The Australian Logistics Council provided a submission to the Department of Home Affairs on the proposed enhancements to the Critical Infrastructure Risk Management Program Rules. The submission supports strengthening critical infrastructure security but stresses that freight operations are highly interdependent, multi-operator environments with long-lived, capital-intensive assets, complex operational technology and information technology systems, and constrained workforce capacity, particularly in cyber and specialised engineering roles. The submission assesses each proposed enhancement—including specified risk advice, cyber maturity uplift, system segregation, multi-factor authentication, artificial intelligence, supply chain mapping, vendor risk, personnel security, and physical security plans—against operational feasibility, integration with existing safety and regulatory frameworks, and impacts on resilience, continuity, and productivity. ALC calls for reforms to be risk-based, proportionate, and operationally feasible, implemented in stages, and focused on material risks. It recommends leveraging existing safety and risk management systems, adopting a shared-responsibility approach with technology vendors, and providing guidance and support to address workforce and vendor constraints.