What does the new Master Code mean for your business?
With the 2026 Master Code now published, the focus shifts from anticipation to application. What does it mean for your transport activities? What has actually changed? And how should your business respond?
In our recent webinar, Aaron Louws, Supply Chain Technical Manager at CoRsafe, and Nathan Cecil, Partner at Holding Redlich, examined the new Code and its practical implications for industry.
Drawing on both operational and legal perspectives, they explored the structural changes in the new Code and what it signals about regulatory expectations going forward.
This article summarises the key insights from that session. If you’d like to hear Aaron and Nathan discuss the changes in more detail, watch the full webinar on demand.
Key takeaways
The fundamental law hasn’t changed, but expectations have. The primary duty and executive due diligence obligations introduced in 2018 remain the same. But the 2026 Master Code provides clearer guidance on what “reasonably practicable” looks like in today’s heavy vehicle environment.
The Code shifts from roles to activities. The 2018 Code focused on supply chain roles and four key risk areas. The 2026 Code is structured around 45 transport activities across eight categories, shifting the focus from who you are in the chain to what you do.
There are significantly more controls. The new Code references more than 500 controls, compared to around 150 in the previous version. This provides clearer guidance on managing risks, but also raises the bar for demonstrating that existing controls are effective. As Nathan explains, businesses don’t need to implement every control listed in the Code, but they do “need to be prepared to demonstrate that the controls they do have in place are as effective, or better than, those in the Code.”
“Transport activities” are broader than many assume. The primary duty extends beyond operational tasks like loading, unloading or scheduling. It captures the business practices and decisions that shape how transport is planned, resourced and executed. That means offices, boardrooms, hiring practices and safety culture are just as relevant as loading docks or highways.
Executive accountability remains central. Executives must understand their organisation’s transport activities, associated risks and the effectiveness of controls in place. This is an ongoing obligation, not a one-off training exercise.
The road to the Code: Why a new Master Code?
The 2026 Master Code sits within a regulatory shift that’s been unfolding for more than a decade.
Chain of Responsibility (CoR) was first introduced through national transport reform in the early 2000s, recognising that safety outcomes are influenced by many parties across a supply chain.
But when the Heavy Vehicle National Law (HVNL) commenced in 2014, CoR was still largely seen as an extension of transport operator liability, rather than a governance issue for the broader supply chain.
That changed in 2018.
Reforms to the HVNL introduced the primary duty, requiring each party in the chain to ensure, so far as is reasonably practicable, the safety of their transport activities. They also introduced due diligence duty for executives, requiring leaders to actively ensure their businesses were meeting that primary duty.
Penalties also increased significantly, including multi-million dollar fines for corporations and potential imprisonment for individuals for the most serious breaches.
“From 2018 onwards, we saw a marked increase in industry maturity,” Aaron said, “in terms of how transport activities are managed; in the sophistication of available controls; and in collaboration across supply chains to reduce risk and improve public safety outcomes.”
Despite that progress, regulators and industry recognised there was still room for improvement.
The 2026 Master Code builds on the 2018 reforms by providing more detailed guidance on how the law may be applied in practice.
“Early on, the regulator adopted a more educative and collaborative approach while industry adjusted [to the HVNL reforms],” Nathan explained during the webinar. “Now, the message is effectively: ‘You’ve been living with this long enough that we expect a more sophisticated approach.’ There will be less hand-holding. That’s what the new Code reflects. The regulator has levelled up what it expects from industry.”
How is the new Code different?
There are four major differences between the 2018 and 2026 Codes that businesses need to understand:
A move from roles to activities
A significant increase in controls
A broader, cross-sector scope
A stronger emphasis on the primary duty
From roles to activities
One of the most significant changes in the new Master Code is how it is structured.
The 2018 Code was organised around supply chain roles – such as consignor or employer – and four key risk areas: speed, fatigue, mass/dimension/loading and vehicle standards.
The 2026 Code takes a different approach.
Instead of focusing on roles, it identifies 45 transport activities, grouped into eight categories:
Foundation activities
Managing drivers
Vehicles and equipment
Premises
Operations
Journey planning
Loads, loading and unloading
Sector-specific controls
This approach reinforces the intent behind the primary duty: safety is determined by activities, not job titles. If a business is involved in a transport activity, it has a role to play in ensuring that activity is carried out safely.
