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Compliance playbook for mining and construction businesses

WHS primary duty s 19, high-risk plant registration under Schedule 5 of the model WHS Regulations, High Risk Work Licences (29 classes), white-card construction induction, state Mining Act tenement obligations, Aboriginal heritage protection by state, EPBC Act + state environment regimes, NGER Act reporting above 50kt CO2-e, Safeguard Mechanism above 100kt, Modern Slavery if consolidated revenue >$100M, Heavy Vehicle National Law chain of responsibility, state Security of Payment Acts, and industrial manslaughter laws by state — every obligation a mining or construction PCBU faces on one page.

20 obligations3 deadlines24 cross-linked articles

Key deadlines — next 12 months

  • 31 October annuallyNGER annual emissions and energy report
  • 31 December 2026Modern Slavery Statement (FY26, 30 June year-end)
  • 1 December 2026Silica WEL reduced to 0.05 mg/m³
  • Pre-disturbanceAboriginal heritage clearance + EPBC referral
  • ContinuousWHS s 19 + s 27 officer due diligence

Does this apply to me?

Answer yes to any of the below and the obligations in this playbook are likely relevant.

  • 1Are you a Person Conducting a Business or Undertaking (PCBU) in mining or construction in Australia?
  • 2Do you operate, own or commission high-risk plant — cranes, pressure vessels, boilers, lifts, amusement devices, concrete-placing booms, mobile cranes (Schedule 5 of the model WHS Regulations)?
  • 3Do you employ workers in any of the 29 High Risk Work Licence (HRWL) classes — scaffolding, dogging, rigging, crane operation, forklift, boom-type elevating work platform?
  • 4Do you hold a mining tenement (exploration / mining / petroleum) under state Mining Acts?
  • 5Do you operate or propose to operate in or near an area of Aboriginal cultural heritage?
  • 6Do your operations exceed 50,000 tonnes CO2-e (NGER reporting threshold) or 100,000 tonnes (Safeguard Mechanism)?
  • 7Do you operate heavy vehicles or appoint others to do so (HVNL Chain of Responsibility)?
  • 8Do you submit progress claims under construction contracts in NSW / VIC / QLD / state security-of-payment regimes?

Plain English summary

Mining and construction are the hardest-regulated PCBU contexts in Australia. The WHS Act 2011 (model) is the master statute — adopted by each state and territory with state-specific variations (Victoria operates under the OHS Act 2004, which is similar but distinct). The primary duty in s 19 captures every PCBU and every officer. The Cat 1 (recklessness) industrial manslaughter offence carries imprisonment for individuals and millions in fines for companies — and now applies in every state except Western Australia (which operates under its own WHS Act with parallel provisions).

The model WHS Regulations Schedule 5 prescribes registration of high-risk plant: certain cranes, pressure vessels, boilers, lifts, amusement devices, concrete-placing booms, and tower cranes must be registered before being used. The 29 High Risk Work Licence (HRWL) classes — from basic scaffolding to crane operation to dogging and rigging — require an individual licence issued by the state regulator. Construction induction (the white card) is a mandatory pre-requisite for entry to a construction site.

Beyond WHS, mining adds the state Mining Act stack (tenement obligations, expenditure conditions, rehabilitation bonds, royalty reporting); Aboriginal heritage law layered on top by state (NSW NPWA, Vic AHA 2006, Qld ACHA 2003, WA AHA 1972/AHAA 2021, SA AHA 1988, NT Sacred Sites Act, Tas Aboriginal Heritage Act 1975); the federal EPBC Act and state environment regimes; the NGER Act for ≥50kt CO2-e operations; the reformed Safeguard Mechanism for ≥100kt facilities; Modern Slavery at ≥$100M consolidated revenue; the HVNL chain of responsibility for heavy-vehicle movements; and the state Security of Payment Acts for construction-contract progress payments.

This playbook lists every obligation a mining or construction PCBU faces, the section of the Act it sits under, who in the company is accountable, the cadence, the maximum penalty, and a regulator-direct source. Tailor down for smaller subcontractors (typically the HVNL, SOPA and WHS layers dominate) and tailor up for major-project tier-1 operators.

Obligation checklist

Every obligation cites the Act and section. Source URLs link to the regulator's portal — Rules Mate does not republish statutory text.

