Record keeping and audit requirements

Records kept about the use of each vehicle
Records of a documented maintenance program, including other maintenance
Records kept about each use of vehicle
Record keeping requirements specific to buses
Driver training
Restricted driver authorisation records
Incident management reports
Safety management plans
Fatigue management records
Audit requirements for compliance obligations
Summary of audit requirements
References

Records kept about the use of each vehicle

Operator must keep a written record of the following information for each use of the vehicle used to provide the service:

the vehicle used
the registration number of the vehicle
the date and time of the use of the vehicle
the name of each driver who used the vehicle
if the driver holds a driver authorisation other than a restricted driver authorisation—the driver’s driver authorisation number.

Records of a documented maintenance program, including other maintenance

The operator must make and keep written records evidencing that they meet the requirements for documented maintenance programs and all maintenance, whether or not performed under the documented maintenance program.

Written records include:

details of the servicing and maintenance performed
daily pre-trip inspections
defect reporting and clearing records
details of all maintenance, whether or not it is performed under the documented maintenance program.

For further details regarding these obligations refer to Maintenance of road-based public passenger vehicles on the Operator accreditation vehicle requirements webpage.

Retention period for documented maintenance records

For buses

Maintenance records must be kept for 5 years after the last maintenance is performed on the bus.

For all other vehicles

Records must be kept for the entire period the vehicle is used to provide the service.

Statement and endorsement by prescribed inspection entity for bus repairs

Where structural repairs have been conducted on a bus, the operator must ensure the maintenance record includes:

a written statement by a prescribed inspection entity stating the name and qualification of each person who performed the repairs.

If a prescribed inspection entity inspects a bus and considers it to be in satisfactory condition:

the operator must obtain an endorsement from the inspection entity on the maintenance record
the endorsement must state that the bus has been inspected and is in satisfactory condition
the endorsement must be signed and dated by the prescribed inspection entity.

For information regarding structural repairs due to corrosion or accident damage, refer to Structural inspections and the repair of heavy buses on the on the Operator accreditation vehicle requirements webpage.

For information regarding refurbishments and life extensions refer to Service classifications, age, design and life extension of buses on the Operator accreditation vehicle requirements webpage.

Driver training records

The operator must keep records showing evidence that:

Introductory training was provided to each person before they drove a vehicle used to provide the service. For example, a training book showing the date, time and place the driver was given introductory training.
Supplementary training was provided to each driver within two months of completing the introductory training.

Operators who drive a vehicle used to provide the service must also keep a record of their participation in introductory and supplementary training.

For more information, refer to Driver training notice – training by accredited operators on the Operator accreditation responsibilities webpage.

Restricted driver authorisation records

Courtesy or community transport services must maintain records about any restricted driver authorisation issued by the operator. The operator must keep a written record of:

the name of the person granted restricted driver authorisation
the issue and expiry date of the restricted driver authorisation
any amendments to the restricted driver authorisation made by the operator and date of the amendments
any cancellation of the restricted driver authorisation, reasons for the automatic cancellation of the restricted driver authorisation and details of the notice of cancellation
the driver licence number including the state or country of issue of the holder of the restricted driver authorisation.

Read more about Restricted driver authorisation on the Operator accreditation responsibilities webpage.

Incident reports

Operators must write and maintain a copy of an incident report.

Read more about Incident report writing and further requirements for school services on the Operator accreditation responsibilities webpage.

Safety management plans

For information on record keeping requirements for safety management plans please refer to the Safety obligations for road-based public passenger services webpage.

Fatigue management records

Passenger transport vehicles regulated under HVNL

Fatigue-related heavy vehicle operators must provide fatigue management records (e.g., work diaries, driver work/rest hours) as required under Heavy Vehicle National Law (Queensland) (HVNL) on request.

Under HVNL, a fatigue-regulated bus is a heavy motor vehicle that:

is built or fitted to carry more than 12 adults (including the driver)
weighs more than 4.5 tonne.

Refer to o the Heavy vehicle fatigue management - bus industry webpage for more details.

