HVNL compliance checklist: 4 areas fleet operators should review in 2026
The amended Heavy Vehicle National Law is now in effect. Use this practical checklist to assess your safety systems, driver fitness processes, fatigue management and operational evidence.
By Geotab Team
Sep 10, 2026

Key Insights
- Under the newly introduced PSOE (Present, Suitable, Operating, and Effective) audit standards, operators must actively prove their safety policies work in real-time.
- The new Unfit to Drive duty applies to drivers of all heavy vehicles over 4.5 tonnes and expands the focus beyond fatigue to a driver's broader health and fitness.
- Basic Fatigue Management and Advanced Fatigue Management are being replaced within the new accreditation framework by Alternative Compliance Accreditation – Fatigue and Alternative Compliance Hours.
Australia's amended Heavy Vehicle National Law is now in effect, for fleet operators, the most important question is whether safety processes are being applied in everyday operations. Under the newly introduced PSOE (Present, Suitable, Operating, and Effective) audit standards, operators must actively prove their safety policies work in real-time.
Use this checklist to identify potential gaps in your fleet's safety and compliance processes following the 1 August HVNL changes.
1. Review your Safety Management System and accreditation requirements
What changed?
The National Heavy Vehicle Accreditation Scheme (NHVAS) is officially being replaced by the Heavy Vehicle Accreditation (HVA) framework.
Under the new HVA framework, operators seeking accreditation must first obtain General Safety Accreditation (GSA) and have a Safety Management System that complies with the Safety Management System Standard 2026. Operators can then progress to other accreditation pathways, including Alternative Compliance Accreditation for fatigue or mass, where applicable. Importantly, operators must be able to demonstrate that their safety systems are not only documented, but are actively implemented and effective in day-to-day operations.
Your checklist
- Establish audit-ready verification: Can you readily produce safety records across vehicle maintenance, driver fatigue and daily operations to support a PSOE entry or compliance audit?
- Check that safety systems operate in practice: Are your documented safety policies actively implemented across maintenance, scheduling, driver management and daily operations?
- Build proactive risk assessment loops: Do you have a system to identify recurring operational issues, such as vehicle faults or driver safety exceptions, and track the corrective actions taken?
- Maintain evidence of corrective action: When a safety risk or non-conformance is identified, can you retrieve records showing how it was reviewed, addressed and followed up?
How fleet technology can help
- The Digital Evidence Locker: Geotab brings vehicle and driver behaviour data together in one platform, helping operators maintain accessible digital records and reduce reliance on fragmented or paper-based processes.
- Continuous SMS Assurance: Geotab provides real-time exception reporting for events such as speeding and critical vehicle faults. These events can be recorded and flagged for management review, helping operators monitor safety risks and maintain a clearer record of how issues are identified and addressed.
2. Expand fitness-to-drive processes beyond fatigue
What changed?
The amended HVNL introduces a new Unfit to Drive duty for drivers of all heavy vehicles over 4.5 tonnes, pulling smaller rigid transport assets into strict enforcement scope.
The duty goes beyond fatigue. Drivers must not operate a heavy vehicle if they are unfit to drive for any reason. This may include physical or mental health conditions, temporary illness or injury, or the effects of alcohol or other drugs.
Drivers are expected to assess their fitness before starting work, monitor it throughout their shift and stop driving if they become unfit. Employers also have responsibilities. If a driver reports that they are unfit to drive, the business must respond appropriately and must not require them to continue driving in circumstances that conflict with its safety duties.
Your checklist
- Review your pre-start declarations: Do your current processes consider fitness factors beyond fatigue, including illness, injury, medication and mental health?
- Check which vehicles are covered: Have you reviewed your driver fitness processes to account for the expanded Unfit to Drive duty, which applies to drivers of heavy vehicles over 4.5 tonnes?
- Review how drivers report concerns: Is there a clear and accessible process for drivers to report that they are unfit to drive without inappropriate scheduling or operational pressure?
- Check your response process: When a driver reports that they are unfit, do dispatch and scheduling teams have a clear process for responding and managing the situation appropriately? Can you retrieve records of driver fitness declarations, reported concerns and the actions taken by the business when required?
How fleet technology can help
- Digitise pre-start declarations: Using Geotab Drive, operators can deploy customisable digital pre-start and Fit for Duty forms that drivers can complete from a tablet or smartphone, helping create a consistent and accessible record of driver declarations.
- Respond quickly to fitness concerns: If a driver reports that they are unfit to drive, digital workflows can help make that information available to the appropriate teams, supporting a timely response and helping reduce the risk of scheduling or operational pressures conflicting with safety responsibilities.
3. Review fatigue management and work diary processes
What changed?
The new HVA framework changes the accreditation pathway for operators that need greater operational flexibility and access to certain concessions. Alternative Compliance Accreditation Fatigue (ACA-Fatigue) builds on the requirements of General Safety Accreditation (GSA). This means operators must first have a compliant Safety Management System (SMS) in place and demonstrate that it is working effectively in day-to-day operations.
Operators seeking accreditation need to show they have appropriate processes to identify and manage risks, meet their legal obligations and continually improve safety performance.
Your checklist
- Review your work diary processes: Are drivers still relying on paper Written Work Diaries (WWDs), and have you identified where manual entries or calculations could create errors or gaps in your fatigue records?
- Assess your fatigue management requirements: Have you reviewed the requirements for Alternative Compliance Hours (ACH) under the new accreditation framework?
- Incorporate Advanced Fatigue and Distraction Detection (FDDT): Determine whether your fleet is aligned with the NHVR Master Code of Practice, which explicitly lists FDDT hardware as a recognised and defensible safety control for ACH qualification.
- Data visibility: If you use FDDT or other driver safety technologies, can safety managers access relevant events alongside other vehicle and driver information to help identify trends and respond to risks?
How fleet technology can help
- Integrate with NHVR-approved EWDs: Geotab integrates with NHVR-approved Electronic Work Diary solutions, helping operators digitise work and rest records and reduce reliance on paper-based fatigue management processes.
- Bring fatigue and distraction data together: Geotab can integrate with compatible Fatigue and Distraction Detection Technologies (FDDT), including AI-enabled driver-facing cameras, helping safety managers view fatigue, distraction and other driver safety events alongside broader telematics data.
4. Review mass, dimensions and road-access controls
What changed?
To reward operators ultilising safety systems, General Mass Limits have increased to align with the previous Concessional Mass Limits in applicable circumstances. The amendments also increase the general access length limit from 19 metres to 20 metres for certain vehicle combinations, subject to specified vehicle and braking requirements.
The new HVA framework also introduces Alternative Compliance Accreditation – Mass (ACA-Mass) for eligible operators, building on the foundational General Safety Accreditation requirements.
Your checklist
- Review mass and axle verification: Can you confirm axle and gross vehicle mass before vehicles leave the loading area?
- Review access requirements for complex combinations: For vehicles such as B-Doubles and Road Trains, have you checked that vehicle configurations and planned routes align with the relevant Restricted Access Vehicle (RAV) network requirements?
- Monitor route adherence: Can you identify when a restricted-access vehicle deviates from its planned or approved route. Can you retrieve location and route information when you need to review deviations, investigate an event?
How fleet technology can help
Monitor vehicle movements with geofencing: MyGeotab’s advanced mapping tools allows operators to create virtual zones and configure rules and notifications around vehicle movements. Fleet managers can use these tools to monitor when vehicles enter, exit or operate outside defined areas, helping them identify route exceptions and respond when required.
The Geotab Team write about company news.
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