  1. 1

    Work Health and Safety Act 2011 (model — NSW/Qld/SA/Tas/ACT/NT/Cth), s 19 (primary duty)

    Ensure, so far as is reasonably practicable, the health and safety of workers and of other persons. Cover workplace, plant, structures, substances, training, supervision, and arrangements for facilities. Apply hierarchy of controls.

    Who's responsible
    PCBU (board + senior management collectively)
    Frequency
    Continuous
    Penalty
    Cat 1 (reckless): up to $14.45M (body corporate) + 25 years prison (individual). Cat 2: up to $1.8M (body corporate). Cat 3: up to $722,750 (body corporate). VIC: equivalent under OHS Act 2004.
  2. 2

    Work Health and Safety Act 2011, s 27 (officer due diligence)

    Officers (directors and senior management who participate in decisions affecting a substantial part of the PCBU) must exercise due diligence: acquire WHS knowledge, understand operations and hazards, ensure resources and processes, verify use.

    Who's responsible
    Every officer (directors + senior executives)
    Frequency
    Continuous
    Penalty
    Cat 1: up to $1.025M + 5 years (individual). Cat 2: up to $361,375 (individual). Cat 3: up to $144,550 (individual).
  3. 3

    WHS Regulations, Schedule 5 (registration of plant)

    Register high-risk plant before use: certain cranes (tower, mobile slewing >10t), pressure vessels (above prescribed thresholds), boilers, lifts, amusement devices, concrete-placing booms, building-maintenance units, mast-climbing work platforms. Use the state regulator's plant-registration portal.

    Who's responsible
    Person with management or control of plant
    Frequency
    One-off + re-registration per state regs
    Penalty
    Up to $30,000 (individual) / $150,000 (body corporate) — per item.
  4. 4

    WHS Regulations, Pt 4.5 — High Risk Work Licences (29 classes)

    Workers performing high-risk work must hold the relevant HRWL: scaffolding (basic / intermediate / advanced); dogging; rigging (basic / intermediate / advanced); crane operation (slewing mobile / non-slewing / tower / vehicle-loading / derrick / bridge and gantry); forklift; boom-type elevating work platform >11m; concrete-placing boom; reach stacker.

    Who's responsible
    PCBU (verify licence); worker (hold licence)
    Frequency
    Continuous
    Penalty
    Up to $6,000 (individual worker) / $30,000 (PCBU) — per breach.
  5. 5

    WHS Regulations, r 316 — Construction induction (white card)

    Every person carrying out construction work must hold a construction induction card (white card). Construction work has the meaning in WHS Regs r 289. PCBU must verify before site entry.

    Who's responsible
    PCBU (verify); worker (hold)
    Frequency
    Continuous
    Penalty
    Up to $6,000 (individual) / $30,000 (PCBU).
  6. 6

    Work Health and Safety Act 2011 — industrial manslaughter (NSW Pt 2 Div 1A / Qld Pt 2A / Vic OHS Act Pt 3 Div 13 / SA, ACT, NT equivalents)

    Do not engage in conduct that causes the death of a worker, in circumstances where the conduct is negligent or reckless. Industrial manslaughter is criminalised in every state except WA (which has parallel Category 1 provisions).

    Who's responsible
    PCBU + Officers
    Frequency
    Continuous
    Penalty
    VIC: up to $19.69M (body corporate) + 25 years (individual). Qld: up to $13.785M + 20 years. NSW (from June 2024): up to $20M (body corporate) + 25 years (individual). WA: Cat 1 Industrial Manslaughter — up to $10.5M / 20 years (individual).
  7. 7

    Mining Act 1992 (NSW) / Mineral Resources Act 1989 (Qld) / Mineral Resources (Sustainable Development) Act 1990 (Vic) / Mining Act 1978 (WA) / equivalents

    Hold valid tenement (exploration licence / mining lease / petroleum production lease). Comply with conditions of grant: expenditure commitments, work programs, environment management plans, rehabilitation bonds, royalty payments.