Fatigue related heavy vehicle operators that comply with the Heavy Vehicle National Law, are exempt from additional fatigue-related record-keeping requirements under the Transport Operations (Passenger Transport) Regulation 2018.

Passenger transport vehicles not regulated under HVNL

Passenger transport vehicles not regulated under HVNL include:

a vehicle that is 4.5 tonne or less
a heavy vehicle over 4.5 tonne, if it is built or fitted to carry less than 12 adults (including the driver).

Operators must maintain written records of:

driver authorisation numbers.
days and times drivers are driving or available to drive (e.g., on duty, connected to booking systems, or travelling to pick up passengers).

Retention period:

Fatigue management records must be retained for a minimum of 2 years after the relevant driving period.

Reporting requirements:

The chief executive may request fatigue management records for a specified period.
Operators must provide the requested records within 28 days.

False or misleading information:

It is an offence to provide false, misleading, or incomplete information in fatigue management records.

Audit requirements for compliance obligations

Frequency and purpose of audits

The department may issue audit notices as often as reasonably required to assess operator compliance. Audits may focus on:

providing the service
a motor vehicle used to provide the service
to verify information given to the chief executive or the authorised person about the duty holder’s business activities in relation to providing the service.

Audit notices

Operators will receive an audit notice that includes the following details:

The purpose of the audit.
The period during which the audit will be conducted.
Confirmation that a report of the audit will be provided to the duty holder.
Any other matters prescribed by regulation.

As an operator you must cooperate with all reasonable requirements during the audit process.

Summary of audit requirements

The Transport Operations (Passenger Transport) Act 1994 (PT Act) and Transport Operations (Passenger Transport) Regulation 2018 (PT Regulation) establishes a framework to ensure the safety, reliability, and compliance of public passenger services in Queensland. Under the PT Regulation, operators and duty holders are subject to specific audit requirements to verify adherence to accreditation standards, safety management plans, fatigue management obligations, and other operational responsibilities. These audits are designed to promote accountability and maintain high standards of service delivery.

The following table summarises the key obligations for meeting audit requirements.

General obligations

Reference	Requirement	Online topic
PT Regulation s221	Display of OA and identification correctly.	Operator accreditation responsibilities - Display of operator accreditation number on vehicles.
PT Act s27A	System or process to ensure drivers have current driver authorisation of appropriate class.	Operator accreditation - Checking currency and category of driver authorisation.
PT Regulation s59B	Reasonable steps to advise a driver of a bus that carries standing passengers that the bus is specifically designed and constructed to carry standing passengers	Operator accreditation vehicle requirements – Standing passengers and buses carrying school students on certain roads.
PT Regulation s18R	Compliance with Code of Conduct for school students (if applicable).	Driver authorisation responsibilities – Code of conduct for school students travelling on buses
PT Regulation s227	Retention of restricted driver authorisation records (community and courtesy only, if applicable).	Operator accreditation responsibilities - Record keeping and audit requirements.
PT Regulation s18H	Reasonable steps to ensure that no more than 1 passenger sits in any adult seat in a vehicle used to provide the service (unless the vehicle is a bus, where 3 children who appear 12 years of age or under may sit in a bench type bus seat designed for 2 adults) or an infant passenger may occupy the same seat as another passenger if the vehicle is a bus.	Operator accreditation responsibilities – Driver training notice – training by accredited operators Driver authorisation responsibilities - Driver authorisation responsibilities summary.

Training requirements

Reference	Requirement	Online topic
PT Regulation s18J (1) & (3)	Provide introductory training to any person who will drive a vehicle for your service. Ensure the training follows the requirements outlined in the Driver training notice – training by accredited operators.	Operator accreditation responsibilities – Driver training notice – training by accredited operators
PT Regulation s18J (2) & (3)	Provide supplementary training within 2 months after the driver completes their introductory training. Ensure the training meets the requirements in the Driver training notice – training by accredited operators.	Operator accreditation responsibilities – Driver training notice – training by accredited operators

