Accreditation comes first, and the line moves by state. In NSW, a vehicle with 12 seats or fewer, counting the driver, comes under point to point transport law: whoever takes bookings for tourist transport needs authorisation as a booking service provider, or has to accept bookings from one. A vehicle with 13 seats or more sits under Transport for NSW's Bus Operator Accreditation Scheme. In Victoria, a bus is a vehicle with seating positions for 10 or more adults including the driver, and Safe Transport Victoria says the operator of a tour and charter bus service needs to be accredited. South Australia splits small and large passenger vehicles at 12 and 13 seats including the driver. Western Australia has no seat threshold: carrying tourists to a published itinerary is tourism passenger transport, the vehicle needs a passenger transport vehicle authorisation, and the driver needs a passenger transport driver authorisation that lasts 12 months. Queensland requires operator accreditation for road-based public passenger services, with taxi and booked hire services exempt. Where a small tour vehicle sits isn't settled on Transport and Main Roads' pages, so ask them. These are the published positions as at October 2026. Check with your state regulator, and see vehicles and passenger liability for the full state table. At least one specialist tour operator wording we place also requires you to tell the insurer if a licence or authorisation you need is lost or restricted.
CTP for the road, public liability for the footpath. Each state and territory runs its own motor accident injury scheme, and they don't work the same way. In NSW, anyone injured in a crash can apply for benefits, at fault or not. The NT's scheme is no-fault and covers all road users injured in a motor vehicle accident in the Territory. Tasmania pays medical and income benefits on a no-fault basis, with access to common law. Queensland's CTP helps people injured in accidents caused fully or partly by another driver, and in WA a passenger can claim where the driver was at fault. Because Queensland, WA and SA run fault-based schemes, an injury can fall between the scheme and your public liability. On the tour operator policies we arrange, public liability excludes injury caused by a registered vehicle altogether. It can respond where the vehicle isn't the cause: a guest who trips on a kerb at a stop, or a fall at a lookout you chose. Damage to the bus, and to other people's vehicles, is commercial motor.
The grey zone is the door. Whether a fall on the bus steps is a motor accident claim depends on how the scheme defines one. In NSW, section 1.4 of the Motor Accident Injuries Act 2017 ties a motor accident to the use or operation of a vehicle, with the injury caused during driving, a collision or action to avoid one, the vehicle running out of control, or a dangerous situation caused by those. Victoria's Transport Accident Commission treats bringing a bus to a standstill, and opening or closing its doors, as part of driving for accidents on or after 19 November 2013. How those definitions apply to a guest stepping down from a parked bus turns on the facts, and it's a question for the scheme's insurer, not something to assume.
Wordings differ on the gap. At least two published Australian tour operator liability wordings keep public liability cover for a vehicle-related injury where the compulsory scheme doesn't respond, as long as the reason isn't a breach of vehicle law. At least one specialist tour operator wording we place does not include that carve-back. Its vehicle exclusion has a narrow exception for loading or unloading beyond the road, and nothing for a vehicle in transit. Insurers treat this differently, and whether the policy quoting your tours responds to a fall while boarding a stationary bus is a point to raise with the underwriter before you bind. Tell the underwriter how your stops work, keep your 'remain seated' briefing in writing, and don't admit fault at the scene. Doing that without the insurer's consent can put cover at risk. For what to hold in your procedures, see risk management for tour operators.