The white card: what the regulation requires, and Victoria

The white card is the most searched construction term in Australia and one of the least accurately described. It is not a licence — the licences that actually gate who may contract to do building work, at what value, are a separate regime entirely, set out in Builder licence thresholds in NSW, Victoria and Queensland. The card does not qualify you to do anything. And in most of the country it does not have an expiry date printed on it — which is why so many people are surprised to find that theirs no longer counts.

What follows is what two of the regulations actually say. New South Wales is representative of the jurisdictions that adopted the model WHS laws; Victoria never did, and its rules are meaningfully different in four places.

New South Wales: two duties, one on top of the other

Part 6.5 of the Work Health and Safety Regulation 2017 creates two separate obligations, both on the person conducting a business or undertaking (PCBU).

Clause 316 — provide the training:

"A person conducting a business or undertaking must ensure that general construction induction training is provided to a worker engaged by the person who is to carry out construction work, if the worker: (a) has not successfully completed general construction induction training, or (b) successfully completed general construction induction training more than 2 years previously and has not carried out construction work in the preceding 2 years. Maximum penalty: (a) in the case of an individual — $3,600, or (b) in the case of a body corporate — $18,000."

"Worker" here carries the wide WHS meaning, reaching a subcontractor on your site as readily as an employee — a broader net than the test that decides whether you actually owe that same person superannuation, covered in the subcontractor rule.

Clause 317 — do not let them start without it:

"(1) A person conducting a business or undertaking must not direct or allow a worker to carry out construction work unless: (a) the worker has successfully completed general construction induction training, and (b) if the worker completed the training more than 2 years previously — the worker has carried out construction work in the preceding 2 years."

Subclause (2) then adds the evidence requirement: the PCBU must ensure the worker holds a card, or, if they have applied and not yet been issued with one, "the worker holds a general construction induction training certification, issued within the preceding 60 days."

The two-year rule is not an expiry date

Read cl 316(b) and cl 317(1)(b) together and the mechanism becomes clear. The card does not lapse because time passed. It stops counting because two years passed without construction work. A carpenter who has been on the tools continuously since 2009 has a valid card. The same carpenter after two years driving trucks does not, and needs the course again.

This is a question about the worker's history, not about a date on a plastic card — which is why it is so often missed at induction. The card is checked; the two years are not asked about.

The course

Clause 5 defines "specified VET course" and, for this purpose, names it:

"(a) in relation to general construction induction training — the VET course Work Safely in the Construction Industry or a corresponding subsequent VET accredited course …"

and "general construction induction training" means "training delivered in Australia by an RTO for the specified VET course for general construction induction training."

Two conditions embedded there: in Australia, and by a registered training organisation. Online training delivered from overseas does not satisfy the definition.

Interstate cards

Clause 318:

"(1) In this Part (other than Division 2), a reference to a general construction induction training card includes a reference to a similar card issued under a corresponding WHS law. (2) Subclause (1) does not apply to a card that is cancelled in the corresponding jurisdiction."

So a Queensland or South Australian card works on a New South Wales site. A cancelled one does not, and the exception in subclause (2) is the reason a site should check the card's status rather than only its existence.

Getting the card

Clause 319 sets out the application: the applicant's name and any other identity evidence required by the regulator, plus either "a general construction induction training certification issued to the applicant" or a written declaration from the trainer on behalf of the RTO. It must be made "within 60 days after the issue of the general construction induction training certification", or at any time if it is accompanied by the trainer's declaration.

Subclause (8) is a useful safety net: "If the regulator has not decided on the application within 60 days, the applicant is taken to hold a general construction induction training card until a decision is made."

Victoria: four real differences

Victoria's Occupational Health and Safety Regulations 2017, Part 5.1 Division 3, cover the same ground under a different name — the construction induction card — and diverge in ways that matter on a mixed-state crew.

1. The worker commits an offence too

Regulation 340: "Subject to regulation 342, a person must not perform construction work at a workplace unless the person holds a current construction induction card."