Vehicles

Reference	Requirement	Online topic
PT Regulation s226	Records of vehicle use, including driver details.	Operator accreditation responsibilities - Record keeping and audit requirements.
PT Regulation s18I(2)(a)	Documented maintenance program with records of servicing and other maintenance of the vehicle to a standard that complies with, or exceeds, the servicing and maintenance program specified by the vehicle’s manufacturer.	Operator accreditation vehicle requirements – Maintenance of public passenger vehicle.
PT Regulation s18I(2)(b)	Documented maintenance program including daily pre-trip inspections that identifies defects in relation to the vehicle that may endanger public safety or substantially reduce passenger comfort; and that is of a standard appropriate to an experienced driver of that general type of vehicle.	Operator accreditation vehicle requirements – Maintenance of public passenger vehicle.
PT Regulation s18I(2)(c)	Documented maintenance program that ensures defects are reported to the operator (beyond pre-trip inspections). Vehicles with defects that endanger public safety are not returned to service until fixed. Defects that reduce passenger comfort are fixed within a reasonable time. All actions taken to fix defects are recorded.	Operator accreditation vehicle requirements – Maintenance of public passenger vehicle.
PT Regulation s18I (3) & (4)	Maintain written records of all servicing and maintenance performed on each vehicle, whether or not it is part of the documented maintenance program.	Operator accreditation vehicle requirements – Maintenance of public passenger vehicle.
PT Regulation s18G	A system or process to ensure vehicle owners have a Certificate of Inspection (COI) as compliant with Transport Operations (Road Use Management—Vehicle Standards and Safety) Regulation 2021, section 71.	Operator accreditation responsibilities - Record keeping and audit requirements.

Heavy buses: warning signs and lights

For vehicles providing school services outside the defined urban area

Reference	Requirement	Online topic
PT Regulation	Ensure warning signs and lights are fitted correctly on buses. Division 19 s111 This requirement applies to a vehicle that is a bus used mainly for carrying children other than a bus fitted with warning lights before July 1999	Operator accreditation vehicle requirements – Warning lights and signs on school buses outside a defined urban area.
PT Regulation Division 19 s112	Ensure that warning signs and lights on school buses operate correctly, particularly when the doors are open.	Operator accreditation vehicle requirements – Warning lights and signs on school buses outside a defined urban area.

Heavy buses: structural inspections and repairs.

Reference	Requirement	Online topic
PT Regulation, Schedule 1AA Part 3 Division 1 & 2 For heavy buses older than 25 years. Where there is a 5-year service life extension or an age zero refurbishment service life extension	Ensure record of grant and certificates issued by prescribed inspection entity.	Operator accreditation vehicle requirements – Structural inspections and repair of buses. Service classifications, age, design and life extension of buses.
PT Regulation, Schedule 1AA Part 4 s22	Ensuring that for a heavy bus that is 20 years old but before it is 21 years old, a prescribed inspection entity has inspected the body framework for signs of weakening caused by rust or incorrect repair.	Operator accreditation vehicle requirements – Structural inspections and repair of buses.
PT Regulation, Schedule 1AA Part 4 s24 & Part 5 s26	Where structural repairs were required on the buses due to corrosion or accident damage, the repairs inspected by a prescribed inspection entity before any painting of the frame or refitting of the body panels.	Operator accreditation vehicle requirements – Structural inspections and repair of buses.

Fatigue management

Reference	Requirement	Online topic
PT Regulation s 77C (2) & s77D (1) (a) (b)	Light vehicles: fatigue-related a duty holder must keep a written record of the following information about each driver of a motor vehicle used to provide a fatigue related service: (a) the driver’s driver authorisation number; (b) the days and times the driver is driving, or is available to drive, the motor vehicle used to provide the service. Heavy vehicles: a written record of a record kept under the Heavy Vehicle National Law (Queensland), chapter 6, part 6.4, Division 3 relating to drivers of a fatigue-related heavy vehicle, within the meaning of that Law.	Operator accreditation vehicle requirements - Record keeping and audit requirements.

