Published 4 February 2026 by the RLM Consult Certify Comply team
Accredited rail operators have until 28 February 2026 to comply with the interoperability provisions that commenced under Rail Safety National Law on 1 November 2025. The Office of the National Rail Safety Regulator (ONRSR) released its final guideline on 29 January, which gives operators four weeks with the regulator’s own interpretation in hand. If you are a rail infrastructure manager or rolling stock operator whose operations affect other operators, the central deliverable is an Interoperability Management Plan (IMP) that sits inside your safety management system. Here is what it needs to do.
Why interoperability is now a safety law matter
Australia’s rail network was built as separate colonial systems and still behaves like one in places: different signalling, different rolling stock standards, different operating rules at the boundaries. The National Rail Action Plan set out to fix that, and the interoperability regulation is the legal instrument that makes operators responsible for it. The regulation requires affected rail transport operators to consider interoperability when they design, change or operate their railways, to consult with the other operators they interface with, and to document how they manage it.
What an Interoperability Management Plan contains
ONRSR’s guideline describes the IMP as a part of the safety management system rather than a stand alone document, and that is the right way to build it. In practice the plan needs to cover:
- Scope. Which of your operations affect interoperability, which networks, corridors and interfaces are involved, and which other operators share them.
- Standards. The national and harmonised standards your infrastructure, rolling stock, signalling and operating rules follow, and where you have adopted alternatives, the justification.
- Change. How proposed changes to infrastructure, rolling stock or systems are assessed for their effect on interoperability before they are made, including the consultation you will carry out with other operators.
- Interfaces. How the plan links to your existing interface agreements under the law, so the two do not contradict each other.
- Responsibilities. Who owns the plan, who reviews it, and how its performance is monitored and reported through your normal management review.
Who is actually affected
The obligation attaches to operators whose railway operations affect the interoperability of railway operations. For a national freight operator or a network manager the answer is obvious. For a contractor holding accreditation as a rail infrastructure manager for a siding, a yard or a construction railway, the answer depends on whether the operations interface with the wider network. The guideline sets out the considerations, and if the honest answer is “our operations do not affect interoperability”, the safety management system should record that assessment and the reasons, so the next ONRSR audit does not have to ask.
Fitting it into a working system
The mistake we want to steer clients away from is writing an IMP as a separate binder because a deadline is looming. The plan draws on the risk register, the change management procedure, the interface agreements, the engineering standards register and the management review. If those elements are already in the safety management system, the IMP is largely a matter of cross referencing and filling a few gaps. If they are not, the IMP will expose it, which is the point of the regulation.
For operators we accredited, such as the rail infrastructure manager application described in our Webuild case study, the safety management system was built around the national law’s structure from the start, so the interoperability requirements slot into existing clauses rather than sitting alongside them.
What to do this month
- Read the ONRSR guideline and record your assessment of whether and how your operations affect interoperability.
- If they do, draft the IMP inside the safety management system and take it through your change management process, including consultation with the operators you interface with.
- Notify ONRSR of the change to your safety management system if your accreditation conditions require it.
- Brief the people who will be asked about it: engineering, operations, and whoever meets the auditor.
Also this week
On 2 February Sydney Water, ACCIONA and SMEC signed the Malabar System Alliance agreement to expand wastewater capacity in Sydney’s south east. Water is the quiet growth sector of the next three years, and alliance delivery models procure subcontractors in the same way the rail alliances do: certified systems, safety performance and social procurement evidence up front.
Frequently asked questions
When did the rail interoperability regulation start?
The interoperability regulation under Rail Safety National Law commenced on 1 November 2025. Affected operators are required to comply from 28 February 2026, and ONRSR released its guideline on 29 January 2026.
What is an Interoperability Management Plan?
An Interoperability Management Plan is the part of an accredited operator’s safety management system that describes how the operator considers and manages the interoperability of its railway operations with other operators, including the standards it follows, how it assesses changes and how it consults with interfacing operators.
Does every accredited rail operator need an IMP?
No. The requirement applies to rail transport operators whose railway operations affect the interoperability of railway operations. Operators whose operations do not affect interoperability should still record that assessment and the reasons in their safety management system.
Do I need to tell ONRSR about the change?
Adding an IMP is a change to the safety management system. Whether it requires notification or a variation depends on the conditions of your accreditation, so check them and, if in doubt, notify.