    Who's responsible
    Holder of tenement (mining company + directors)
    Frequency
    Continuous; annual returns + quarterly royalty reports per state
    Penalty
    Forfeiture of tenement; state-specific civil + criminal penalties.
  8. 8

    Aboriginal cultural heritage law (Aboriginal Heritage Act 1972 + Aboriginal Cultural Heritage Act 2021 (WA — under review) / Aboriginal Heritage Act 2006 (Vic) / Aboriginal Cultural Heritage Act 2003 (Qld) / NPWA 1974 (NSW) / Aboriginal Heritage Act 1988 (SA) / Tasmanian Aboriginal Heritage Act 1975 / NT Aboriginal Land Rights Act + Sacred Sites Act 1989)

    Do not harm Aboriginal cultural heritage without authorisation. Pre-clearance via state regulator: AHA Approval (Vic), Cultural Heritage Management Plan (Vic where high impact), s 18 approval (WA), heritage agreement (SA). Engage Traditional Owners through the state-prescribed Native Title or RAP process.

    Who's responsible
    Project proponent + tenement holder
    Frequency
    Pre-disturbance + ongoing
    Penalty
    VIC: up to ~$1.83M (body corporate). WA s 18: up to $10M (body corporate) + 5 years (individual). NSW NPWA: up to $1.65M + 2 years.
  9. 9

    Environment Protection and Biodiversity Conservation Act 1999 (Cth), s 18 + Pt 9

    Refer any 'controlled action' likely to have a significant impact on a Matter of National Environmental Significance (NES) to the Minister via DCCEEW. Do not commence the action without approval. Comply with conditions.

    Who's responsible
    Project proponent
    Frequency
    Pre-action + per condition timetable
    Penalty
    Up to $13.2M (body corporate) for body corporate civil penalty + 7 years (individual) for criminal taking of controlled action without approval.
  10. 10

    National Greenhouse and Energy Reporting Act 2007 (Cth)

    Where group facility emissions are ≥50kt CO2-e, or group consumption ≥200TJ energy, or single-facility emissions ≥25kt: register and report under NGER. Report annually by 31 October for the prior 1 July–30 June year.

    Who's responsible
    Controlling corporation (group level) + CFO
    Frequency
    Annual — 31 October
    Penalty
    Civil penalty up to $626,000 (corporate) per breach; Clean Energy Regulator enforcement.
  11. 11

    National Greenhouse and Energy Reporting (Safeguard Mechanism) Rule 2015 (reformed 1 July 2023)

    Where a facility has direct Scope 1 emissions of ≥100kt CO2-e: comply with the facility-specific baseline. From FY24 onwards, baselines decline year-on-year (4.9% from FY24-FY30). Surrender Australian Carbon Credit Units (ACCUs) or Safeguard Mechanism Credits (SMCs) to cover excess emissions.

    Who's responsible
    Facility operator + CFO
    Frequency
    Annual
    Penalty
    Civil penalty up to ~$313,500 per day for non-surrender; Clean Energy Regulator enforcement.
  12. 12

    Modern Slavery Act 2018 (Cth), s 5 + s 16

    Where consolidated revenue is AUD $100M or more: publish an annual Modern Slavery Statement covering 7 mandatory criteria within 6 months of FY-end. Lodge on the Modern Slavery Statements Register.

    Who's responsible
    Board approves; CFO + ESG Lead prepares
    Frequency
    Annual
    Penalty
    Public listing on register; civil penalties proposed under Modern Slavery Amendment Bill 2024.
  13. 13

    Heavy Vehicle National Law (HVNL) — Chain of Responsibility (CoR)

    Every party in the heavy-vehicle supply chain (consignor, packer, loader, scheduler, driver, operator, consignee) must take reasonable steps to ensure they do not cause or contribute to a contravention. CoR positive duty applies regardless of which party physically performs the act.

    Who's responsible
    Every party in the chain + Officers of the corporation
    Frequency
    Continuous
    Penalty
    Up to $3M (corporate) per Cat 1 breach (reckless conduct causing death/serious injury); $1.5M Cat 2; $400k Cat 3.
  14. 14

    Building and Construction Industry Security of Payment Act 1999 (NSW) / Building and Construction Industry Security of Payment Act 2002 (Vic) / Building Industry Fairness (Security of Payment) Act 2017 (Qld) / state SOPA equivalents

    Comply with SOPA progress-payment regime: claimant lodges valid payment claim; respondent lodges payment schedule within statutory timeframes; adjudication available if dispute. Failure to deliver a valid payment schedule results in payment liability without setoff.

