Published 7 July 2026 by the RLM Consult Certify Comply team
The new financial year brought five changes that touch most of the contractors we work with. None of them is a surprise, all of them were announced months ago, and every one of them will be tested by a regulator, a client or an auditor before the year is out. Here is what started on 1 July 2026 and the practical response to each.
1. NSW codes of practice are binding
From 1 July a business in New South Wales must comply with an approved code of practice or demonstrate that it manages the risk to an equivalent or higher standard. For construction that means the codes on construction work, excavation, falls, plant, demolition, manual tasks and psychosocial hazards now set the floor. If you followed the nine week plan in our April article, you are done. If not, the shortest path is a mapping of each applicable code against your procedures, then an internal audit that confirms the site matches the paperwork.
2. ONRSR’s Critical Risk Compliance Program
The Office of the National Rail Safety Regulator has begun a Critical Risk Compliance Program that focuses its audits and inspections on the risks with the greatest potential for catastrophic outcomes across the rail industry. For accredited rail infrastructure managers and rolling stock operators, and for the contractors who work under their safety management systems, the effect is that ONRSR engagement this year will be organised around those critical risks rather than around a general review of the system. Expect the regulator to ask for the specific controls, the assurance activities and the evidence for each critical risk relevant to your operations. If your risk register does not clearly identify which of your risks are critical and how each is controlled and verified, that is the gap to close first.
3. Rail accreditation fees
ONRSR’s 2026-27 fees took effect on 1 July: 2.8 per cent nationally, with increases averaging about 11 per cent for operators in New South Wales, Victoria and the Northern Territory and about 4 per cent elsewhere. Budget for it, and if your accreditation scope includes operations you no longer perform, consider whether a variation would reduce the fee basis.
4. Group 2 climate reporting
Entities that meet two of three tests (revenue of $200 million, gross assets of $500 million, 250 employees) must prepare climate related financial disclosures for financial years beginning on or after 1 July 2026. Few of our clients are Group 2 entities. Most of their clients are. The practical effect on a subcontractor is a request for fuel, electricity and materials data by project, and questions about climate related physical risk on sites. Build the data capture into the environmental management system now; ISO 14001:2026 asks for the climate context anyway.
5. Indigenous Procurement Policy eligibility
From 1 July the Commonwealth’s Indigenous Procurement Policy defines an Indigenous enterprise as one that is 51 per cent or more First Nations owned and controlled, or registered with the Office of the Registrar of Indigenous Corporations. The tightened test responds to concerns about businesses claiming Indigenous status without genuine ownership and control. For genuine Indigenous businesses the change strengthens their position on Commonwealth funded projects. For head contractors it means verifying the status of the enterprises they count towards their targets, which will flow through to supply chain questionnaires.
Coming up
Three more dates matter in the next two months. The amended Heavy Vehicle National Law commences on 1 August, bringing Heavy Vehicle Accreditation and the safety management system standard. Western Sydney International Airport opens to freight on 26 July. And the ISO 45001 revision is at the draft international standard stage, with the ballot closing on 9 August. We will cover each as it lands.
One process for all five
Each change above is a legal or contractual requirement, and ISO 9001, ISO 14001 and ISO 45001 all require you to identify your compliance obligations, plan to meet them and evaluate whether you have. A certified integrated management system with a living compliance register absorbs changes like these as routine updates. A set of documents assembled for a single tender does not. If 1 July felt like five separate problems, the system is the issue, not the changes.
Frequently asked questions
What is ONRSR’s Critical Risk Compliance Program?
A regulatory program that commenced on 1 July 2026 under which the Office of the National Rail Safety Regulator focuses its audits, inspections and engagement on the critical risks with the greatest potential for catastrophic outcomes in rail operations, and on the controls and assurance operators have in place for them.
Which entities are in Group 2 for climate reporting?
Entities that meet at least two of three thresholds: consolidated revenue of $200 million or more, gross assets of $500 million or more, or 250 or more employees. Group 2 reporting applies to financial years beginning on or after 1 July 2026.
What changed in the Indigenous Procurement Policy on 1 July 2026?
The definition of an Indigenous enterprise was tightened to businesses that are 51 per cent or more First Nations owned and controlled, or registered with the Office of the Registrar of Indigenous Corporations.
Are NSW codes of practice mandatory now?
Yes. From 1 July 2026 a person conducting a business or undertaking in NSW must comply with approved codes of practice or demonstrate an equivalent or higher standard of health and safety.