What does the new Master Code mean for your business?

In our recent webinar, Aaron Louws, Supply Chain Technical Manager at CoRsafe, and Nathan Cecil, Partner at Holding Redlich, examined the new Code and its practical implications for industry.

Drawing on both operational and legal perspectives, they explored the structural changes in the new Code and what it signals about regulatory expectations going forward.

This article summarises the key insights from that session. If you’d like to hear Aaron and Nathan discuss the changes in more detail, watch the full webinar on demand.

Key takeaways

• The fundamental law hasn’t changed, but expectations have. The primary duty and executive due diligence obligations introduced in 2018 remain the same. But the 2026 Master Code provides clearer guidance on what “reasonably practicable” looks like in today’s heavy vehicle environment.

• The Code shifts from roles to activities. The 2018 Code focused on supply chain roles and four key risk areas. The 2026 Code is structured around 45 transport activities across eight categories, shifting the focus from who you are in the chain to what you do.

• There are significantly more controls. The new Code references more than 500 controls, compared to around 150 in the previous version. This provides clearer guidance on managing risks, but also raises the bar for demonstrating that existing controls are effective. As Nathan explains, businesses don’t need to implement every control listed in the Code, but they do “need to be prepared to demonstrate that the controls they do have in place are as effective, or better than, those in the Code.”

• “Transport activities” are broader than many assume. The primary duty extends beyond operational tasks like loading, unloading or scheduling. It captures the business practices and decisions that shape how transport is planned, resourced and executed. That means offices, boardrooms, hiring practices and safety culture are just as relevant as loading docks or highways.

• Executive accountability remains central. Executives must understand their organisation’s transport activities, associated risks and the effectiveness of controls in place. This is an ongoing obligation, not a one-off training exercise.