Understanding the new Chain of Responsibility Master Code: What’s changing and how to prepare

Aug 20

The proposed changes to the Chain of Responsibility code of practice, known as the Master Code, have been released for consultation. It’s more than a minor update – the proposed Code challenges businesses to reconsider their role in the Chain of Responsibility, and for many, it means recognising duties and obligations they may not have considered before.

Aaron Louws, Supply Chain Technical Manager at CoRsafe, breaks down what’s changing in the Master Code, why it matters, and what you can start doing now to prepare.

Key takeaways

The Master Code is moving beyond the four primary risk areas. Instead of focusing on speed, fatigue, mass/dimension/loading and vehicle standards, the proposed Code is built around 46 transport activities that reflect real-world operations and organisations.
A wider range of hazards and risks are now in scope. The proposed Code still covers familiar risks, but expands into areas often not linked with CoR – from pests in loads to workplace behaviour, bullying and even criminal infiltration.
Your responsibilities are tied to activities, not just your role. The proposed Code makes it clear that meeting your chain of responsibility obligations isn’t about how you identify your role in the supply chain – it’s about the transport activities you influence and control, and managing the risks involved.
Foundation Activities highlight core responsibilities for everyone. The proposed code introduces groupings for different activities, including ‘Foundation Activities’ for all businesses, that emphasise the importance of a strong safety culture, executive due diligence, training and proper management of third-party relationships.
Start preparing now to avoid pressure later. This isn’t a ‘watch and wait’ situation. Businesses should review the proposed 46 activities today, identify those they influence and control, consider any gaps in their systems based on the guidance, and strengthen their controls, particularly for any critical risks, as soon as possible.

What is the Master Code?

The current Master Code, registered in 2018, was designed as a practical guide to help parties in the Chain of Responsibility (CoR) meet their obligations under the Heavy Vehicle National Law (HVNL), specifically the ‘Primary Duty’ – to ensure the safety of their transport activities, ‘so far as is reasonably practicable’.

Chain of Responsibility laws apply to anyone who can influence or control the use of heavy vehicles over 4.5 tonnes (except in WA & NT), including those who:

Operate or control heavy vehicles, or employ, engage or manage drivers
Schedule transport of goods or passengers, or set driver work/rest times
Request transport of goods by road, either directly or through a representative
Send or receive goods (as consignor or receiver)
Assemble, package, load or unload goods for transport
Import goods into Australia for road transport

The current Master Code was written to explore the safety duties under the HVNL, and provide guidance on how to manage risk, particularly across the four primary risk areas:

Speed
Fatigue
Mass, Dimension & Loading
Vehicle Standards

For each of these risk areas, the Master Code details:

What the risk is
What the law says
What each party can do and why

This structure made it easy for businesses to look up a risk, then find their role and see the suggested controls and considerations. But it also likely reinforce the perception that meeting your CoR obligations is only about controlling these four risks, and may have given businesses a false sense of assurance that they’ve met all their obligations under the HVNL.

What’s new in the 2025 draft Master Code?

When releasing the draft, the National Heavy Vehicle Regulator (NHVR) said industry understanding of the ‘Primary Duty’ has matured since 2018. The focus now is on how you and your supply chain contribute to safer outcomes overall, not just managing isolated obligations and risks.

That’s why the proposed 2025 Master Code flips the current approach on its head. Instead of four primary risk areas, it’s organised around 46 distinct ‘Transport Activities’ that the NHVR believes represent what actually occurs across every stage to enable the transportation of goods or people.

Each activity has a set of controls – about 524 in total, including some that overlap – and these go beyond just reducing risk across the four primary areas.

Instead, they address a broad range of hazards that could arise from these activities, with a focus on how multiple parties working together are often required to achieve a safe (or unsafe) outcome.

This still covers well-known risks like fatigue and load restraint, but also adds issues not traditionally linked with CoR – from pests in loads to workplace behaviour, bullying, harassment, criminal infiltration and blackmail.

Why does this matter?

