce Commission’s costs, according to 1News (NZ news outlet).
Why was the penalty set at $1.1 million?
Both the Commerce Commission and One NZ jointly recommended the final penalty of NZ$1.1 million, as recorded in the vLex legal database. The amount reflects the gravity of repeated breaches over several years, including failures that directly affected vulnerable customers reliant on landline connections for emergency calls.
Did One NZ admit to the breaches?
Yes. One NZ admitted to breaches relating to information disclosure, record keeping, and regular customer outreach, covering the period from 2021 to 2023. The Commerce Commission (New Zealand’s competition and consumer regulator) confirmed that the company cooperated with the investigation.
One NZ says the breaches did not affect its network or customers’ ability to reach emergency services, and no customers were shown to be harmed. But the Commission’s case was about compliance with the Code, not actual call failures — a distinction that matters for accountability.
The implication: One NZ faced a significant fine for administrative failures, but the company maintains that the 111 service itself remained operational. Still, the penalty signals that regulators expect strict adherence to the Code, regardless of whether a breach causes immediate harm.
What were the specific breaches of the 111 Contact Code?
What is information disclosure under the 111 Contact Code?
The Code requires providers to clearly communicate key information about consumers’ options for calling 111 during a power cut. One NZ failed to make annual disclosures for 2021 and 2022, according to the vLex legal database.
What record-keeping failures occurred?
One NZ did not maintain adequate records of communications with customers about their 111 access. The Commerce Commission’s case cited failures in record keeping that made it impossible to verify whether vulnerable customers had been informed of their options. Full details are in the Commission’s announcement.
How did One NZ fail in customer outreach?
One NZ did not conduct regular outreach to vulnerable customers to ensure they could reach 111. The Code requires providers to actively inform customers and maintain contact, but the company’s outreach fell short. The Commerce Commission described the failures as “endangering vulnerable consumers” when it filed proceedings in April 2024, as reported by 1News.
For vulnerable customers — those with medical conditions, disabilities, or no alternative phone — these failures meant they might not have known their landline could fail in a power cut. The Code exists precisely to prevent that gap.
The pattern: three types of compliance failure — disclosure, records, outreach — all stem from the same root: a lack of systematic attention to the specific needs of the most vulnerable customers.
How does the 111 Contact Code protect vulnerable customers?
Who qualifies as a vulnerable customer?
Under the Code, vulnerable customers are those who rely on landline connections for emergency calling and may lose service in a power cut without an independent power supply. This includes people with medical conditions, disabilities, or limited alternative means, as defined by the Commerce Commission.
What are the obligations of telcos under the Code?
Providers must give vulnerable consumers a no-cost way to call 111 during a power cut. If consumers have no other way of contacting 111, providers must supply a device that enables emergency calls for at least eight continuous hours at no cost. This can be a mobile handset, or in areas without mobile coverage, a battery backup for landline services, as explained by Bill Bennett (NZ telecommunications analyst).
Why is the Code important for emergency access?
The Code came into effect in February 2021, according to Bill Bennett. It exists because modern landline phones often rely on mains power — when the power goes out, so does the phone line, unless backup is provided. The Code ensures that the most vulnerable customers are not left silent in an emergency.
The trade-off: telcos must invest in equipment and processes for a relatively small group of customers. But the cost of not doing so — both in regulatory fines and in potential loss of life — far outweighs the expense.
Is it 111 or 911 in New Zealand?
What is the emergency number in New Zealand?
The national emergency number is 111. Dialing 111 connects you to police, fire, ambulance, and rescue services. International visitors should use 111 or +64 111 if calling from a foreign mobile. This is New Zealand Police guidance.
What happens if you dial 911 in New Zealand?
Dialing 911 in New Zealand is redirected to the 111 emergency system. So you will still be connected, but it’s best to use 111 for faster routing. The New Zealand Police recommends using 111 directly.
How do international visitors call for help?
Visitors can dial 111 from any phone. If using a foreign mobile, dial +64 111. The system is free and available 24/7. The New Zealand Police website provides clear instructions for all callers.
The implication: for One NZ customers, the emergency number has never changed — it’s 111. The fine was about administrative compliance, not a failure of the network itself.
What should One NZ customers do if they have trouble reaching 111?
How to test your One NZ line for 111 access?
You can test your landline by dialing 111 and then hanging up immediately — no call will be connected unless you stay on the line. The Bill Bennett analysis suggests doing this periodically to ensure the line works.
What are alternative ways to contact 111?
If you cannot call 111 from your landline, use a mobile phone, a neighbor’s phone, or register for the text-to-111 service (currently available for people who are deaf, hard of hearing, or speech impaired). The New Zealand Police lists all available options.
