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Australia's Fair Work Commission (FWC) has entered new regulatory territory. On 17 August 2026, Minimum Standards Order MS2024/3 took effect, establishing minimum hourly earnings for on-demand delivery workers engaged through platforms such as Uber Eats and DoorDash. The rates range from AUD 31.30 per hour for bicycle and e-bike couriers to AUD 32.00 per hour for motor vehicle operators.
This order applies specifically to employee-like workers performing on-demand delivery through digital labour platforms. But it does not exist in isolation. Under the same proceedings, two additional applications remain active: MS2024/1 covers employee-like workers performing last-mile delivery through digital platforms, and MS2024/2 covers regulated road transport contractors in last-mile delivery. Both are still under consideration, and the Transport Workers' Union (TWU) filed further amended proposed orders for both cases on 13 August 2026.
For businesses operating their own last-mile delivery fleets, the regulatory direction is clear: driver time costs are shifting from implicit to explicit, and how efficiently a delivery operation manages that time will directly affect its cost structure.
Engaged Time: The Cost Metric That Matters Now
The FWC defines "engaged time" under MS2024/3 as the period between a worker accepting a delivery task and completing it. This includes driving to the pickup point, waiting for the order to be ready, transporting it to the customer, and completing the handoff.
The proposed MS2024/2 order takes this concept further with a definition tailored to road transport contractors. Under the TWU's proposed Small Vehicle Minimum Standards Order, "the Services are Performed" covers all time reasonably spent from the Starting Place to the Finishing Place, excluding breakdowns, accidents, and any breaks the contractor chooses to take. The proposed order explicitly notes that breaks include periods where a contractor performs work for another principal contractor or undertakes other activities (Proposed MS2024/2 MSO, Clause 2, "the Services are Performed").
For delivery businesses, both definitions turn operational waste into visible cost lines. A driver who arrives at a warehouse before the order is packed is accumulating service time while producing no throughput. A poorly planned route that adds unnecessary kilometres inflates the cost of every delivery in the run. An incorrect address that triggers a re-attempt doubles the driver time for that order.
What the Proposed MS2024/2 Order Means for Last-Mile Delivery
While MS2024/3 covers food and beverage delivery through digital platforms, MS2024/2 targets the core of Australia's package delivery industry. The proposed order covers contractors operating vehicles with a carrying capacity of up to 3 tonnes performing "the pickup and delivery of Goods" (Proposed MS2024/2 MSO, Clause 2, "Services"). The vehicle categories start at ordinary motor cars, vans, and utilities under 750 kg carrying capacity, which is the typical owner-driver courier setup. Specialised vehicles such as refrigerated trucks, tankers, and cash-in-transit vehicles are excluded (Proposed MS2024/2 MSO, Schedule 2).
The parties filing submissions in MS2024/1 and MS2024/2 include Amazon, Australia Post, StarTrack, and Aramex, which confirms that the proceedings are directly concerned with Australia's major parcel delivery networks and the owner-driver contractors who service them.
Proposed minimum rates
The TWU's proposed minimum safety net rates for MS2024/2 are significantly higher than the MS2024/3 on-demand delivery rates, because they incorporate both a labour component and a vehicle cost component. For vehicles up to 5 years old, the proposed hourly rates range from AUD 42.17 (under 750 kg) to AUD 46.35 (1.5 to 3 tonnes). For vehicles 6 years and older, the rates range from AUD 41.01 to AUD 44.51 (Proposed MS2024/2 MSO, Clause 18.1).
The rate structure is broken out in Schedule 3: a uniform labour component of AUD 36.91 per hour across all vehicle classes, plus fixed and running costs that vary by vehicle size and age, from AUD 4.10 to AUD 9.44 per hour (Proposed MS2024/2 MSO, Schedule 3). This makes the cost logic transparent: the labour floor is the same regardless of vehicle, and the vehicle cost component scales with size and depreciation.
Record-keeping obligations
The proposed order requires principal contractors to maintain records demonstrating that contractors have been paid at least the minimum safety net rate. The specified records include all invoices, start and finish times, gross and net amounts paid, and deductions, as well as any written contracts under which the contractor is engaged. These records must be retained for seven years and may be kept in electronic form (Proposed MS2024/2 MSO, Clause 9.2).
Technology and software requirements
Principal contractors may require contractors to provide a smartphone, download software applications required for performing the services, and use those applications as directed (Proposed MS2024/2 MSO, Clause 4.1). This provision establishes a regulatory basis for delivery businesses to mandate the use of dispatch and delivery management software.
Where the Pressure Lands
Five operational areas face the most direct cost pressure when driver time carries an enforceable floor.
Route quality. Suboptimal stop sequencing and path planning inflate per-delivery time. A route optimization algorithm that reduces total drive time by 15% across a 40-stop run compresses the labour cost of that run by a comparable margin. At scale, the difference between optimized and unoptimized routing can define whether a delivery operation is viable.
