ENS 186 TRT – Medical Practitioners permanent residency pathway changes

The Australian Government has introduced a change to the Employer Nomination Scheme (Subclass 186) Temporary Residence Transition (TRT) stream, which could impact 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, effective 29 November 2025.

What has changed?

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

From 29 November 2025, this flexibility will no longer exist.

The regulations now require that the two-year qualifying period must be completed with an approved work sponsor.

Only employment with a business that holds an approved Standard Business Sponsorship will count toward eligibility for permanent residency under the TRT stream.

Who may be impacted by this change?

Medical Practitioners or senior executives who are not currently working with an approved sponsors or employees in exempt occupations who have worked part of their qualifying period with a non-sponsoring entity.

Example:

A medical practitioner currently working in Australia on a SC482 visa. They have spent one year with their current employer who initially sponsored them (and is an approved sponsor), and another year with a previous employer that was not an approved Standard Business Sponsor.

Under the current settings, both years of employment could be combined to meet the two-year requirement when applying for an Employer Nominated (subclass 186) visa via the Temporary Residence Transition (TRT) stream.

From 29 November 2025, this will no longer be permitted. The entire two-year period must be with an approved standard business sponsor. Any time working for a non-sponsoring employer will not count towards the two-year periods.

Who is not impacted by this change?

Anyone who has lodged their Employer Nominated Scheme (ENS) (subclass 186) visa application before 29 November 2025 will not be impacted by this change.

Actions for employers and impacted SC482 visa holders

Lodging applications before 29 November 2025

Anyone in an exempt occupation (such as Medical Practitioners, CEO, or General Manager) who is currently eligible and relying on time with a non-sponsoring employer to meet the two-year requirement must submit their Subclass 186 TRT application before 29 November 2025.

Visa holders that are not eligible yet

For those who cannot meet eligibility before the deadline and are not currently employed by an approved sponsor, action is needed if you intend on transition to permanent residency. This may include asking your employer to become an approved sponsor or changing to an employer who already holds sponsorship approval.

Workforce review for employers

Employers should review their workforce and if they have employees in this situation, review their eligibility and ensure they are familiar with the new requirements. If possible, lodging 186 TRT applications prior to the 25 November 2025 is advisable.

More information & assistance

For personalised advice or assistance with urgent 186 TRT applications, employer sponsorship, compliance, and strategic workforce planning, contact our experienced team at Ethos Migration Lawyers for further assistance and advice.