What does the WHS Act require employers to provide in training?

The training duty applies to every person conducting a business or undertaking (PCBU), and it protects workers and other people affected by the work. Under the model laws a PCBU is broader than an employer: it includes companies, partnerships, sole traders, government agencies and many not for profit bodies.

The model WHS laws are in force in the Commonwealth and every state and territory except Victoria. According to Safe Work Australia, the Commonwealth, the ACT, New South Wales, the Northern Territory and Queensland implemented them on January 1, 2012, South Australia and Tasmania on January 1, 2013, and Western Australia's version became operational on March 31, 2022. Each jurisdiction enacts its own Act, so section numbers are consistent but some wording and penalties vary.

This page refers to the Commonwealth text of the Work Health and Safety Act 2011 and the Work Health and Safety Regulations 2011 as at September 2026. Check the equivalent provision in your own jurisdiction before relying on a section number in a policy or training record.

Section 19(3)(f) requires a PCBU to ensure, so far as is reasonably practicable, the provision of information, training, instruction and supervision needed to protect people from work risks. It sits inside the primary duty of care in section 19(1), so training is not a standalone obligation: it is one of the means by which the primary duty is met.

Three features of the wording matter for training design. First, the test is necessity: training is required where it is needed to control a risk, not as a general expectation of annual courses. Second, the duty protects "all persons", which includes visitors, customers and members of the public where the work creates risks for them. Third, training sits alongside instruction and supervision, so a PCBU is expected to combine them in proportion to the risk and the experience of the worker.

Regulation 39 then sets the standard the training must meet. The PCBU must ensure that information, training and instruction provided to a worker is suitable and adequate having regard to the nature of the work, the nature of the risks at the time the training is provided, and the control measures implemented. It must also ensure, so far as is reasonably practicable, that the training is provided in a way that is readily understandable by the people receiving it.

• Tied to the work: generic content that does not reflect the actual tasks is unlikely to be suitable and adequate.
• Tied to current risks: training must reflect the risks at the time it is delivered, so it needs review when work, equipment or hazards change.
• Tied to the controls: workers must understand the specific control measures the PCBU relies on, such as a safe work procedure or a permit system.
• Understandable: language, literacy, format and delivery must suit the audience, which can mean translated or practical delivery.

Officers must exercise due diligence to ensure the PCBU complies, and section 27(5) defines due diligence to include verifying that safety resources and processes are provided and used. For boards and executives, that means seeking evidence that training is happening and working, not only that a training policy exists.

Section 27(5) lists reasonable steps that include acquiring and keeping up to date knowledge of WHS matters; understanding the operations and their hazards and risks; ensuring the PCBU has and uses appropriate resources and processes to eliminate or minimize risks; ensuring processes exist to receive and respond to information about incidents, hazards and risks; ensuring processes exist for complying with duties; and, in paragraph (f), taking reasonable steps "to verify the provision and use of the resources and processes" in the earlier paragraphs.

Paragraph (a) also creates a learning need for officers themselves. Directors are expected to keep their own WHS knowledge current, which is why many organizations include officer briefings in their training matrix and report training coverage to the board. A method for that reporting is set out in how to report training compliance to the board.

Victoria has not adopted the model WHS laws, but its duty is substantively similar. Section 21(2)(e) of the Occupational Health and Safety Act 2004 (Vic) requires an employer to provide the information, instruction, training or supervision employees need to perform their work safely and without risks to health, so far as is reasonably practicable.

The WorkSafe Victoria summary of general duties describes the employer duty as providing "information, instruction, training or supervision needed for them to work safely and without risks to their health". Under section 21 the duty extends to independent contractors and their employees for matters the employer controls.

The practical differences are in terminology and structure. Victoria uses "employer" and "employee" rather than PCBU and worker, and it has its own regulations. From December 1, 2025, for example, the Occupational Health and Safety (Psychological Health) Regulations 2025 limit how far a Victorian employer can rely on information, instruction or training to control psychosocial risks. That rule is explained in psychosocial hazard training requirements.

Beyond the general duty, the WHS laws contain specific training obligations for particular roles and hazards. The most common ones for a training manager are listed below; the Regulations also contain hazard specific duties for areas such as hazardous chemicals, confined spaces and plant.

Safe Work Australia's model Code of Practice: How to manage work health and safety risks (November 2024 edition) adds practical guidance on the standard expected. It says training must cover "the nature of the work, the associated risks and the control measures", and that training should require workers to demonstrate they are competent in performing the task. Codes of practice have legal effect only where approved in a jurisdiction, but regulators and courts can refer to them as evidence of what is known about a risk and how to control it.

The strongest evidence links each training activity to a specific risk and control, and shows the worker could perform the task safely afterward. Attendance lists alone show that training occurred, not that it was suitable and adequate.

The table below is an illustrative mapping of the legal requirements to learning outcomes and assessment evidence. It is a planning template, not legal advice, and the examples should be replaced with the organization's own risks and controls.

The model code also lists training records among the information to keep when documenting risk management. A practical records approach is described in how to prepare training records for an audit, and the difference between recording attendance and confirming capability is covered in completion tracking vs competency verification.

Inadequate training can support both a breach of regulation 39 and a breach of the primary duty, which carries the heavier penalties. In the Commonwealth Regulations, regulation 39 is a strict liability offense with a tier E monetary penalty.

Failure to comply with a health and safety duty is prosecuted under the category offenses in sections 31 to 33 of the Act, graded by the seriousness of the risk and the level of fault. The Commonwealth Act also contains an industrial manslaughter offense in section 30A for PCBUs and officers whose conduct breaches a health and safety duty and causes a death. Several states and territories have their own industrial manslaughter provisions, and maximum penalties differ by jurisdiction, so they are not reproduced here.

Training evidence is often central in investigations after an incident. Regulators typically ask what training the worker received, whether it covered the task and the control that failed, when it was last reviewed, and whether the worker's competence was checked. A verification of competency process answers the last question directly.

Knowledge Foundry maps each WHS obligation and control measure to defined concepts, learning outcomes and assessment points before any training content is written. When a risk assessment, procedure or code of practice changes, the affected outcomes and assessments are flagged for review, and the provenance of each item is kept for audit. See audit evidence and compliance programs.