The shift to an activity-based model highlights the need to:

Identify the transport activities you’re involved in, not just the duties you think apply
Consider the hazards and risks linked to those activities
Take steps to eliminate or reduce those risks as far as reasonably practicable
Seek assurance that the activities you carry out, and those undertaken by the parties you work with, are being conducted safely

This approach broadens the scope from, ‘How do I comply with these four risk areas?’, or even ‘I’m a consignor, what are my risks?’, to ‘How do I systematically manage risk in every transport activity I touch?’

These changes have long been hinted at through recently endorsed industry codes of practice, like the Log Haulage Code released in July. In those codes, we’ve seen a departure from role-based checklists, and an increased focus on identifying the specific activities you undertake and the expectations that flow from them.

By using transport activities as the organising principle, the regulator is reinforcing that:

Your legal duty is to ensure the safety of transport activities, not just to avoid breaching specific rules.
Supply chains are complex, and the legal obligations relating to HVNL across a range of transport activities are difficult to apply when only considering specific risks or roles.
Risk management needs to be integrated and proactive – identifying hazards, assessing them, and putting reasonably practicable controls in place before they cause harm.

This new layout will challenge businesses and individuals to consider their role differently. Many will find themselves linked to activities, and therefore duties, they hadn’t considered before.

This may create new problems for businesses, from added assurance requirements to further training and changing risk profiles.

It’s important to understand, however, that this isn’t a shift in the chain of responsibility laws themselves. CoR parties have always been required to consider their risks and put appropriate controls in place.

What’s different is that this proposed Code removes old guidance that might have given businesses a false sense of assurance after addressing only a limited set of risks, and makes clear that obligations extend to every transport activity you influence.

To make reviewing the list of 46 transport activities easier, the NHVR has grouped them based on their similarity, and in some cases has added descriptions to help people decide if they apply.

One of these groups is titled ‘Foundation Activities’. These are areas all businesses need to be managing as part of their overall CoR approach. These include things like:

Fostering a strong safety culture
Training executives
Sharing safety information

While the existing Code talked vaguely about some of these areas, their explicit identification – complete with dedicated controls and guidance material – signals the proactive shift the proposed Code is ushering in.

What happens next?

Now that the proposed Code has been released, public consultation is underway, and is set to finish on Friday 19 September 2025.

In the meantime, businesses should consider:

Reviewing the list of transport activities in the proposed Code, and marking the ones they’re involved in (even if only occasionally).
Evaluating what hazards and risks are present for those activities, particularly for areas they haven’t considered before.
Checking the controls listed for those activities and comparing them to existing controls.
Closing gaps in your safety management system now – especially in areas like culture, information sharing, and contractor management, which have been given greater emphasis in the proposed Code.
If they haven’t implemented a safety management system, or seriously considered their risks before – let this be the call to action.

When the Code is published, auditors, customers and regulators may expect you to demonstrate how you’ve aligned with this guidance. Being ready early can prevent last-minute scrambles and help you respond confidently when questions come.

More importantly, if the Code helps you identify risks you’re not currently managing, lifting your controls can improve safety outcomes – protecting people, property and the environment.

At CoRsafe, we’re ready to help businesses grapple with what these changes mean for them, and better understand what they can do to respond. Our tools, training and content are all undergoing review to ensure they capture what these updates mean for our customers, and we’re hosting a webinar where legal expert Nathan Cecil and I will be unpacking the most notable changes and implications.

The Master Code is evolving. The sooner you adjust your thinking and your systems, the better your safety and compliance outcomes will be. And with the right support, you’ll be prepared from the very start.

Join us on Tuesday 2 September at 1:00pm AEST for a live webinar with technical expert Aaron Louws and legal expert Nathan Cecil, where we’ll unpack the proposed changes in more detail and answer your questions. Register here.

This article is general information only and is provided without taking into account your particular objectives, circumstances and needs. While every effort has been made to ensure the information is accurate, its accuracy and suitability to your specific circumstances are not guaranteed. You should seek independent professional advice before acting on the information contained in this article. 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 any of the information provided.

CoRsafe Team