The Subclass 186 ENS visa Employer Nomination Scheme visa (subclass 186) Direct Entry stream lets skilled workers, who are nominated by an employer, live and work in Australia permanently.
Counting time on bridging visa for work experience requirements
The Department has confirmed that time spent on a bridging visa can count towards work experience requirements for the purpose of 186.227 if it relates to an occupation identified in a granted 457 or 482 visa. This includes time spent on a BV where a new substantive 457/482 visa application is yet to be decided, and time spent on a BV in association with a Sc 186 TRT application that is subsequently withdrawn.
However, if the applicant is holding a BV and is awaiting an outcome on a Sc 482 visa application in a new occupation, this work experience cannot be counted until the 482 visa in the new occupation is granted.
Related: New 186 TRT Rule Adversely Impacts Medical Practitioners’ PR Pathway
Department Clarifies Employment Requirements for ENS 186 TRT Stream
The Department of Home Affairs has provided clarification on recent changes affecting the Employer Nomination Scheme (ENS) subclass 186 visa under the Temporary Residence Transition (TRT) stream.
What Has Changed?
Recent amendments were introduced to clarify that the required period of employment for the ENS 186 TRT stream must be completed with an approved work sponsor.
This led to questions from migration professionals and visa applicants about whether an employer must remain an approved sponsor for the entire employment period in order for that experience to count.
Department’s Clarification
The Department has now confirmed that:
An employer does not need to remain an approved sponsor for the full duration of the employment period.
Work experience can still be counted as long as the employer was an approved sponsor during the time the employment took place.
This clarification is particularly relevant for applicants whose employers may have later stopped sponsoring workers or allowed their sponsorship approval to lapse.
No Practical Change for Most Applicants
The Department has also confirmed that these amendments were not intended to introduce new requirements. Instead, they were designed to clarify existing arrangements.
Importantly:
Only employment completed with an approved sponsor can be counted toward TRT eligibility.
Work experience with employers that have been barred, sanctioned, or had their sponsorship cancelled cannot be relied upon.
What This Means for You
For most ENS 186 TRT applicants, the practical requirements remain unchanged. If you completed your qualifying employment with an approved sponsor, that experience should still count — even if your employer is no longer an approved sponsor at the time you apply.
If you are unsure how your employment history may affect your ENS 186 application, VisaEnvoy’s registered migration agents can assess your situation and provide clear, personalised advice.
Subclass 186 – Employer Nomination Scheme Visa: Temporary Residence Transition Stream
The purpose of the subclass 186 – Employer Nomination Scheme (ENS) is to allow Australian employers to fill highly skilled positions with suitably qualified migrants. The scheme is designed to assist employers who are unable to meet their skilled Australian workforce needs from the local labour market. The requirements for the Temporary Residence Transition stream of this visa are set out below:
TEMPORARY RESIDENCE TRANSITION STREAMEmployer The business seeking to employ you must: · still be actively and lawfully operating in Australia · genuinely need you to work in the nominated position under its direct control, and have the capacity to employ you in this position for at least two years Position The position to be filled must: · be full-time and available for at least 2 years from the time your visa is granted · be an occupation on the current Medium and Long-term Strategic Skills List (MLTSSL) NOTE: Certain occupations on the MLTSSL will be subject to additional requirements (e.g. salary, type of business operated by employer, nature of position). Please contact us for further details based on your particular circumstances.
· have a salary that is: o at least AU$79,499 per year (excluding any non-monetary benefits) – CSIT: $79,499 (current 2025–26 value: $76,515) AND o at least the annual market salary rate (AMSR) for your nominated occupation NOTES: the AMSR for your nominated occupation (excluding non-monetary benefits) must also be no less than AU$53,900 per year. The AMSR is the salary that an Australian earns (or would earn) for performing equivalent work on a full-time basis for a year in the same workplace at the same location. You will be exempt from this requirement if your salary is more than AU$250,000 per year. · be subject to conditions of employment (other than earnings) that are no worse than those that apply (or would apply) to Australians performing equivalent work in the same location. |
| Visa Applicant
As the visa applicant, you must: · have held one of the following visas to work on a full-time basis in the nominated position (or a very closely related position) for the nominating employer in Australia for at least 3 years during the last 4 years: o subclass 457 Temporary Work (Skilled) visa (not granted under the Labour Agreement stream) OR o subclass 482 Temporary Skill Shortage (TSS) visa in the Medium-term stream OR o subclass 482 TSS visa in the Short-term stream, if: § on 18 April 2017 you held (or had applied for, and were subsequently granted) a subclass 457 visa OR § you were in Australia for at least 12 months between 1 February 2020 and 14 December 2021, and you are currently employed by an Australian business NOTE: This exemption is available only for applications lodged before 1 July 2024.
