AI governance in Australian transport and logistics.

Every party in the chain of responsibility, including operators, schedulers, consignors and executives, must ensure so far as is reasonably practicable the safety of transport activities (s 26C). Where AI drives dispatch, routing or fatigue and hours planning, the duty holder remains accountable and must not let a system pressure drivers to exceed hours, speed limits or drive fatigued. Executives owe a due diligence duty (s 26D).

Telematics, GPS trails, dashcam footage, biometric fatigue monitoring and driver-behaviour scoring are personal and often sensitive information, so collection must be lawful, necessary and disclosed, and holdings secured. NB: the automated-decision transparency duty commences 10 December 2026, which captures algorithmic driver deactivation, pay and allocation.

A PCBU owes a primary duty of care for autonomous vehicles, automated guided vehicles and warehouse robotics, treating them as plant that must be risk assessed. The NSW Work Health and Safety Amendment (Digital Work Systems) Act 2026 received assent on 18 February 2026, but its new s 21A duty commences by proclamation on a date that has not been announced. Once proclaimed it will make AI and algorithmic work allocation an express WHS risk a PCBU must manage, even for third-party software.

The Fair Work Commission can set binding minimum standards for regulated road transport contractors and employee-like gig workers on digital labour platforms, advised by the Road Transport Advisory Group. Algorithmic management of drivers, including app-based allocation, ratings, pay setting and deactivation, is in scope, and eligible workers can challenge unfair deactivation.

Transport is a critical infrastructure sector covering aviation, freight infrastructure, freight services, ports and public transport. Responsible entities for critical freight infrastructure and services must maintain a written all-hazards Critical Infrastructure Risk Management Program addressing cyber, personnel, physical and supply-chain hazards including AI-enabled operational technology, and must report serious cyber incidents.

The ten voluntary guardrails set an expected baseline for accountability, risk and impact assessment, data governance, testing, human oversight, transparency and record keeping when deploying AI in scheduling, routing, autonomous driving or robotics. Adoption is voluntary but supports evidence of reasonable care under the safety and work-health duties.

A national Automated Vehicle Safety Law is being developed with a new in-service safety regulator and duties on automated driving system entities. Transport ministers agreed in November 2025 to conditional automated vehicle deployment from 2027, covering in-service safety, remote operation and modifications. Operators trialling driverless freight should track and prepare for these obligations.

Map every AI system across dispatch, routing, scheduling and fatigue tools to the chain-of-responsibility duty holders and document how each is prevented from pressuring drivers to breach hours or speed limits

Inventory telematics, GPS, dashcam and biometric fatigue data flows, update privacy policies before 10 December 2026 to disclose automated decision making, and tighten security and retention under APP 11

Risk assess autonomous vehicles, automated guided vehicles and warehouse robotics as plant under WHS duties, and apply the NSW digital work systems duty covering algorithmic work allocation

Review algorithmic management of drivers and gig couriers against the Fair Work employee-like and road transport minimum standards, including allocation, pay setting and deactivation

Confirm whether the business is a responsible entity for critical freight infrastructure or services and maintain a compliant Critical Infrastructure Risk Management Program with cyber incident reporting

Adopt the ten Voluntary AI Safety Standard guardrails as an internal baseline, with governance ownership, impact assessments and human oversight for high-impact transport AI

Monitor the Automated Vehicle Safety Law and prepare for in-service safety and remote-operation duties ahead of conditional deployment from 2027