ENS 186 TRT Changes for Medical Practitioners: New Permanent Residency Requirements

The Australian Government introduced a significant change to the Employer Nomination Scheme (ENS) subclass 186's Temporary Residence Transition (TRT) stream. As one of the key employer-sponsored visas, the change will affect applicants in exempt occupations, such as medical practitioners, corporate general managers, managing directors, and CEOs.

This article outlines the changes to the ENS 186 TRT stream for medical practitioners, new permanent residency requirements effective from 2025, and the implications for current and prospective visa holders.

What Has Changed for the ENS 186 TRT Pathway?

Previously, eligibility for the ENS 186 TRT stream required at least two years of relevant employment in the nominated occupation, which could, for certain exempt occupations, include time spent working for employers who were not approved sponsors.

The new change has removed the previous flexibility in sponsorship obligations, requiring that, from 29 November 2025, the two-year eligibility period must comprise employment undertaken with employers who hold an approved Standard Business Sponsorship (SBS). Only this sponsored employment will be recognised for permanent residency eligibility under the ENS 186 TRT stream.

This change will be in effect from 29 November 2025 and is a part of the Migration Amendment (Skilled Visa Reform Technical Measures) Regulations 2025 and imposes a new requirement on ENS 186 TRT applicants.

Who Is Affected by the New Regulations?

These new migration regulations by the Australian government will affect skilled migrants seeking permanent residence in the country who lodge their ENS visa application after 29 November 2025. The following sections cover this in detail:

Medical Practitioners and Healthcare Specialists

• Medical Practitioners: General practitioners, surgeons, specialist physicians, psychiatrists, etc.
• Healthcare Specialists: Registered nurses, physiotherapists, medical therapists, pharmacists, etc.

CEOs, Corporate General Managers, and Managing Directors

• CEOs, MDs, corporate general managers, and other senior executives with a prior Skill in Demand visa, or an eligible bridging visa.

SC482 Visa Holders Working for Non-Approved Sponsors

Employees in exempt occupations under the bridging visa subclass 482, whose current employers are non-approved sponsors, will also be affected.

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Example Scenario: How Eligibility Changed After 29 November 2025

For example, consider a healthcare specialist on a Subclass 482 visa who has completed one year of employment with an approved sponsor and one year with a non-approved sponsor.

If they lodge their TRT application before 29 November 2025, they can include both years of employment to meet the two-year eligibility. However, if applying after, they must show employment with an approved standard business sponsor for the entire two-year duration. Any time working under non-sponsored nominating employers will not count.

Who Is Not Affected by the Rule Change?

Any applications lodged before 29 November 2025 will remain unaffected. If you apply for your 186 TRT visa after that date, the new rules will apply.

Recommended Actions for Affected Visa Holders

Those affected by this new change should consider the following steps:

Lodge ENS 186 TRT Before 29 November 2025 (If Eligible)

TSS visa holders, Skills In-Demand (SID) visa holders, or anyone else applying via the TRT stream should apply before the deadline. If you are in an exempt occupation with a non-sponsoring employer, lodge your application before 29 November 2025 to remain eligible.

Switching to or Requesting Employment with an Approved Sponsor

Applicants who are unable to meet the eligibility criteria with their current employer before 29 November 2025 may need to seek employment with an approved sponsor or request their current employer to obtain Standard Business Sponsorship approval.

Ensuring Employment Counts Towards the Qualifying Period

You must check and ensure that your current employment is eligible for the two-year period. If you are applying after 29 November 2025, ensure that your two-year qualifying period includes an approved work sponsor.

Guidance for Employers

Employers of medical practitioners and other exempt occupations should review current workforce arrangements to ensure compliance with the amended requirements. Here are the key steps:

Reviewing Current SC482 Employees

Thoroughly audit current SC482 employees to identify whose eligibility depends on employment periods under non-approved sponsors. Prioritise these employees so that their TRT applications can be lodged before 29 November 2025.

Becoming an Approved Standard Business Sponsor

Employers whose Standard Business Sponsorship approval is expiring or who do not currently hold an SBS should apply or renew promptly, as only employment with an approved sponsor will be recognised for ENS 186 TRT eligibility after 29 November 2025.

Strategic Recruitment and Retention Considerations

From 29 November 2025, employers should ensure that prospective ENS 186 TRT applicants meet the two-year sponsored employment requirement with an approved SBS.

How Our Migration Lawyers Can Support Your Case

Whether you are applying before 29 November 2025, reviewing your eligibility and ensuring compliance is vital and can also feel overwhelming, as there are complex requirements involved.

At Australian Migration Lawyers, our registered immigration professionals can help you understand your situation clearly. From merit reviews to explaining approved sponsor requirements, our team of lawyers helps ensure that you understand every aspect of your visa status and next steps. This way, you do not have to rely on guesswork and can navigate your TRT application confidently.

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Book a Consultation‍

If you are interested in getting more information about a visa, get in touch with Australian Migration Lawyers for a consultation.

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Frequently Asked Questions

Will Time Spent Working for a Non-Sponsoring Employer Count Towards the 2-Year ENS 186 TRT Requirement After 29 November 2025?

No. After 29 November 2025, only employment with approved sponsors will count towards the two-year ENS 186 TRT requirement.

Are Medical Practitioners Still Eligible for Permanent Residency Through the ENS 186 TRT Pathway Under the New Regulations?

Yes. As long as the employment falls under the new eligibility criteria, medical practitioners can still seek permanent residency through the ENS 186 TRT pathway.

What Happens If a Visa Holder Cannot Meet the 2-Year Requirement With an Approved Sponsor Before 29 November 2025?

In this case, they will need to switch companies and work under an approved sponsor for two years before applying for their ENS TRT visa.

Can I Lodge My ENS 186 TRT Application Before the Deadline Even If I Am Still a Few Weeks Short of the 2-Year Period?

No. Even if you are applying before the deadline, the employment must showcase at least two years of eligible work.

Do I Need to Change Employers If My Current Employer Is Not an Approved Standard Business Sponsor?

If you are applying after the deadline, then yes. Once the new rule comes into effect, no time worked under a non-approved SBS employer will count for the two-year qualifying period.

Are Applicants Who Submit Their ENS 186 TRT Application Before 29 November 2025 Affected by the Rule Change?

No. Applications lodged before 29 November 2025 will be viable under the old eligibility requirements.

What Actions Should Employers Take If They Have SC482 Visa Holders Who May Be Impacted by the 2025 Changes?

If employers have SC482 holders who can be impacted by this deadline, they must get their TRT applications lodged before it.