Aaron highlighted the importance of foundation activities, which apply to all businesses with HVNL obligations. These include organisational safety capability, executive understanding of the business, policies and procedures, monitoring and assurance, information sharing and commercial agreements.
“To ensure the safety of transport activities, you need more than compliance checklists,” Aaron said. “You need organisational safety capability. That’s supported by informed and engaged executives, underpinned by clear policies and procedures, and experienced by workers who are trained and fit for work.
“It also extends to how you work with other businesses, plan journeys, monitor and measure the effectiveness of their systems, share information, or even having appropriate agreements in place. Those elements help close the gap between work as imagined and work as performed.”
Another example is the inclusion of ‘Managing Fitness to Work’ as a foundation activity. Nathan explained that earlier drafts focused heavily on drivers, but the final Code recognises that many other roles influence heavy vehicle safety.
“Whether those individuals are properly trained, understand their responsibilities, are adequately supervised, and are physically, mentally and emotionally fit for work is crucial,” Nathan said.
A significant increase in controls
Another major difference is the number of controls referenced in the Code.
The previous Code referred to around 150 controls or considerations.
The 2026 Code references more than 500.
This increase reflects both the broader range of transport activities, and a more mature understanding of risk management within the industry.
Importantly, the Code is intended as guidance rather than a checklist.
Businesses do not need to implement every control listed. Instead, they should assess which controls apply to their transport activities and whether their existing systems achieve the same safety outcomes.
A broader, cross-sector scope
The 2018 Master Code was heavily freight-focused.
The new Code is designed to apply more clearly across all industries that use heavy vehicles – from freight and construction to agriculture, passenger transport and resources.
If heavy vehicles form part of your operations, the Code is relevant to your business.
A stronger emphasis on the primary duty
The 2026 Master Code also places a stronger emphasis on the breadth of the primary duty.
Many businesses interpret ‘transport activities’ as the physical tasks associated with moving a heavy vehicle. But Nathan says the definition is much broader.
“Transport activities include business practices and decision-making associated with the use of a heavy vehicle on a road.”
That includes how transport is planned, scheduled, resourced, contracted and monitored – decisions that often occur long before a vehicle enters the road network.
Overlaying this is the executive due diligence duty, which requires executives to actively ensure their business complies with its primary duty.
Nathan pointed to a subtle but important wording change between earlier drafts and the final Code.
The draft referred to training executives in the business.
The final Code refers to ensuring executives understand the business.
“That’s not just semantics,” Nathan said.
“Executives must genuinely understand their transport activities and remain across those issues on an ongoing basis. It’s not a one-off training exercise.”
Choosing the right controls
While the new Code references more than 500 controls, the intention is not to create unnecessary red tape.
These controls are spread across 45 distinct activities, and no single business undertakes all of them. Many simply reflect safe practices that already exist in well-managed organisations.
An effective starting point is to:
Identify the transport activities your business undertakes
Review the controls recommended for those activities
Assess what controls you already have in place
Identify where improvements may be required
Different businesses will implement controls differently depending on their size and capability. A large organisation may adopt sophisticated technology solutions, while smaller businesses may achieve the same outcomes using simpler systems.
Courts assessing what is reasonably practicable consider factors such as the likelihood and severity of harm, what is known about the risk and whether the cost of a control is grossly disproportionate to the risk.
The new Code does not create new obligations, but it will likely become a key reference point for what effective risk management looks like.
“If there’s something you can do to manage a risk and it’s not unreasonably difficult or unreasonably expensive, you probably should do it,” Nathan said.
How CoRsafe is responding
The new Master Code introduces a more detailed framework for managing transport activities. Our focus has been on helping businesses understand what the changes mean in practice – and what to do next.
Alongside the webinar, now available on demand, we’ve developed several resources to help organisations respond to the Code:
Watch the free webinar
Complete the free e-learning course
Work through the free business readiness review
Access all resources on our Master Code page.
© 2026 Logistics Safety Solutions Pty Ltd (LSS) ABN 25 134 417 379. General information only. LSS bears no responsibility, and shall not be held liable, for any loss, damage or injury arising directly or indirectly from your use of or reliance on the information in this article.