Q1 Do you support the introduction of Option 2? Why/ why not? 

We support Option 2.

AUSMASA assesses any licensing proposal against the licensing design principles set out in Table 1 below.² These principles are drawn from our research and reflect consultation with industry. 

Option 2 is the only option before this consultation that satisfies the principles of risk-proportionate controls and a task-based approach, because it defines scope of work by the task performed rather than by occupation or by vehicle type. Industry has raised concerns around licensing or permit requirements tied to specific qualifications or skill sets. Assessed against the principles above, the main reasons are set out below: 

Q2 What work on EVs should be considered low and high-risk? 

Tables 1 and 2 below set out core electrical tasks by level of electrical hazard. Hazard levels are based on AUSMASA's consultation through the EV Skills Mapping Project. Even where an action or service task is an electrical hazard, it can be actioned once the vehicle has been safely isolated or depowered. Most isolation and depowering can be undertaken by technicians who have undertaken the AURETH101 unit of competency. Tying EV servicing or repair work to a broad-based license will result in wait times and cost blowouts. A cost and wait time escalation will also result in making the EVs less attractive as a light passenger vehicle option, and risk delaying progress toward the federal government's goals of Net Zero.  

Through the EV Skills Mapping Project, AUSMASA is undertaking targeted research to identify key EV servicing occupations, analyse the tasks performed within these roles, and assess the associated electrical and EV-specific skill requirements, depending on the nature of any electrical hazard. The project will produce detailed skills maps for all tasks undertaken on an EV in a workshop setting.⁴ 

The project is due to be finalised in September 2026, and we recommend that the key electrical tasks identified through it be used to inform this Reform. For opportunities for engagement and feedback, please see: https://ausmasa.org.au/research/current-research/ev-skills-mapping-project/

Q3 Is EV servicing considered low-risk?  

The question is framed at the wrong level. "Servicing" is not a single activity, and the answer changes depending on which task is meant. As shown in Tables 1 and 2, EV servicing as a category spans both low-risk and high-risk tasks, so risk should be assessed at the task level rather than assigned to "servicing" as a whole. This is the task-based approach and risk-proportionate controls principles in Table A applied directly: the control should attach to the task, not to the occupation or the vehicle. 

That said, if the question is whether routine EV servicing presents a level of electrical risk that warrants restriction, the answer is no. Routine maintenance is where the bulk of workshop volume sits, and the tasks involved, including logbook servicing, cabin air filter replacement, wiper and washer service, motor coolant work, and state-of-health and state-of-charge diagnostics, are never electrical hazards.  

Even for tasks that are electrical hazards, most are hazardous only until the vehicle is isolated or depowered, and that isolation and depowering is precisely what AURETH101 is targeted to mitigate. Once it is performed, the work proceeds safely. Only a small subset of tasks, principally work inside the high-voltage battery and RESS, live insulation resistance testing, HV fuse and contactor replacement, and damaged battery handling, are hazardous at all times and warrant the higher requirement. 

Treating "EV servicing" as a single restricted category would therefore apply a high-risk control to a large body of work that carries no electrical hazard. That is the outcome the principles in Table A are designed to prevent, and it is why we support Option 2's separation of scopes rather than a category-wide restriction. 

Q4 As motor mechanics have been repairing conventional hybrids for over 20 years, should their scope of work be unrestricted on hybrid vehicles? (not including plug-in hybrid vehicles).  

Yes. AUSMASA's position is that additional licensing should not be imposed unless there is evidence that current arrangements are failing.  

Motor mechanics have serviced, diagnosed and repaired conventional hybrids for two decades without a dedicated licence class or restricted scope. It reflects the quality assurance, hazard mitigation and compliance protocols the automotive industry has developed and endorsed, operating alongside existing WHS duties, which already require employers to ensure workers are trained for the tasks they perform, and Australian Consumer Law guarantees of due care and skill. Not to mention breaches of liability and insurance commitments arising from unsafe working practices, which pose a significant risk to employers if not adequately mitigated.  

The national evidence base points away from new restrictions. The Productivity Commission's final report, Building a Skilled and Adaptable Workforce (Inquiry report no. 110, December 2025), recommends that state and territory regulators replace excessive occupational entry regulations with less burdensome alternatives and identifies motor vehicle repairers in New South Wales, Western Australia and the ACT as one of three priority starting points (Recommendation 4.1).⁵ The Commission also found that for many lower-risk occupations, licensing requirements can be overly restrictive while delivering limited safety benefits. Restricting an established, safely performed scope of work would move NSW in the opposite direction of that recommendation. 

Where a task requires work on an unisolated high-voltage system, the appropriate control is the relevant unit of competency, not a licence class. Those competencies already exist and are already delivered, including through AURETH011 and AURETH101. Adding a licence layer on top of an existing competency requirement does not add safety value; it adds cost and wait time. Consistent with our answers to Q2 and Q3, risk should be assessed at the task level. On that basis, the scope of work for motor mechanics on conventional hybrids should be unrestricted. 

Q5 Are there any risks in changing the scope of work for motor mechanics to permit low-risk EV repair work upon completion of AURETH101?  

The risks of making this change are low. By definition, tasks in Table 2 are never an electrical hazard, and the tasks in Table 1 that are hazardous only until depowered are made safe by the isolation and depowering competencies that AURETH101 delivers. Permitting motor mechanics to carry out this work on completion of AURETH101 aligns the permission with the actual hazard. It does not create a residual risk that some other instrument would have addressed. 

Against that, the risk of not proceeding is material and immediate. Restricting low-risk EV work to holders of a broader qualification would push routine servicing through a training pipeline of 41 RTOs nationally, at $1,500 to $3,000 per technician, in a sector already short of nearly 28,000 technicians, with another 10,500 needed by 2050.⁶ Smaller workshops, which employ the bulk of the workforce and rely on multi-skilled staff, cannot take technicians offline at that scale. The result is longer wait times, higher consumer costs, and a slower EV transition, with no offsetting safety gain. The Productivity Commission's Recommendation 4.1 points NSW toward reducing entry restrictions for motor vehicle repairers, rather than adding them. 

Two implementation matters will determine how well the change works in practice, neither of which is a reason to delay it: 

We support the proposed 3-year transition period. Consistent with the principles of industry-informed design and adaptive and future-ready frameworks, we recommend that the scope definitions adopted under Option 2 be reviewed against the findings of AUSMASA's EV Skills Mapping Project, due for completion in September 2026, and thereafter at intervals that allow the settings to keep pace with EV design, workshop practice, and the battery life cycle. Fixing task classifications now, ahead of that evidence, would lock in assumptions that the project is specifically designed to test.