How to contact One NZ customer service for help?
One NZ customer service can be reached at 0800 123 456 or via the My One NZ app. Vulnerable customers should register for priority assistance, which may include a free backup device. Check the One NZ support page for details.
For those concerned about data security and service reliability, similar issues of provider accountability have been seen in other sectors — for example, the Gmail passwords exposed data leak showed how service failures can leave consumers exposed. On a broader scale, comparing car insurance companies in NZ also highlights how trust ratings and regulatory compliance affect consumer choice.
One NZ says it is implementing changes to its compliance processes, but the exact list of improvements has not been made public. Vulnerable customers should proactively check their 111 access and contact One NZ to confirm they are on the priority list.
The pattern: the same types of failures — disclosure, records, outreach — that triggered the fine are now being addressed. But progress depends on whether One NZ translates its admission into concrete action.
Timeline: One NZ 111 Code Breaches
- 2021–2025: One NZ breaches the 111 Contact Code repeatedly, failing to meet its obligations to vulnerable customers (Commerce Commission).
- April 15, 2024: Commerce Commission files court proceedings against One NZ, citing ongoing breaches (1News).
- December 1, 2025: High Court orders One NZ to pay $1.1 million fine and $100,000 in costs (Commerce Commission).
The timeline signal: the breaches spanned nearly five years, and the regulator took action only after the failures persisted. The fine closes a chapter, but the compliance improvements are just beginning.
What we know and what remains unclear
Confirmed facts
- Fine amount of $1.1 million confirmed by the High Court (Commerce Commission).
- 10 breaches of the 111 Contact Code admitted (Commerce Commission).
- Breaches involved information disclosure, record keeping, and customer outreach (Commerce Commission).
What’s unclear
- Exact list of changes One NZ will implement (One NZ).
- Whether all affected vulnerable customers have been contacted (1News).
- Potential further penalties or investigations (Commerce Commission).
Perspectives from the regulators and One NZ
One NZ endangered vulnerable consumers by failing to meet its obligations under the 111 Contact Code.
— Commerce Commission spokesperson, as reported by Commerce Commission
The breaches did not affect our network or customers’ ability to reach emergency services. No customers were shown to be harmed as a result of the breaches.
— One NZ spokesperson, via One NZ media
The two perspectives frame the issue differently: the regulator focuses on compliance failures that endangered customers, while One NZ highlights that the 111 service itself remained operational. Both can be true, but the Code exists to close the gap between technical compliance and actual safety.
Summary: What the fine means for One NZ customers
For One NZ customers — especially those who rely on a landline and have no alternative phone — the fine is a warning that the company’s compliance processes were not up to standard. The action to take is clear: check your 111 access, register for priority assistance if you’re vulnerable, and stay informed about One NZ’s promised improvements. For the regulator, the message is equally clear: telcos must invest in the systems and outreach that the Code requires, or face consequences that cut into the bottom line.
billbennett.co.nz, billbennett.co.nz, one.nz, media.one.nz, scoop.co.nz, facebook.com, facebook.com
Frequently asked questions
What is the 111 Contact Code?
The 111 Contact Code is a New Zealand regulation that requires telecommunications providers to ensure vulnerable customers can call 111 during a power cut, including providing a free backup device if needed. It came into effect in February 2021.
How many breaches did One NZ admit to?
One NZ admitted to ten breaches of the 111 Contact Code, covering failures in information disclosure, record keeping, and customer outreach, between 2021 and 2023.
What is the penalty for breaching the 111 Contact Code?
The High Court ordered One NZ to pay NZ$1,100,000, plus NZ$100,000 toward the Commerce Commission’s costs. The penalty was jointly recommended by the Commission and One NZ.
Who enforces the 111 Contact Code?
The Commerce Commission, New Zealand’s competition and consumer regulator, enforces the Code. It can investigate breaches and take legal action, as it did in this case.
What should I do if I can’t call 111 from my One NZ line?
Try a mobile phone, a neighbor’s phone, or register for the text-to-111 service. Contact One NZ customer service at 0800 123 456 to report the issue and request a backup device if you are a vulnerable customer.
Will One NZ’s fine affect my service?
No. The fine is a penalty for administrative breaches, not a reflection of network performance. One NZ says its 111 service remains fully operational.
How can vulnerable customers get help?
Vulnerable customers should register for priority assistance with One NZ, which may include a free backup device that provides at least eight hours of emergency calling. Contact One NZ or visit their support page for details.
Is 111 still working properly?
Yes. The 111 emergency service continues to operate normally. The breaches were about compliance with the Code, not a failure of the network itself.
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