What training does Chain of Responsibility under the HVNL expect?

A business is a Chain of Responsibility (CoR) party if it performs any of ten functions in heavy vehicle transport, regardless of job titles or contract wording. The National Heavy Vehicle Regulator (NHVR) lists them as employer, prime contractor, operator, scheduler, consignor, consignee, packer, loading manager, loader and unloader.

More than half of these functions involve businesses that never own or drive a truck. The NHVR's rule of thumb is that a business that sends or receives goods by heavy vehicle is a party in the chain. Employed drivers are not CoR parties because they drive, but they have their own duties under the HVNL and are trained as part of their employer's obligations.

According to the NHVR, the HVNL commenced on February 10, 2014 in the ACT, New South Wales, Queensland, South Australia, Tasmania and Victoria. It has not commenced in Western Australia or the Northern Territory, although vehicles from those jurisdictions must comply when they operate where the HVNL applies. The HVNL is the schedule to the Heavy Vehicle National Law Act 2012 (Qld). This page describes the law as at September 2026.

The primary duty requires each CoR party to eliminate or minimize public risks from the transport activities it influences or controls, so far as is reasonably practicable. Since the October 2018 reforms, a party can breach the duty by not having adequate safety measures in place, even if no incident occurs.

Section 26C(2) adds that each party must, so far as reasonably practicable, eliminate or minimize public risks, and ensure its conduct does not directly or indirectly cause or encourage a driver to contravene the HVNL or exceed a speed limit, or another person to contravene the law. Section 26A sets the principle of shared responsibility: a party's responsibility depends on the functions it performs, the public risk and its capacity to control that risk.

The NHVR's guidance on complying with the primary duty sets out six steps: know your transport activities; identify the risks, starting with fatigue, speeding, excessive mass or dimension, poorly restrained loads and unsafe vehicles; assess them; find ways to manage them; implement controls; and monitor and update. The controls it lists include training or recruitment procedures, and subscribing to safety bulletins and education and training updates.

Executives must exercise due diligence to ensure the business complies with its safety duties, and the HVNL defines that to include keeping their own knowledge current. This makes executive education an explicit legal expectation rather than a courtesy.

Section 26D(3) says due diligence includes taking reasonable steps:

1. to acquire, and keep up to date, knowledge about the safe conduct of transport activities;
2. to gain an understanding of the nature of the entity's transport activities and their hazards and risks, including public risk;
3. to ensure the entity has, and uses, appropriate resources to eliminate or minimize those hazards and risks;
4. to ensure the entity has and implements processes to eliminate or minimize risks, to receive and respond in a timely way to information about hazards, risks and incidents, and to comply with its safety duties;
5. to verify that those resources and processes are being provided, used and implemented.

The NHVR's executive duty guidance explains that "executive" includes executive officers, directors and partners, and that the due diligence duty applies to 18 safety duty provisions, including the primary duty, prohibited requests (section 26E), speed limiter tampering and false container weight declarations. Section 26D(2A) excludes executives acting on a voluntary basis.

Training should follow the functions each person performs and the risks those functions create. The table below is an illustrative mapping built from the HVNL duties and NHVR guidance; it is not a prescribed curriculum.

Assessment should confirm people can apply the procedure in their own setting, which is the difference between completion tracking and competency verification. A training matrix that maps CoR functions to roles makes gaps visible, especially where one person performs several functions.

Two changes in 2026 affect CoR training content: a new Master Code and an amended HVNL. Training materials written before 2026 should be checked against both.

• 2026 Master Code: the NHVR describes the 2026 Master Code as moving from a role based to an activity based structure, describing 45 activities. Training organized around old role headings may need restructuring.
• Amended HVNL: the NHVR reports that the Heavy Vehicle National Law Amendment Bill 2025 was passed by the Queensland Parliament on November 18, 2025 and that the amended HVNL commenced on August 1, 2026, with a new Heavy Vehicle Accreditation scheme, fatigue and work diary changes, and changes to mass, dimension and loading provisions.
• Safety management system standard: supporting instruments approved in May 2026 include a Safety Management System Standard 2026, which is relevant where training forms part of an accredited operator's system.

The core CoR duties in sections 26A to 26E remain in the amended law, although section 26D was amended in 2025 and a new section 26I on alternative verdicts was inserted. Keeping a compliance obligations register that links each training module to the provision it supports makes this kind of change easier to absorb. See how to update training when regulations change.

Primary duty offenses are graded into three categories by seriousness, and executives who fail to exercise due diligence face the same penalty as an individual who breaches the primary duty. The maximum penalties below are as stated in the HVNL text current from August 1, 2026.

Training records often matter in investigations because they help show whether a party had reasonably practicable measures in place. The NHVR notes that an effective safety management system can be evidence of compliance with both the primary duty and the due diligence duty.

Knowledge Foundry links each CoR function, risk and control to defined learning outcomes and assessment points, so training can be traced to the HVNL provision and Master Code activity it supports. When the law or code changes, dependent content is flagged for review rather than found later by audit. See remediation and operational procedure programs.