Before outlining the recent update, let’s clarify the terminology.
What is the Employer Nomination Scheme?
The Employer Nomination Scheme (ENS) is the Australian Government’s permanent visa programme for skilled workers. It allows employers to sponsor valued employees for permanent residency, supporting long-term workforce retention.
What is the 186 visa?
The 186 visa is the permanent residency visa granted under the ENS programme. For many sponsored workers, it is the end goal. For employers, it is a key mechanism for retaining hard-to-find skills.
What is the Temporary Residence Transition stream?
Many workers first enter Australia on a temporary sponsored visa, most commonly a 482 visa.
The Temporary Residence Transition (TRT) stream is the pathway that allows these workers to move from a temporary visa to permanent residency after working in their sponsored role for the required period, unless the employer is sponsoring them via the Direct Entry pathway.
What changed on 29 November 2025?
The Government updated the wording around what work experience can be counted when sponsoring an employee for the ENS 186 visa through the TRT stream.
The revised wording states that the required work experience must be undertaken with an approved work sponsor.
This caused uncertainty among employers, particularly around whether:
- experience with a previous sponsoring employer would still count
- a worker needed to remain with the same sponsor for the full qualifying period
- only time with a currently approved sponsor could be counted
- employers needed to hold Standard Business Sponsorship continuously
Following industry feedback, the Department has now clarified its position.
What the Department has clarified
The intent of the rule change is straightforward.
1. Genuine sponsored work still counts
Any full-time, sponsored work undertaken in Australia can be counted toward the ENS 186 TRT requirements, provided:
- the worker was sponsored for the role they performed, and
- the role matched the visa they were granted
This applies even where the worker has changed employers during their time in Australia.
2. Work can be counted while a new nomination is being processed
When a worker moves to a new employer, work experience can be counted from the date the new nomination is lodged, not only from the date it is approved. This aligns with existing policy.
3. Sponsorship approval does not need to cover the full employment period
An employer does not need to be an approved sponsor for the entire employment history being relied on. They must have legitimately sponsored the worker for the relevant period being counted.
4. When experience may not count
Previous sponsored work cannot be counted only where the former employer has:
- been barred
- been sanctioned, or
- had their sponsorship cancelled
This ensures system integrity and protects visa holders.
What this means in practice
For most employers, this clarification is positive.
It confirms that workers can still transition to permanent residency using the majority of their sponsored work experience, even if they have changed employers.
It also means employers can confidently hire already sponsored workers and still support their permanent residency pathway, provided the worker’s history is compliant and legitimate.
Further clarification is still expected for certain exempt occupations, and updates will be shared as soon as industry bodies receive confirmation.
Here to help
If you would like advice on how these changes may affect your workforce, your current 482 visa holders, or future 186 planning, our team can help you navigate the requirements and put a clear, compliant pathway in place for your people.