New South Wales puts the duty entirely on the business. Victoria puts one on the individual as well. Regulation 341 then adds the employer's duty — not knowingly allowing an employee to perform construction work without a current card — at 100 penalty units for a natural person and 500 for a body corporate.

2. The card has unlimited duration, but lapses

Regulation 347 is headed "Construction induction card to be of unlimited duration". Regulation 349 is headed "Lapse of construction induction cards", and the note to regulation 339 states the rule: "Regulation 349 provides that a person's construction induction card lapses if that person has not performed any construction work for any consecutive period of 2 years."

Same substantive outcome as New South Wales, reached the other way round: the card is permanent and the entitlement is not.

3. A 28-day grace period for new starters

Regulation 342(1) is the provision most useful to a Victorian employer taking on someone new to the industry. Regulations 339, 340 and 341 do not apply for 28 days after employment starts if:

"(a) the person has not performed construction work during the preceding 2 years; and (b) the employer makes an application and pays for the person to undertake construction induction training before or during the period of 28 days; and (c) the employer ensures that the person receives direct supervision, directions, demonstrations and monitoring appropriate to the construction work performed by the person for the 28-day period …"

All three limbs. Booking the course is not enough without the supervision; supervising is not enough without booking and paying.

Regulation 342(2) gives a separate 60-day window after a construction statement of attainment is issued, which is the Victorian equivalent of the NSW certification rule.

4. Refusing a valid card is an offence

Regulation 343: "An employer must not knowingly refuse to accept from a person — (a) a current construction induction card; or (b) a construction statement of attainment issued to a person within the previous 60-day period; or (c) a card evidencing completion before 1 July 2008 of the Construction Industry Basic Induction training course; or (d) recognised evidence of construction induction training." Sixty penalty units for a natural person, 300 for a body corporate.

Paragraph (d) is the interstate case. "Recognised evidence of construction induction training" is defined in regulation 5 as "evidence of general occupational health and safety training to the construction industry completed outside Victoria and recognised by the corresponding Authority of the jurisdiction in which the training was completed". Under regulation 342(4) it works if it was issued not more than two years ago, or the person has performed construction work in the preceding two years.

Paragraph (c) is the long tail: a card from the pre-2008 Construction Industry Basic Induction course still has to be accepted, provided under regulation 342(3) the holder has done construction work in the preceding two years.

Who Division 3 does not apply to

Regulation 338 sets the boundary, and it is narrow: everyone at a workplace where construction work is performed, except "visitors to the workplace who are accompanied at all times by a person who has received construction induction training" and "persons temporarily at the workplace to deliver plant, supplies or materials." A note adds that the general duties under the Act still apply to both groups.

What this means for a business running a crew

• Ask two questions at induction, not one. Does the person hold a card, and have they done construction work in the last two years? The second question is the one the regulation actually turns on, and the card cannot answer it.
• Keep the answer with the worker's record. The two-year test is about work history, so it is only checkable if you know when they last worked on a site.
• Interstate cards are fine — cancelled ones are not. In New South Wales, cl 318(2) is the whole exception.
• In Victoria, use the 28 days properly or not at all. Apply, pay, and supervise directly. Two out of three is not the exemption.
• Do not refuse a valid interstate card in Victoria. Regulation 343 makes that an offence in its own right.

None of this is a substitute for the actual health and safety duties. The card is evidence that someone has had a half-day induction. The primary duty — to provide and maintain safe systems of work — sits in the Acts, not in the card, and no card discharges it.

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Checked on 29 August 2026 against the in-force Work Health and Safety Regulation 2017 (NSW) on the NSW legislation register and version 017 of the Occupational Health and Safety Regulations 2017 (Vic), in force 29 July 2026. Queensland, South Australia, Tasmania, the ACT, the Northern Territory, Western Australia and the Commonwealth each have their own regulation on this subject; the NSW provisions above are representative of the model WHS regulations but the section numbers and penalties differ by jurisdiction. This describes the regulations and is not legal or safety advice.

What Zirko does: it keeps employee records and records time per person per day, so who was on which site on which day is documented. What Zirko does not do: it does not track card numbers or expiry, does not verify a card with a regulator, and does not manage induction.