Chain of Responsibility compliance is about to matter more than it has in years. On 1 August 2026 the amended Heavy Vehicle National Law (HVNL) commences, alongside the 2026 Master Code. If your business is part of a supply chain that moves freight, your obligations are changing, whether you run a single truck or a national distribution network.
Here is what Chain of Responsibility means, who it applies to, and what the 2026 changes ask of you.
What is Chain of Responsibility?
Chain of Responsibility (CoR) shares responsibility for heavy vehicle safety across every party involved in moving goods, not just the driver. The principle is simple. If you can influence how a heavy vehicle is operated, you share responsibility for making sure it is done safely and legally.
Parties who carry CoR obligations include:
- Transport operators and drivers
- Schedulers and logistics coordinators
- Consignors and consignees, the businesses sending and receiving freight
- Loaders and packers
- Company directors and executive officers
At SCSE we describe this as managing risk when the wheels are stopped and when the wheels are turning. What you do in your yard, loading, restraining and scheduling, travels down the road with the freight. That is the essence of CoR for off-road parties.
Every party has a primary duty
Under the HVNL, each party in the supply chain has a primary duty to ensure the safety of its transport activities, so far as is reasonably practicable. This mirrors the approach in work health and safety law. It places a positive duty on you to manage risk, rather than simply avoid doing the wrong thing.
That duty reaches the top of the business. Executive officers are expected to exercise due diligence to make sure their organisation is meeting its CoR obligations, not just assume that it is.
What changes on 1 August 2026
The 2026 Master Code is the biggest shift for CoR parties since the Code was first registered.
The most important change is structural. The Code has moved from a role-based structure to an activity-based one. The National Heavy Vehicle Regulator (NHVR) describes the shift as focusing on “the risks associated with transport activities, rather than a specific job title or role”.
In practice, you can no longer find your job title, work through that one section, and stop. You now have to work through every transport activity your business actually performs.
The 2026 Master Code describes 45 activities and more than 500 controls. That number alarms people, but the NHVR is clear that “no single business in Australia would apply all of them”. The job is to identify which activities you perform, then work out which controls apply to them. We explain the change in more detail in what the 2026 Master Code means for your business.
What a CoR compliance programme looks like
CoR compliance is not a one-off exercise. It needs ongoing systems, including:
- Risk assessments for your freight and transport activities
- Written policies and procedures for scheduling, loading and driver management
- Training for everyone with CoR obligations, including executive officers
- Due diligence checks on your contractors and suppliers
- Regular audits and control effectiveness reviews
- Documented evidence of the steps you have taken, and when
Documentation matters more than people expect. If something goes wrong, being able to show what you did, and when, is often what separates a manageable outcome from a serious one.
But a control that sits in a folder and not on the ground is not really a control. The real test is simple: are you doing what you say you do? That is the question we come back to in chain of responsibility risk management.
Work with the people who wrote the Code
CoR compliance takes specialist knowledge that most internal teams do not hold in-house, and the 2026 changes raise the bar again.
SCSE’s Director and Principal Consultant, Sean Minto, is the Technical Writer of the Master Code, the registered industry code of practice under section 706 of the HVNL. 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.
If you want a clear view of your CoR obligations before 1 August, get in touch with Sean.
