What is changing for Subclass 186 (TRT) Stream Australia

The Australian Government has introduced a change to the Employer Nomination Scheme (Subclass 186) TRT stream, which may affect organisations employing Medical Practitioners, CEOs, Corporate General Managers, and Managing Directors.

This change is part of the Migration Amendment (Skilled Visa Reform Technical Measures) Regulations 2025, coming into effect 29 November 2025.

What’s changing?

Previously, employees in exempt occupations could count time spent working in their nominated occupation with a non-sponsoring employer toward the two-year employment requirement for the TRT stream.

From 29 November 2025, this will no longer be allowed.

Now, the entire two-year qualifying period must be completed with an approved work sponsor. Only employment with a business holding an approved Standard Business Sponsorship will count toward eligibility for permanent residency under the TRT stream.

Who could be affected?

• Medical Practitioners or senior executives not currently working for an approved sponsor.
• Employees in exempt occupations who have partially completed their qualifying period with a non-sponsoring employer.

Example:
A medical practitioner on a SC482 visa has spent:

• 1 year with their current employer (approved sponsor)
• 1 year with a previous employer (not an approved sponsor)

Under current rules, both years could be combined to meet the two-year TRT requirement for a Subclass 186 visa.

From 29 November 2025, only the year with the approved sponsor will count. Any time with a non-sponsoring employer will no longer contribute to the two-year requirement.

Who is not affected?

Anyone who has already lodged their Subclass 186 TRT application before 29 November 2025 will not be impacted.

Recommended actions

1. Lodging applications before 29 November 2025
Employees in exempt occupations who are relying on time with a non-sponsoring employer should submit their Subclass 186 TRT application before 29 November 2025.

2. Visa holders not yet eligible
If you cannot meet the two-year requirement before the deadline and are not employed by an approved sponsor, action is needed:

• Ask your employer to become an approved sponsor, or
• Transfer to an employer who already holds Standard Business Sponsorship.

3. Employer workforce review
Employers should:

• Review their workforce for affected employees.
• Ensure they understand the new TRT requirements.
• Lodge Subclass 186 TRT applications before 29 November 2025, where possible, to avoid issues.

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The information provided is a general guide and does not constitute legal or immigration advice; there are many regulations that may apply depending on each individual’s circumstances alongside changes in the industry. It is the user’s responsibility to verify the currency of information. Those seeking advice should engage a MARA registered migration agent.

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