· be genuinely performing the tasks of your nominated occupation · have competent English i.e. o hold a valid passport issued by the UK, USA, Canada, New Zealand or the Republic of Ireland (and you are a citizen of that country) OR o an IELTS test score of at least 6 in EACH test component OR o an OET test score of at least B in EACH test component OR o a TOEFL iBT test score of at least 12 for listening, 13 for reading, 21 for writing and 18 for speaking OR o a PTE test score of at least 50 in EACH test component OR o a CAE (C1 Advanced) test score of at least 169 in EACH test component NOTES: In each case, the test must have been undertaken within the last three years. · be under 45 years of age (unless exempt from this requirement) NOTE: If on 18 April 2017 you held (or had applied for, and were subsequently granted) a subclass 457 visa, then you must only be under 50 years of age · meet any mandatory licensing, registration or professional membership requirements · satisfy the relevant health and character criteria |
Changes to Temporary Residence Transition stream
- Applicants can count all periods of sponsored employment towards their 2-year work experience requirement. This does not just apply to employment with their sponsor.
- Applicants who have been employed in a related field or received a promotion can count this work towards the work experience requirement.
- Applicants are required to provide evidence they meet the work experience requirement, rather than the nominating employer.
- The Core Skills Income Threshold (CSIT) replaces the Temporary Skilled Migration Income Threshold (TSMIT). CSIT: $79,499 (current 2025–26 value: $76,515)
- Age exemptions under the Temporary Skill Shortage visa still apply under the Skills in Demand visa. These include exemptions for regional medical practitioners and high income applicants. Without an exemption, applicants need to be younger than 45 at the time of application.
- Changes to the Temporary Residence Transition stream do not extend to the Regional Sponsored Migration Scheme (subclass 187). This visa closed in 2019, except for certain transitional groups who can access the program in limited circumstances. This access continues for those eligible.
APPLICATION PROCESS
Stage 1: Nomination Application
This application is lodged with the Department of Home Affairs (the DOHA) on behalf of your employer, and relates to the skilled position that you have been offered, which must meet the requirements referred to above. Your employer is required to supply documents to the DOHA in support of this application, the nature and extent of which will vary depending upon the circumstances of the business.
| Skilling Australians Fund Levy
Employers must pay a one-off Skilling Australians Fund (SAF) levy for EACH subclass 186 nomination lodged with the DOHA. The amount payable varies based on the employer’s annual turnover: · For employers with an annual turnover of LESS THAN AU$10 million, the SAF levy is AU$3,000 per nomination. · For employers with an annual turnover of AT LEAST AU$10 million, the SAF levy is AU$5,000 per nomination. The SAF levy must be paid upfront, at the time that the nomination is lodged. Please contact our office for further information regarding the SAF levy. |
Stage 2: Visa Application
Your visa application is lodged with the DOHA either at the same time as the nomination application, or within six months of the DOHA’s approval of the nomination. The main criterion is that you fulfil the above requirements, including the standard health and character checks.
Once the DOHA has approved both applications, you will be granted a permanent subclass 186 – Employer Nomination Scheme visa. You may be in Australia or outside Australia when your visa is granted.
PLEASE NOTE: We estimate that it may take several weeks to prepare and lodge your application, with the time taken largely dependent on how promptly you and your employer provide us with the necessary supporting information and documents.
The time that it takes the DOHA to process your application is dependent upon its processing time service standards, and may also vary due to a number of other factors, including the complexity of your case, perceived risk factors and processing priorities. Please contact us for current information regarding likely processing timeframes for this type of application.
