
With the revised Heavy Vehicle National Law (HVNL) now in place, industry has been navigating the various impacts including mass, dimension and loading, compliance obligations under Heavy Vehicle Accreditation (HVA) and Safety Management Systems (SMS), Euro VI implications, unfit to drive and audits.
Electronic Work Diaries (EWDs) are impacted too, and members have received numerous enquiries from operators trying to understand how this works in practice. It’s important to note, existing approved EWDs can continue to be used after 1 August 2026, the amended HVNL does not make them obsolete. Some of the changes to work diaries impact written diaries and are clerical amendments targeted as simplifying diary entry requirements and aligning with the HVNL generally. The changes summarised by the NHVR in May were:
- Includes Alternative Compliance Hours (ACH)
- Marking the day of the week is now optional
- Marking standard hours is now optional
- Recording work and rest totals is now optional
- Overall updates to align with amended HVNL
- Drivers are no longer required to return a lost or stolen WWD (if found/returned) to the NHVR
What has changed under the new HVNL is accreditation arrangements for operators managing fatigue. Basic Fatigue Management (BFM) and Advanced Fatigue Management (AFM) schemes are being replaced over time by ACH. However, an operator holding valid BFM or AFM accreditation can continue operating under that accreditation until:
- the certificate expires,
- the operator chooses to amend or transition its accreditation; or
- the accreditation is cancelled by the NHVR.
Operators do not need to change their accreditation arrangements solely because the amended law commences on 1 August. However, existing BFM and AFM accreditations cannot be amended or renewed after that date. When an operator’s accreditation requires renewal or amendment, it will need to transition to the new Heavy Vehicle Accreditation scheme and apply for the Alternative Compliance Accreditation (ACA) Fatigue module. This application will need to include an operators proposed ACH, fatigue risk management system, fatigue controls and countermeasures, and the specific risks of their operations.
Operators may also choose to transition before their current accreditation expires. Applications under the new scheme can be submitted through the NHVR from 1 August 2026. To obtain ACA-Fatigue, an operator must first obtain the entry-tier General Safety Accreditation, or GSA. GSA requires the operator to have a whole-of-business Safety Management System. ACA-Fatigue is the next tier and requires that Safety Management System to incorporate a suitable Fatigue Risk Management System.
So, to EWD or not to EWD? The list of positives for the transition to digital records seems to be getting longer, particularly as this allows businesses to identify compliance, fatigue, and scheduling issues early and apply corrective actions to rectify these issues and prove SMS capability. With increasing complexity in managing fatigue within a heavy vehicle operation, any system which reduces human error and manual data entry is going to go a long way. There are some gains operators can get through EWDs recording to the last minute, rather than in 15-minute blocks previously lost to rounding. EWDs also remove miscalculations and warn you before you break a rule. This can assist in reducing honest errors in rounding. Due to camera technology and GPS tracking, it is becoming increasingly easier for law enforcement to establish false work diary records. Hence to ensure maximum compliance and minimum paperwork, the benefits of EWDs are there and the popularity is increasing.
Approved EWD providers are listed on the NHVR website and compliant EWDs are available now.
Additionally, there is a second piece of work known as Generation 2.0 EWD. The revised framework for Generation 2.0 EWD is being worked on between Transport Certification Australia (TCA) and the National Heavy Vehicle Regulator (NHVR) and concerns the future development of EWD requirements. This is not linked to the recent HVNL changes and is a distinct program, transition to Generation 2.0 will be voluntary for operators and more information will be released in the coming weeks.
Thank you to the HVIA Telematics and Data working group for suggesting and to the members who assisted in putting together this article. For HVIA members wishing to join this working group, please contact r.michaud@hvia.asn.au.