The 2026 Master Code has changed how Chain of Responsibility guidance is organised. If your business has mapped its CoR obligations by job title, that mapping no longer lines up with the Code.
Here is what changed, and what it means in practice.
What the Master Code is
The Master Code is a registered industry code of practice under section 706 of the Heavy Vehicle National Law (HVNL). It sets out guidance on managing heavy vehicle safety risk, and helps Chain of Responsibility parties understand how to meet their primary duty.
SCSE Director and Principal Consultant Sean Minto is the Technical Writer of the Master Code. SCSE is also an approved Australian Logistics Council (ALC) Master Code Audit Service (AMCAS) provider, and we conduct CoR audits against the requirements of the HVNL and the Master Code.
The 2026 Master Code moved from roles to activities
The most important change is structural.
The earlier edition was organised around roles. You found your job title, or the role your business performed, and worked from there.
The 2026 Master Code is organised around activities. The NHVR describes the shift as emphasising “the risks associated with transport activities, rather than a specific job title or role”.
That reads like a technicality. It is not.
Most businesses in a supply chain perform more than one activity. A single distribution centre might load, unload, restrain loads, schedule movements and receive freight. Under a role-based structure it was easy to find the entry that matched your title, work through it, and stop. Under an activity-based structure you have to work through every activity your business actually performs.
The practical consequence is uncomfortable. Businesses that were confident they had covered their obligations may find gaps, purely because the guidance is now organised a different way.
45 activities and more than 500 controls
The 2026 Master Code describes 45 transport activities and contains more than 500 controls.
That figure alarms people when they first hear it. It should not. The NHVR is explicit that “no single business in Australia would apply all of them”, because each business only undertakes certain activities.
The work is not implementing 500 controls. The work is identifying which activities your business actually performs, and then working out which controls apply to those activities.
That is a scoping exercise before it is a compliance exercise. Get the scoping wrong and everything downstream is wrong with it.
The HVNL is changing at the same time
Amendments to the Heavy Vehicle National Law commence on 1 August 2026.
Two things landing at once matters. If you are reviewing your CoR position against the new Code, review it against the amended law at the same time. Doing them separately means doing the same work twice, and risks leaving a gap between the two.
Where to start
If you do nothing else, do this:
- List the transport activities your business actually performs. Not job titles. Activities.
- Check that list against the activities described in the 2026 Master Code.
- For each activity, identify the controls you already have in place.
- Find the gaps between what the Code describes and what you actually do.
- Check the controls you do have are working in practice, not just written down.
That last point is the one businesses most often skip. A control that exists on paper but not on the ground is not a control. We wrote about this in The Missing Link: Reviewing Control Effectiveness.
How SCSE can help
At SCSE we conduct CoR risk assessments and CoR control effectiveness reviews. We facilitate workshops to help clients identify CoR hazards and assess the risks associated with their transport activities and business practices.
We also conduct field visits to check that existing CoR risk controls reflect operational practice, the way work is actually done, and to identify what is working and what is not.
If you need a fresh set of eyes on your CoR position before the new law commences, get in touch with Sean.
