A significant regulatory amendment — the Migration Amendment (Skilled Visa Reform Technical Measures) Regulations 2025 — has introduced an adverse change affecting Subclass 186 Temporary Residence Transition (TRT) visa applicants in exempt occupations, including Medical Practitioners, CEOs, Corporate General Managers and Managing Directors.
This change applies to all 186 TRT visa applications lodged on or after 29 November 2025.
What Has Changed?
The amendment updates the employment requirement for the 186 TRT stream by inserting the words:
“…by an approved work sponsor.”
This requirement is added to both:
- subclause 186.227(1) (non-exempt occupations), and
- subclause 186.227(2) (exempt occupations)
Why This Is a Serious Issue for Exempt Occupations
For exempt occupations, the change is not merely clarifying existing law — it introduces a NEW restriction.
Before 29 November 2025
Medical practitioners, CEOs and GMs could count relevant employment with a non-sponsoring employer toward the 2-year TRT requirement.
After 29 November 2025
Time employed by a non-sponsoring entity will no longer count Only employment by an approved Standard Business Sponsor will count toward the 2-year requirement
This is a major shift that will leave many previously eligible applicants instantly ineligible.
Who Will Be Affected?
This change affects anyone in an exempt occupation who:
- Has mixed periods of sponsored + non-sponsored employment
- Works for a clinic, hospital, corporation or organisation that is not an approved sponsor
- Intends to lodge a 186 TRT visa on or after 29 November 2025
This group includes many:
- General practitioners
- Specialist doctors
- Hospital medical officers
- CEOs, MDs and General Managers
Learn more about pathways for medical professionals here:
Who Is NOT Affected?
Anyone who lodges their 186 TRT application before 29 November 2025 Anyone whose 2-year qualifying period is already fully sponsored Applicants in non-exempt occupations
Immediate Actions Required
1. Eligible Now? Lodge Before 29 November 2025
If you are a Medical Practitioner, CEO or General Manager and have been relying on non-sponsored employment to meet the 2-year TRT requirement:
You MUST lodge your 186 TRT application before 29 November 2025.
2. Not Eligible Before the Deadline? You Must Act Fast
If you cannot meet the 2-year requirement by the deadline:
You may need to:
- Request your employer to apply for a nomination transfer of your 482 visa, or
- Move to an employer who is already an approved sponsor
3. Employers & HR Teams Must Review All Affected Staff
Any employee in an exempt occupation whose PR plan depends on mixed employment arrangements must be reviewed immediately.
4. Seek Professional Assistance
These changes have major PR implications and strict timelines.