Safety duties and safety management plans (SMP)

Reference	Requirement	Online topic
PT Act, part 2 (safety duties), part 3 (SMPs), part 4 (audits) and part 5 (directions to comply)	Outlines the legal obligations of responsible duty holders and duty holders for road-based public passenger services.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation s77G	An SMP must be developed by the responsible duty holder having regard to the people involved in providing the service (including any other duty holders), the vehicles used to provide the service, and any other relevant activities related to providing the service.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation s77J(1)(b)	The SMP, and any associated documents related to the SMP, must be made accessible to the chief executive or an authorised person on request.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation s77H(1)	The SMP must be in writing (hard copy or electronic).	Safety obligations for road-based public passenger services \| Business Queensland
PT Act 67ZB (1) (a)	The responsible duty holder must identify and describe each hazard arising from the provision of the service in their SMP.	Safety obligations for road-based public passenger services \| Business Queensland
PT Act 67ZB (1) (b)	The responsible duty holder must assess the safety risks that might arise from exposure to each identified hazard in their SMP.	Safety obligations for road-based public passenger services \| Business Queensland
PT Act 67ZB (1) (c)	The SMP must outline the actions to be taken to eliminate the safety risks, or to the extent it is not reasonably practicable to eliminate the safety risks, minimise those risks.	Safety obligations for road-based public passenger services \| Business Queensland
PT Act 67ZB (1) (d)	The SMP must clearly identify the person, or class of persons, responsible for taking each of the actions outlined for eliminating or minimising safety risks.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation s77I	The SMP must state the day on which it takes effect.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation s77J(1)(a)	The SMP, and any associated documents, must be accessible to all other duty holders for the service.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation s77K (1) & 276A (3-year review)	The responsible duty holder must conduct a comprehensive review of a SMP every 3 years from the day on which the plan takes effect. Where a comprehensive review is conducted, the responsible duty holder must ensure the outcomes of the review, and the reason for conducting the review, are included in a written report to be kept by the responsible duty holder.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation s77K (2) (a), (3) & 276A (material change)	The responsible duty holder must conduct a review of the safety management plan, to the extent necessary, at any time before the 3-year review required if: there has been, or will be, a material change in the provision of the road-based public passenger service provided by the responsible duty holder. Where a review is conducted due to material change, the responsible duty holder must ensure the outcomes of the review, and the reason for conducting the review, are included in a written report to be kept by the responsible duty holder. If a safety management plan needs to be amended or replaced as a result of a review conducted the plan must be amended or replaced as soon as reasonably practicable after the review is completed.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation PT Regulation s77K (2) (b), (3) & 276A (prescribed incident)	The responsible duty holder must conduct a review of the safety management plan, to the extent necessary, at any time before the 3-year review required if: there has been a prescribed incident. Where a review is conducted due to a prescribed incident, the responsible duty holder must ensure the outcomes of the review, and the reason for conducting the review, are included in a written report to be kept by the responsible duty holder. If a safety management plan needs to be amended or replaced as a result of a review conducted the plan must be amended or replaced as soon as reasonably practicable after the review is completed.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation PT Regulation s77K (2) (c), (3) & 276A (notifiable incident)	The responsible duty holder must conduct a review of the safety management plan, to the extent necessary, at any time before the 3-year review required if: there has been a notifiable incident under the Work Health and Safety Act 2011, section 38. Where a review is conducted due to a notifiable incident, the responsible duty holder must ensure the outcomes of the review, and the reason for conducting the review, are included in a written report to be kept by the responsible duty holder. If a safety management plan needs to be amended or replaced as a result of a review conducted the plan must be amended or replaced as soon as reasonably practicable after the review is completed.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation PT Regulation s77K (2) (d), (3) & 276A (duty holder has reported a hazard in writing)	The responsible duty holder must conduct a review of the safety management plan, to the extent necessary, at any time before the 3-year review required if: a duty holder has reported a hazard in writing arising from the work carried out by the responsible duty holder in providing the service and the hazard is not already identified or not compliant with SMP requirements. Where a review is conducted due to a notifiable incident, the responsible duty holder must ensure the outcomes of the review, and the reason for conducting the review, are included in a written report to be kept by the responsible duty holder. If a safety management plan needs to be amended or replaced as a result of a review conducted the plan must be amended or replaced as soon as reasonably practicable after the review is completed.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation PT Regulation s77K (2) (e), (3) & 276A (duty holder has reported a hazard in writing)	The responsible duty holder must conduct a review of the safety management plan, to the extent necessary, at any time before the 3-year review required if: the responsible duty holder otherwise becomes aware, or ought reasonably to be aware the SMP is not meeting compliance requirements. Where a review is conducted due to a notifiable incident, the responsible duty holder must ensure the outcomes of the review, and the reason for conducting the review, are included in a written report to be kept by the responsible duty holder. If a safety management plan needs to be amended or replaced as a result of a review conducted the plan must be amended or replaced as soon as reasonably practicable after the review is completed.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation s77M	If a SMP is amended, the responsible duty holder must ensure the amendment is recorded in the SMP.	Safety obligations for road-based public passenger services \| Business Queensland
PT Regulation s77L (1)	The SMP must, so far as reasonably practicable, be developed and reviewed in consultation with each other duty holder for the service.	Safety obligations for road-based public passenger services \| Business Queensland
PT Act 67ZC (2)	The SMP must be implemented.	Safety obligations for road-based public passenger services \| Business Queensland