    Who's responsible
    Head contractor + project director
    Frequency
    Per progress payment cycle
    Penalty
    Statutory liability for full claim if no schedule lodged on time; adjudication awards; injunctive relief.
  15. 15

    Long Service Leave portable schemes (state — e.g. NSW Long Service Corporation BCISS / VIC CoINVEST / Qld QLeave / WA MyLeave)

    Register construction workers with the state portable long-service-leave scheme. Pay employer levy quarterly. Most states levy 1.5-3% of construction wages.

    Who's responsible
    Payroll + HR
    Frequency
    Quarterly levy returns
    Penalty
    Late-payment interest + state-specific penalties.
  16. 16

    WHS Regulations, Pt 7.1 — Hazardous chemicals (incl. silica dust)

    Manage WHS risk of hazardous chemicals: GHS classification, SDS, control measures. Engineered-stone ban commenced 1 July 2024. Silica WEL reduced to 0.05 mg/m³ from 1 December 2026. Health monitoring + medical surveillance for silica-exposed workers.

    Who's responsible
    PCBU + safety manager
    Frequency
    Continuous
    Penalty
    WHS Cat-tiered: Cat 1 up to $14.45M (body corporate). Engineered-stone ban breach: up to $50K per state.
  17. 17

    WHS Regulations — Plant operator competency + working at heights

    Workers operating plant must be competent: HRWL + training. Working at heights ≥2m requires fall-prevention or fall-arrest system; risk assessment + control hierarchy.

    Who's responsible
    PCBU + site supervisor
    Frequency
    Continuous
    Penalty
    WHS Cat-tiered.
  18. 18

    Mining-specific WHS — Mining Safety Acts (Coal Mining Safety and Health Act 1999 (Qld) / Coal Mining Health and Safety Act 2002 (NSW) / Mines Safety and Inspection Act 1994 (WA))

    Comply with mining-specific safety regime: site senior executive (SSE) at every mine, statutory positions (e.g. underground manager, ventilation officer), incident-notification regime, principal hazard management.

    Who's responsible
    Mine manager / SSE + Officers
    Frequency
    Continuous
    Penalty
    Cat 1: Up to ~$3M + 2 years (mining-specific in NSW/Qld); industrial manslaughter overlay where applicable.
  19. 19

    Mining rehabilitation bond regimes (state)

    Lodge financial assurance (rehabilitation bond) for each mining lease. Bond calculated against approved Mine Closure Plan or Mining Operations Plan. Annual update.

    Who's responsible
    Tenement holder + CFO
    Frequency
    On grant + annual recalculation
    Penalty
    Forfeiture of tenement; bond claimed by state for rehabilitation costs.
  20. 20

    Environment Protection Act 1970 / 2017 (Vic) + state environmental authority regimes

    Hold and comply with state environmental authority / EPA licence for prescribed-premises activities (e.g. crushing, screening, batching, dewatering). Comply with conditions: discharge limits, monitoring, reporting.

    Who's responsible
    Site manager + Environment Manager
    Frequency
    Continuous; periodic monitoring + reports per licence
    Penalty
    State-specific; up to ~$3.6M (Vic EP Act 2017) for body corporate.

Deadlines

Pulled from the Rules Mate compliance calendar. Click through for the full deadline page.

Forms and regulator portals

Direct links to the lodgement forms and regulator portals. Rules Mate does not host copies — we link to the official source.

  • State WHS regulator — plant registration portals

    State portals for high-risk plant registration. Each state regulator maintains its own portal.

    Open portal →
  • State HRWL licence application portals

    State portals for High Risk Work Licence applications and renewals.

    Open portal →
  • DCCEEW EPBC Act referral portal

    Lodge EPBC Act referral for proposed controlled actions affecting Matters of National Environmental Significance.

    Open portal →
  • Clean Energy Regulator EERS / NGER reporting

    Lodge NGER reports and Safeguard Mechanism information via the Emissions and Energy Reporting System.

    Open portal →
  • Modern Slavery Statements Register

    Lodgement portal for entities at or above the $100M consolidated revenue threshold.

    Open portal →
  • NHVR HVNL portal

    Chain of Responsibility resources and accreditation under the National Heavy Vehicle Accreditation Scheme.

