This paper examines organisational learning from a regulator perspective and claims the need for a system perspective to learning. A system perspective grasps the inter-organisational complexity which makes an important characteristic of the way work, safety and learning is organised in the petroleum sector. The purpose is to describe theoretical perspectives on organisational learning and our working model, demonstrate examples of regulatory activities addressing organisational learning and discuss organisational learning in a regulatory perspective. A system perspective to learning takes into consideration that learning takes place 1) between organisations and organisational units, 2) across different organisational levels, and that 3) learning is being restrained or promoted by various organisational, cultural and environmental aspects. In addition the intertwining of people, systems and processes has to be taken into account when trying to understand how learning happens and how learning manifests itself. Based on a literature review on organisational learning and learning with regards to safety, we propose a system model to organisational learning to illustrate this topic. The model and how it addresses learning and traces of learning will be discussed in relation to empirical data from a sector embracing survey and findings from four PSA audits. Finally, we will discuss factors that might facilitate or restrain organisational learning and implications of the study.