How to run one health and safety system across the Tasman without tripping over the differences
Because New Zealand's HSWA was modelled on Australia's model WHS Act, a business working in both countries can run a single, consistent health and safety system rather than two unrelated ones. The discipline is in the differences: separate regulators, Australia's nine jurisdictions, industrial manslaughter, psychosocial rules, licensing, and ACC versus state-based workers' compensation. Build one core system, and stay jurisdiction-aware.
The core duties are the same on both sides of the Tasman.
New Zealand's Health and Safety at Work Act 2015 drew directly on the Australian model WHS Act, so the big concepts line up: the PCBU, the primary duty of care, officers' due diligence, the “so far as is reasonably practicable” standard, and duties to engage workers. That shared base is what makes a single system realistic — your policies, registers, risk assessments and training records translate well across the border.
A handful of structural differences need a deliberate overlay.
| Area | New Zealand | Australia |
|---|---|---|
| Law & regulator | One Act (HSWA), one regulator (WorkSafe NZ) | Nine jurisdictions, each with its own Act and regulator (plus Comcare) |
| Industrial manslaughter | No standalone offence | A separate offence in every jurisdiction |
| Psychosocial rules | Covered within the primary duty | Specific psychosocial regulations everywhere |
| High-risk work | Certificates of competence and qualifications | High-risk work licences (HRWL) |
| Injury cover | ACC (no-fault, all injury) | State and Commonwealth workers' compensation |
Each row links to a deeper guide below. Notifiable-event rules and penalties also differ — confirm the specifics for each jurisdiction.
One core system, with jurisdiction overlays.
General information, not legal advice. Requirements differ by country and by Australian jurisdiction, and change over time. Confirm the current position with the relevant regulator.
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Yes, in large part. Because the HSWA and the model WHS Act share the same foundations, a single core system — policies, registers, risk assessments, training and reporting — works across both, provided you overlay each jurisdiction's specific requirements.
Separate regulators, Australia's nine jurisdictions (with Victoria outside the model laws), industrial manslaughter offences in Australia, specific psychosocial regulations, high-risk work licensing versus NZ certificates of competence, and ACC versus state-based workers' compensation.
Not automatically. Australia uses high-risk work licences and New Zealand uses certificates of competence and qualifications; they are not automatically cross-recognised, so confirm the requirement where the work is done.
Yes. ACC has no Australian equivalent. In Australia you must hold the appropriate workers' compensation in each jurisdiction you operate in, separately from your New Zealand ACC obligations.