References

Transport Operations (Passenger Transport) Act 1994

Section 27A: A system or process to ensure drivers have current driver authorisation of the appropriate class.
Chapter 6A, Part 2 (safety duties), Part 3 (SMPs), Part 4 (audits), and Part 5 (directions to comply): Outlines the legal obligations of responsible duty holders and duty holders for road-based public passenger services.
Part 2 (safety duties), Part 3 (SMPs), Part 4 (audits), and Part 5 (directions to comply): Outlines the legal obligations of responsible duty holders and duty holders for road-based public passenger services.
Section 67ZB(1)(a): The responsible duty holder must identify and describe each hazard arising from the provision of the service in their SMP.
Section 67ZB(1)(b): The responsible duty holder must assess the safety risks that might arise from exposure to each identified hazard in their SMP.
Section 67ZB(1)(c): The SMP must outline the actions to be taken to eliminate the safety risks, or to the extent it is not reasonably practicable to eliminate the safety risks, minimise those risks.
Section 67ZB(1)(d): The SMP must clearly identify the person, or class of persons, responsible for taking each of the actions outlined for eliminating or minimising safety risks.
Section 67ZC(2): The SMP must be implemented.

Read the full PT Act on the Queensland Legislation website.

Transport Operations (Passenger Transport) Regulation 2018

Section 18G: A system or process to ensure vehicle owners have a Certificate of Inspection (COI) compliant with the Road Use Management—Vehicle Standards and Safety Regulation 2021, section 71.
Section 18H: Reasonable steps to ensure that no more than 1 passenger sits in any adult seat in a vehicle used to provide the service (unless the vehicle is a bus, where 3 children who appear 12 years of age or under may sit in a bench-type bus seat designed for 2 adults) or an infant passenger may occupy the same seat as another passenger if the vehicle is a bus.
Section 18I: Documented maintenance program requirements, including servicing, pre-trip inspections, and defect reporting.
Section 18J: Driver training requirements, including introductory and supplementary training.
Section 18R: Compliance with the Code of Conduct for school students (if applicable).
Section 77C: Fatigue management records for light vehicles.
Section 77D: Fatigue management records for heavy vehicles under the Heavy Vehicle National Law.
Section 77K: Safety management plan review requirements, including material changes and prescribed incidents.
Section 226: Records of vehicle use, including driver details.
Section 227: Retention of restricted driver authorisation records (community and courtesy services).
Section 276: When required, a person must maintain records for at least 5 years and produce the records on request of the chief executive or an authorised person.
Section 276A: Record keeping requirements in relation to reviews of safety management plans.

Read the full PT Regulation on the Queensland Legislation website.

Passenger Transport Regulation 2018 – Schedule 1AA

Part 3, Division 1 & 2: Structural inspections and certifications for heavy buses older than 25 years.
Part 4, Section 22: Inspection of body framework for buses aged 20 years but before 21 years.
Part 4, Section 24 & Part 5, Section 26: Structural repairs due to corrosion or accident damage must be inspected before painting or refitting. Read the full Regulation on the Queensland Legislation website.