Counting periods of time for 186 TRT broken by bridging visas
Under policy, the Department takes a flexible approach where the nominee held more than one Subclass 457/482 visa in the relevant period, but the time holding these visas was broken by time spent on a bridging visa associated with an application for a further Subclass 457/482 visa that was subsequently granted. In this scenario, time holding the bridging visa can be counted towards meeting 186 transition visa requirements. Time spent on a bridging visa associated with the initial 457/482 visa cannot be counted.
Nomination identifies an eligible occupation
The Regulations require the occupation identified in the nomination to be the same occupation as the nominee’s most recently held subclass 457 visa, or subclass 482 (TSS/SID) visa. Under policy, flexibility may be given where the nominated occupation is not the same as the most recently held subclass 457 visa, or subclass 482 (TSS/SID) visa, but has the same 4-digit ANZSCO group code. In cases where the nominated occupation may appear to be different due to updates to the codes in the ANZSCO dictionary, DOHA will have regard to the tasks of the position.
Note: Home Affairs defined occupations specified under a labour agreement using code 070499, will not be able to meet TRT stream requirements.
The Department of Home Affairs has set 25 November 2023 for implementing changes to the employer-sponsored permanent residency program. Once the ENS reforms have been implemented, short-term Temporary Skill Shortage (TSS) 482 visa holders will gain access to permanent residency under the 186 Temporary Residence Transition (TRT) stream of the ENS visa program.
All Temporary Skill Shortage (TSS) SC 482 visa holders will be eligible for ENS visas sponsored by their employers.
Applicants will need to continue to work in the occupation nominated for their TSS visa(s).
Sponsored visa holders will be eligible for ENS TRT after two years (down from three years) of sponsorship on a TSS by their employer.
Applicants will need to meet all other nomination and visa requirements for the TRT stream of the Employer Nomination Scheme visa.
The limit on Short Term stream TSS visa applications that can be made onshore has also been removed in the interim.
From 1 July 2022, eligible 457 and TSS – short term stream visa holders will be able to apply through the TRT stream. The pathway will be accessible for two years from its commencement on 1 July 2022, see eligibility for details
186 Temporary Residence Transition Stream Age Limit Exemptions
- Academic applicants
- Regional medical practitioner applicants
- Science applicants
- Subclass 457/482 workers who meet the Fair Work High Income Threshold for 3 years
- Subclass 457/482 coronavirus concession workers (STSOL)
- Transition 457 workers under 50
- Legacy 457 workers (from 1 July 2022)
- PR for sc482 visa holders with an occupation on the Regional Occupation List (ROL)
Book a meeting today for a commitment free briefing with our Registered Migration Agents in Melbourne to find more about your visa options.
The Sc 186 TRT Nomination policy allows Sc 457/482 visa holders in certain circumstances to apply for a Sc 186 ‘a few days’ prior to their 2 year date. How is ‘a few days’ defined in this context?
In limited circumstances, yes.
The Department has indicated that it may accept applications lodged a few days before the required employment period is reached, particularly where waiting would create unnecessary complications.
However, applicants are generally expected to wait until they fully satisfy the eligibility requirements before lodging. As a guide, lodging more than five days early would generally not be considered acceptable.
The Sc 186 TRT Nomination policy allowed Sc 457/482 visa holders in certain circumstances to apply for a Sc 186 ‘a few days’ prior to their 2-year date. With the 7 December changes does this policy still apply?
Yes. The Department has advised that it intends to continue allowing limited flexibility for applications lodged a few days before the required employment period is completed.
Does all Sc 482 work experience in a nominated occupation count towards the two years required under a Sc 186 TRT visa application or does the visa holder have to be directly sponsored, i.e. a nomination transfer needs to be approved, for experience to be counted?
All sponsored work experience can be counted, the clock does not restart if the Sc 482 visa holder changes employers.
The department has advised that when changing employers, work experience can be counted from the time a nomination was lodged to transfer the Sc 482 visa holder to another employer, as long as that new nomination is subsequently approved. Work experience cannot be counted where the applicant holds a Sc 482 visa but has left the previous sponsor and has not yet had a new nomination lodged. Work experience cannot be counted where a subsequent nomination was refused.
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