Self-audit your WHS officer due diligence against the six limbs of section 27(5) of the model Work Health and Safety Act. Rate the evidence you could show in each area to build a due-diligence scorecard, see your priority gaps, and learn what good evidence looks like.
Last verified: 21 June 2026Officer due diligence is a personal duty under s27 of the model WHS Act, owed regardless of whether the PCBU complies with its own duties. This self-audit rates the evidence you could show against the six limbs of s27(5) — knowledge; understanding the operations and risks; resources and processes; receiving and responding to information; compliance processes; and verification — to show your evidence and your gaps. It is distinct from a risk score: it asks whether you could prove you took reasonable steps.
Section 27(5) of the model Work Health and Safety Act says an officer's due diligence includes taking reasonable steps across six areas. Rate the evidence you could actually point to in each one — your scorecard updates as you go.
This audits your evidence and gaps against the six statutory limbs. It is different from a risk score: it asks "could you show you took reasonable steps?", not "how risky is the business?".
For each limb, rate the strength of the evidence you could show today on a four-level scale: No evidence (1), Partial (2), Documented (3), Verified (4).
1. Knowledge of work health and safety matters (s27(5)(a))
1.0 — No evidenceTake reasonable steps to acquire and keep up to date knowledge of work health and safety matters.
Do you actively keep your WHS knowledge current — for example through briefings, training, industry updates or professional development?
Do you stay across changes to WHS laws, codes of practice and regulator guidance relevant to your operations?
2. Understanding the operations, hazards and risks (s27(5)(b))
1.0 — No evidenceTake reasonable steps to gain an understanding of the nature of the operations of the business or undertaking and generally of the hazards and risks associated with those operations.
Do you understand the nature of the operations — what the business actually does and how the work is carried out?
Do you understand the main hazards and risks those operations create for workers and others?
3. Appropriate resources and processes to eliminate or minimise risks (s27(5)(c))
1.0 — No evidenceTake reasonable steps to ensure the PCBU has available for use, and uses, appropriate resources and processes to eliminate or minimise risks to health and safety.
Does the PCBU have appropriate resources and processes available to eliminate or minimise WHS risks — budget, people, equipment and systems?
Are those resources and processes actually used in practice, not just available on paper?
4. Processes for receiving information and responding in a timely way (s27(5)(d))
1.0 — No evidenceTake reasonable steps to ensure the PCBU has appropriate processes for receiving and considering information regarding incidents, hazards and risks and responding in a timely way to that information.
Does the PCBU have processes to receive and consider information about incidents, hazards and risks — reporting channels, registers and reviews?
Does the PCBU respond to that information in a timely way, and do you see evidence it acts on what is reported?
5. Processes for complying with WHS duties (s27(5)(e))
1.0 — No evidenceTake reasonable steps to ensure the PCBU has, and implements, processes for complying with any duty or obligation of the PCBU under the Act.
Does the PCBU have processes in place to comply with its specific WHS duties and obligations under the Act?
Are those compliance processes actually implemented — for example consultation, notification of notifiable incidents, training and record-keeping?
6. Verifying the provision and use of resources and processes (s27(5)(f))
1.0 — No evidenceTake reasonable steps to verify the provision and use of the resources and processes referred to in the limbs above.
Do you independently verify that the WHS resources and processes are actually provided and used — rather than relying only on assurances from others?
Can you point to evidence of that verification — for example audits, inspections, dashboards, or board-level WHS reporting you review and challenge?
Overall due-diligence evidence: No evidence (1.0 of 4)
This is the average of your six limb scores. A higher score means you can point to stronger, verified evidence that you took reasonable steps — it is a self-audit prompt, not a compliance certification or proof of due diligence.
1. Knowledge of work health and safety matters (s27(5)(a))
What good evidence looks like: A record of WHS training, briefings and professional development kept up to date over time, plus a way of staying across changes to WHS law, codes of practice and regulator guidance relevant to the business.
2. Understanding the operations, hazards and risks (s27(5)(b))
What good evidence looks like: Evidence that you understand what the business does and how the work is done — site visits, operational briefings, risk registers and hazard profiles — and can describe the principal hazards and risks of the operations.
3. Appropriate resources and processes to eliminate or minimise risks (s27(5)(c))
What good evidence looks like: Budget, people, equipment and safety processes that are both available and actually used to eliminate or minimise risk — for example funded controls, a working safety management system, and evidence the controls are applied day to day.
4. Processes for receiving information and responding in a timely way (s27(5)(d))
What good evidence looks like: Working reporting channels, an incident and hazard register, and a clear record that information is considered and acted on promptly — with timely corrective actions tracked to completion rather than left open.
5. Processes for complying with WHS duties (s27(5)(e))
What good evidence looks like: Documented processes that map to the PCBU's specific WHS obligations — consultation, notifiable-incident reporting, training, record-keeping — together with evidence those processes are implemented and followed, not just written down.
6. Verifying the provision and use of resources and processes (s27(5)(f))
What good evidence looks like: Active verification that the other five limbs are real — audits, inspections, independent reviews, WHS reporting to the board that you read and challenge — so you are checking the resources and processes are provided and used, not just taking assurances on trust.
Your priority evidence gaps
These limbs are your weakest. Start here to build the evidence that you took reasonable steps under s27(5).
Due diligence is your personal duty
Due diligence is a personal duty. Under section 27 of the model Work Health and Safety Act an officer of a PCBU must exercise due diligence to ensure the PCBU complies with its WHS duties, and section 27(5) sets out the six limbs of reasonable steps that due diligence includes. An officer can be held liable for failing to exercise due diligence regardless of whether the PCBU is itself convicted of an offence — the duty is owed by the officer personally, not by the business alone. The s27 framework applies in NSW, Queensland, South Australia, Tasmania, the ACT, the Northern Territory and the Commonwealth, and is mirrored in Western Australia under the Work Health and Safety Act 2020. Victoria's Occupational Health and Safety Act 2004 does not use the s27 due-diligence framework and treats officer liability differently.
For a risk-based view of director exposure, see the Director WHS Liability Risk Score, check maximum exposure with the Industrial Manslaughter Penalties tool, or browse the Safety Hub for the full set of WHS tools.
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FairWork Mate is an independent commercial service. We are not affiliated with, endorsed by, or associated with the Fair Work Ombudsman, the Fair Work Commission, or any Australian Government agency. Content is general information and estimates only — not legal, financial, or tax advice. Always verify with the Fair Work Ombudsman (13 13 94) or a qualified professional.
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