Chain of Responsibility often gets treated as something only transport companies need to worry about. In practice, CoR obligations under the Heavy Vehicle National Law extend to anyone in the supply chain who performs one of ten defined functions, which catches far more Queensland businesses than the name suggests, including many that don't own or operate a single truck.
Who CoR actually applies to
Your business may be a party in the Chain of Responsibility even if it doesn't own or operate heavy vehicles. Under the HVNL, CoR applies according to the functions a business performs, not its job title or industry. The law identifies ten CoR functions: employer, prime contractor, operator, scheduler, consignor, consignee, packer, loading manager, loader, and unloader. Many businesses hold more than one of these functions at once, a manufacturer might be a consignor, scheduler and loading manager simultaneously without ever owning a vehicle.
The important question isn't simply whether you own trucks, it's what influence or control your business has over heavy vehicle transport activities. The HVNL applies to heavy vehicles over 4.5 tonnes gross vehicle mass, so a business that regularly sends or receives goods using vehicles over that threshold can be a CoR party purely through the consignor or consignee function, regardless of what else the business does.
Primary Duty and executive due diligence
Each party in the chain has a Primary Duty under HVNL section 26C to ensure, so far as is reasonably practicable, the safety of the transport activities it influences or controls. This mirrors the "reasonably practicable" standard used in WHS law, the duty holder must take proportionate steps to eliminate or minimise risk, not guarantee a zero-risk outcome.
Separately, executives of a business that is a CoR party carry a distinct due diligence duty under HVNL section 26D. This requires executives to actively understand the business's transport activities and their risks, ensure the business has and uses adequate resources and processes to manage those risks, and verify that safety processes are genuinely implemented, not just documented. This duty is personal and cannot be discharged simply by delegating it to operational staff. See the NHVR's regulatory advice on the Primary Duty for the full detail.
When a CoR audit or compliance review makes sense
There's no single statutory trigger that requires every CoR party to commission an external audit, but a few situations commonly prompt one: the business has grown into freight tasks it didn't previously manage, more delivery volume, new routes, or new vehicle types; a principal contractor or client is now asking for evidence of CoR compliance as part of a contract or tender; there's been an intercept, infringement or incident that exposed a gap the business wasn't aware of; significant operational change, new contracts, new sites, or the acquisition of a transport operation; recurring fatigue, load restraint, mass or maintenance issues; or executives want independent assurance that the business's systems would satisfy their own due diligence duty.
A proactive review gives the business an opportunity to identify and address weaknesses before they contribute to an incident, contractual issue, or regulatory non-compliance.
What a CoR audit actually covers
Rather than only checking work diaries and mass limits, a proper CoR review looks at the business as an operational and risk management system. That typically includes which CoR functions the business performs and who is accountable for each, the transport activities those functions touch, risk assessment and scheduling practices, fatigue and speed management, mass, dimension, loading and load restraint, vehicle safety and maintenance, contractor management, competency and training, incident and record-keeping systems, and how executives monitor and verify that all of this is actually working, not just documented.
The NHVR's 2026 Master Code, which took effect from 1 August 2026 alongside the broader HVNL amendments, provides detailed guidance across dozens of transport activities and hazard types to help CoR parties understand what "reasonably practicable" looks like in practice. It isn't a mandatory checklist, but courts can treat it as evidence of what a reasonable CoR party should have known.
Where CoR and WHS overlap
For many businesses, CoR shouldn't sit in isolation from the broader WHS management system. Scheduling, fatigue, contractor management, competency, incident management and risk controls often overlap across both frameworks, and the NHVR's own regulatory advice encourages CoR parties to build on their existing WHS risk management processes rather than running a separate, parallel system.
Frequently asked questions
Does CoR only apply to transport companies?
No. More than half of the ten CoR functions relate to businesses that don't own or operate a heavy vehicle at all, including consignors, consignees, packers and loading managers.
What is the Primary Duty under the HVNL?
It's the duty each CoR party has under section 26C to ensure, so far as is reasonably practicable, the safety of the transport activities it can influence or control.
Are company executives personally responsible for CoR compliance?
Yes. Executives of a CoR party carry a separate due diligence duty under section 26D, requiring them to actively understand the business's transport risks and verify that safety systems are genuinely in place and working.
Getting your CoR obligations reviewed
Not sure where your business sits in the Chain of Responsibility? Overwatch Safety Solutions can review your transport activities, identify the CoR functions your business performs, and assess whether your current systems and controls provide appropriate assurance against your heavy vehicle safety obligations.
Sources: NHVR: Regulatory Advice: The Primary Duty, NHVR: 2026 Master Code.