    Open portal →
  • State Security of Payment Act portals

    State portals for adjudication applications under SOPA.

    Open portal →

Free tools that help

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What changes 2025–2026

1 July 2024 — Engineered-stone ban

The use, supply and manufacture of engineered stone became prohibited in Australia.

Late 2024 onwards — Industrial manslaughter rollout

NSW criminalised industrial manslaughter from June 2024. SA, Qld and Vic already had standalone offences. NT and ACT also operate equivalent offences. WA operates under Cat 1 WHS rather than an industrial-manslaughter offence per se.

1 December 2026 — Silica WEL halved

The workplace exposure limit for respirable crystalline silica falls to 0.05 mg/m³ from 0.1 mg/m³. Triggers control-measure upgrades for crushing, batching, tunnelling, drilling and demolition.

31 October annually — NGER reporting deadline

Annual NGER reporting due 31 October for the prior 1 July–30 June year (≥50kt threshold).

31 December 2026 — Modern Slavery Statement (FY-end 30 June)

For 30 June year-end mining and construction reporting entities, the FY26 statement is due 31 December 2026.

Watch — Modern Slavery Amendment Bill 2024

If passed, lowers reporting threshold from $100M to $50M consolidated revenue.

Ongoing — Safeguard Mechanism baseline decline

Reformed Safeguard Mechanism baselines decline 4.9%/year from FY24-FY30 for facilities ≥100kt. Plan for ACCU/SMC surrender.

Watch — Aboriginal Cultural Heritage Act 2021 (WA) under review

The 2021 WA Aboriginal Cultural Heritage regime was repealed and the previous Aboriginal Heritage Act 1972 reinstated with amendments — monitor further reforms.

In-depth reading

24 Rules Mate articles tagged to this playbook.

Frequently asked

Does s 19 WHS apply to every subcontractor on a multi-tier construction site?

Yes. Every PCBU has the primary duty under s 19 — concurrent with every other PCBU on the same site. The head contractor, each subcontractor, the principal, and any labour hire each owe s 19 duties to workers and other persons. The duty extends to workers of the other PCBUs to the extent of practicable control.

What's the practical line between Cat 1 (reckless) and Cat 2 (failure to comply causing serious risk)?

Cat 1 requires recklessness — conscious disregard of substantial risk of death or serious injury. Cat 2 is the breach of a duty + exposure to risk of death or serious injury, without recklessness. The dividing line is the mental element. Industrial manslaughter requires negligence or recklessness causing death.

When does our project trigger an EPBC Act referral?

Where the action is likely to have a significant impact on a Matter of National Environmental Significance: listed threatened species, listed threatened ecological communities, listed migratory species, World/National Heritage, Ramsar wetlands, Commonwealth marine areas, nuclear actions, large coal/gas/water-resource impacts. Significant-impact threshold is judged against DCCEEW Significant Impact Guidelines.

Does the engineered-stone ban affect existing benchtops in place?

No. The ban prohibits new use, supply and manufacture from 1 July 2024 — existing in-place benchtops are not retroactively unlawful, but removal/modification of existing engineered stone is now strictly regulated.

How does Chain of Responsibility under HVNL apply to a mining company that doesn't operate the trucks?

The mining company is the consignor of the load. As consignor, it has a positive duty to take reasonable steps to ensure no contravention of mass, dimension, load restraint, fatigue and speed rules — including in its scheduling, loading, and consignment instructions. Outsourcing to a logistics provider does not displace the consignor's CoR duty.

Are the state SOPA regimes really worth complying with — can't we use general contract law?

Yes — fail to deliver a payment schedule on time and the claimant becomes entitled to the full claim amount with no contractual defence. The SOPA regimes deliver a 'pay now, argue later' adjudication outcome that bypasses ordinary contractual dispute resolution.

How does NGER interact with ASRS climate disclosure?

NGER captures verified facility emissions; ASRS captures Scope 1, 2 and 3 in financial reports. NGER data feeds Scope 1 and 2 in many cases. Both will become reconcilable for Group 1 (1 Jan 2025) / Group 2 (1 July 2026) / Group 3 (1 July 2027) reporters.

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Last verified: 9 June 2026

Rules Mate provides citation-first reference material, not legal advice. Always consult a qualified professional for specific obligations.