Pickup wait time. When drivers arrive at merchants or warehouses before orders are packed and ready, service time accumulates without forward progress. Aligning dispatch timing with order readiness is the most direct way to reduce this dead time.
Address accuracy. Incomplete or incorrect delivery addresses cause failed attempts, customer callbacks, and re-routing. Each failure adds a second full delivery cycle of driver time to a single order. Validating addresses at the point of order entry costs far less than absorbing a re-delivery.
Dispatch visibility. Businesses that coordinate drivers via group chats, phone calls, or spreadsheets have no structured data on where time is spent. Without timestamps on task assignment, pickup arrival, departure, and delivery completion, it is impossible to identify which part of the process is consuming the most driver time. The proposed MS2024/2 record-keeping requirements, including start and finish times retained for seven years, make this kind of structured tracking a compliance matter, not just an efficiency preference.
Proof of delivery and records. Time-stamped proof of delivery, driver activity logs, and route completion records serve two purposes simultaneously: operational analysis and regulatory audit readiness.
What Delivery Businesses Can Do Now
MS2024/1 and MS2024/2 have not been decided. The TWU's proposed orders are proposals, not final standards. But the direction of regulatory travel is visible, and the operational improvements that prepare a business for these standards are the same ones that reduce costs today.
Digitize the fulfilment chain. Move from manual dispatch to a system that records every step: order entry, route assignment, driver task sync, pickup confirmation, in-transit status, delivery completion, and exception handling. The proposed seven-year record retention requirement in MS2024/2 makes electronic record-keeping infrastructure a near-term necessity for any delivery business using contractor drivers.
Optimize routes before dispatch. Automated route optimization assigns stops in a sequence that minimizes total drive time and distance. The result is not only faster routes for drivers but a lower per-delivery time cost for the business. Under the proposed rate structure, every unnecessary minute of service time directly increases the minimum payment obligation.
Track driver time at the task level. Record when each task is assigned, started, and completed. The proposed MS2024/2 order specifically requires records of start and finish times. Building this tracking into daily operations now means you will not need to retrofit it later.
Coordinate pickup readiness. Align dispatch timing with order or shipment readiness at the origin wherever possible. A driver dispatched to a warehouse 10 minutes before the shipment is packed loses 10 minutes of service time on every such occurrence. Across a fleet, this adds up quickly.
Maintain auditable records. Even if minimum standards do not yet directly apply to your operation, building a documented, time-stamped delivery process now means you will not need to retrofit compliance infrastructure later.
Where Delivery Management Software Fits
The operational improvements listed above are not manual projects. They require systems that can optimize routes across hundreds of stops, synchronize tasks to driver devices in real time, record timestamps at each stage of the delivery process, capture proof of delivery with photos and signatures, and log exceptions when deliveries deviate from plan.
This is the core function of delivery management platforms like iDirect: route optimization, driver task synchronization, real-time tracking, proof of delivery, customer notifications, and exception logging, connected into a single auditable fulfilment chain. The proposed MS2024/2 technology clause already contemplates that principal contractors may require contractors to use designated software applications. The value of delivery management software is concrete: it is the difference between a delivery operation where every step is tracked, timed, and optimizable, and one where the business only sees the beginning and end of each day.
As Australia's regulatory framework for delivery work continues to develop, businesses with digitized, efficient, and auditable delivery processes will be better positioned than those relying on manual coordination. This holds true regardless of how the final minimum standards for last-mile delivery are written.
References
- Fair Work Commission, Interim On-Demand Delivery Employee-like Worker Minimum Standards Order (MS2024/3), made 11 August 2026, effective 17 August 2026. Available at: TWU regulated worker minimum standards orders applications (MS2024/1-3)
- Transport Workers' Union of Australia, Proposed Further Amended Minimum Standards Order - MS2024/2 (Small Vehicle Minimum Standards Order), filed 13 August 2026. Available at: Small Vehicle Minimum Standards Order (PDF)
- Transport Workers' Union of Australia, Proposed Further Amended Minimum Standards Order - MS2024/1, filed 13 August 2026. Available at the same case page as above.
- Fair Work Commission, Directions in matters MS2024/1 and MS2024/2, issued 6 August 2026. Available at: TWU regulated worker minimum standards orders applications (MS2024/1-3)
- Fair Work Ombudsman, Regulated workers information. Available at: fairwork.gov.au
Uber, Uber Eats, DoorDash, Amazon, Australia Post, StarTrack, and Aramex are trademarks of their respective owners. This article is not affiliated with, endorsed by, or sponsored by any of these companies, the Fair Work Commission, or the Transport Workers' Union. All proposed minimum standards order content referenced in this article is drawn from publicly available documents filed with the Fair Work Commission as of 13 August 2026. The proposed MS2024/2 order is a proposal by the TWU and has not been made or approved by the Commission.