PAW Is Closing - Here's What Australian Employers Need to Do About Psychosocial Risk Next

Psychosocial Risk After PAW: What Compliance Actually Looks Like Now

For roughly 5,000 Australian organisations, the People at Work (PAW) survey wasn't just a wellbeing tool, it was an entire psychosocial risk assessment. When it closes on 2 October 2026, it won't just take a survey offline. For many employers, it will remove the only evidence they had that they were managing psychosocial hazards at all.

The timing is pointed. Psychosocial hazard obligations are now enforceable in every Australian state and territory, and from 1 July 2026, NSW went a step further: its WHS Codes of Practice stopped being guidance and became a legally enforceable benchmark. In a recent myosh Academy session, Ian Fagan (Founder) and Sam McKenzie (Director of Psychosocial Compliance) from Skodel walked HR, WHS and governance professionals through exactly what's changed, and what to do about it.

Why PAW Is Closing, and Why It Matters More Than a Lost Survey

PAW was Safe Work Australia's free, national psychosocial risk survey, a tool many organisations leaned on heavily to consult their workforce and evidence their risk management. According to Fagan and McKenzie, it's being decommissioned for three reasons: it no longer covers all hazards

named in the current PsychosocialCode of practice (e.g sexual harassment and remote or isolated work), participation rates had been declining, and better tools have emerged since it was originally designed.

“It was viewed as the complete psychosocial risk assessment for them in their organisation,” Fagan said of one organisation Skodel had worked with.  

Once the platform closes, historical data, exports and trend history disappear with it, but the underlying legal obligation to identify, assess, control and review psychosocial hazards doesn't pause for a replacement tool.

The Regulatory Landscape Has Shifted Underneath Employers

Every state and territory now has its own psychosocial regulations, built out progressively since NSW introduced the first Code of Practice in 2021, followed by Queensland, WA and Tasmania in 2022, South Australia in 2023, and Victoria, the last state to legislate, in December 2025.

NSW has since gone further again. From 1 July 2026, its Codes of Practice, previously treated by inspectors and courts as guidance on what was “reasonably practicable,” without independent legal application, became directly enforceable. PCBUs must now either comply with an approved Code or demonstrate an equivalent or higher standard through an alternative approach. As McKenzie put it during the session, the practical effect is that “a regulator no longer needs to prove harm occurred,  falling short of the Code may constitute a breach on its own.”

What Regulators Are Actually Testing For

Three real, recent enforcement cases discussed in the session illustrate the pattern. In one, the Royal Australasian College of Physicians was found by SafeWork NSW to have failed to manage bullying allegations within its own board, resulting in a prohibition notice barring directors from contacting staff except through the CEO, and the charity regulator later suspending the incoming president. In another, a ten-month workplace investigation by the NSW Department of Education was itself found to be a psychosocial hazard, after a stood-down worker was given no detail of the allegations against her; the Commission ruled that a single worker's complaint was enough to ground an improvement notice against the department's entire system of work. In a third, a Victorian transport company was fined $1.43 million, with its director personally convicted, after a driver worked 17 consecutive overnight shifts with no system to limit hours or mandate rest.

Across all three, the same six things stand out as what regulators are testing for: a documented system (not a policy nobody uses), real timeliness safeguards rather than “guide only” targets, conduct at every level including the board, evidence that workers were actually consulted, alignment to the Code's four-step process, and a visible communication trail.

What This Means in Practice

Fagan and McKenzie were clear that audit-ready doesn't mean a one-off pulse survey. It means four things: a structured, repeatable system to identify and score hazards; trend evidence built up across multiple assessment periods; findings that are explicitly linked to controls and outcomes; and leadership training grounded in the same framework the organisation assesses against.

For organisations still relying on PAW, the immediate priority is to export and archive any remaining data before the platform closes. From there, the recommended sequence is practical: within 30 days, audit current tools against the Code's named hazards and assign ownership of psychosocial risk reporting internally; within 60 days, run or refresh a risk assessment and stand up risk-banded reporting linked to controls; within 90 days, build a recurring assessment cadence and roll out leadership and board training aligned to the same framework.

myosh's risk and compliance reporting tools are built to support exactly this kind of documented, ongoing evidence trail, turning hazard identification and control tracking into something that can actually be shown to a board or a regulator, rather than scattered across spreadsheets and one-off survey exports.

Key Takeaways

• PAW closes 2 October 2026, for many organisations, that removes their only evidence of psychosocial risk management, not just a survey tool

• Every Australian jurisdiction now has enforceable psychosocial regulations; NSW's Codes of Practice became legally enforceable from 1 July 2026

• Regulators no longer need to prove harm occurred, falling short of the Code can be a breach in itself

• Recent enforcement action shows the duty extends to board and leadership conduct, not just frontline management

• Audit-ready means a documented, repeatable system with trend evidence, not a one-off survey

• A practical 30/60/90-day plan can get most organisations from PAW-reliant to audit-ready

Presenters: Ian Fagan, Founder, Skodel; Sam McKenzie, Director of Psychosocial Compliance, Skodel

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