Following our recent article 'Full steam ahead! Interoperability requirements introduced under the Rail Safety National Law,' this update follows the commencement of the Rail Safety National Law National Regulations (Safety Management System) Amendment Regulations 2025 (Regulations) on 1 November 2025, with requirements applying from 28 February 2026. In addition, the Office of the National Rail Safety Regulator (ONRSR), working with the National Transport Commission (NTC) and Rail Industry and Safety Standards Board (RISSB), has released the Draft Guideline on Interoperability of railway operations to support implementation of the new regulations. Consultation on the draft guideline is open until 14 November 2025.
What the Regulations require
Under the Regulations, accredited rail organisations that operate on the NNI must include within their safety management systems (SMS):
- Systems and procedures to identify and consider interoperability matters when planning changes to railway operations on, or that form part of, the NNI; and
- An Interoperability Management Plan (IMP) to ensure any identified interoperability matters are taken into consideration before such changes are made.
The regulations define ‘interoperability matters’ as those relating to the ability of a rail transport operator’s railway systems to operate together with those of other operators, enabling railway operations to be undertaken safely and seamlessly on the NNI.
Who is in scope and how will this be applied
The requirements apply to accredited rail infrastructure managers that form part of the NNI and accredited rolling stock operators that operate on the NNI. Operators determined by the Regulator to be tourist and heritage railway operators are exempt.
ONRSR will notify relevant accredited operators in writing where their railway operations are undertaken on, or form part of, the NNI. If an operator is not notified by the Regulator, the interoperability element and IMP are not required as part of the operator’s SMS.
Timelines and immediate actions
The Regulations commenced on 1 November 2025 and the new requirements apply from 28 February 2026 following a transition period. Ahead of application, operators should:
- Review their SMS and establish an Interoperability of railway operations element that sets out how interoperability matters will be identified and considered when planning changes on the NNI.
- Determine whether planned changes on the NNI will trigger interoperability matters and, where they do, prepare an IMP proportionate to the interoperability impacts and associated safety risks.
- Ensure consultation is undertaken in accordance with section 99 of the Rail Safety National Law when updating the SMS and each time an IMP is developed.
Consultation on ONRSR’s draft guideline to support implementation is open until 14 November 2025.
For guidance on the Regulations and implementation, please contact Chris Mitchell and Larissa Buriak.
We will continue to monitor the regulatory program and provide further updates.
