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Skilled Migration News Update: Key Changes to the Subclass 186 Visa and WA DAMA Framework

Senior Associate - Senior Australian Migration Lawyer
Published on:
November 24, 2025
|
Modified on:
August 27, 2026
Work & Skilled
Senior Associate - Senior Australian Migration Lawyer
Published on:
November 24, 2025
Modified on:
August 27, 2026
Senior Associate - Senior Australian Migration Lawyer
Published on:
November 24, 2025
Modified on:
August 27, 2026
Table of Contents
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Key Takeaways

  • Subclass 186 processing is no longer strictly based on lodgement date, since March 2026 the Department prioritises by occupation type, employer status, and location.
  • Ministerial Direction 119 replaced Ministerial Direction 105 on 25 July 2026 as the current priority framework, now also covering the 482 visa.
  • Approximate 2026 processing figures: Direct Entry around 12 months at the 50th percentile and 18 to 20 months at the 90th, TRT around 13 to 14 months and up to 18 months, Labour Agreement around 5 months and up to 9 months.
  • New business eligibility criteria narrow the Management Consultant occupation pathway under the 186 visa.
  • The Goldfields DAMA transitioned into the WA DAMA on 4 April 2026, and the South-West DAMA is scheduled to transition in December 2026.
  • Existing labour agreements and their concessions remain valid for their full duration through both transitions.
minute read

Australia’s skilled migration landscape continues to evolve as the Government prepares for the 2025–26 program year. The Australian Government is making changes to the migration program, including updates to visa subclasses and pathways to permanent residency. These changes are designed to address skills in demand across Australia, ensuring that regional and industry labour shortages are met through targeted migration solutions. Recent updates to employer-sponsored visa processing, occupation requirements, and Designated Area Migration Agreements (DAMAs) will be highly relevant to businesses, skilled workers, and applicants planning their migration pathway. This article summarises the major changes announced across the Employer Nomination Scheme (Subclass 186) and Western Australian DAMA streams to help you understand how these developments may affect your strategy.

Subclass 186 Visa Processing Times

The Department of Home Affairs' Employer Sponsored Program Delivery (ESPD) team continues to report a significant rise in Subclass 186 Employer Nomination Scheme applications, and processing times remain extended into 2026. As of March 2026, the Department confirmed that processing is no longer conducted strictly by lodgement date. Instead, applications are prioritised based on occupation type, employer status, and location, meaning some newer applications may be assessed ahead of older ones. Approximate figures reported through mid-2026 place the Direct Entry stream at around 12 months for half of all applications and 18 to 20 months for the slowest 10 percent, the Temporary Residence Transition stream at around 13 to 14 months and up to 18 months, and the Labour Agreement stream considerably faster, at around 5 months and up to 9 months.

As of 25 July 2026, this priority order is governed by Ministerial Direction 119, which replaced the previous Ministerial Direction 105. Under the new Direction, the 482 visa has also been brought into the same formal priority framework as the 186, 190, 491, and 494 visas, based on occupation category and whether the applicant is in or outside Australia.

These timelines highlight ongoing pressure on the employer-sponsored visa program. Preparing complete, accurate, decision-ready applications is more important than ever to avoid unnecessary delays. Visa applicants must ensure they meet all migration regulations, including providing evidence of labour market testing, as part of their submission.

The Department has also confirmed that from 1 July 2026, the nominated salary must meet the current Core Skills Income Threshold of $79,499, and the visa application charge and quota reset for the new program year, both of which can affect timing decisions for employers planning a 186 nomination.

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Changes to the Occupation Requirements for Management Consultant (Subclass 186)

Applicants nominating the occupation of Management Consultant under the Subclass 186 visa should be aware of newly imposed business eligibility criteria.

Under updated requirements:

  • The nominated position must be in an eligible occupation; and
  • Employers must first attempt to recruit appropriately qualified Australians for the role before nominating an overseas candidate; and
  • The nominated position cannot be located in a business with an annual turnover under $1 million; and
  • The business must employ at least five staff members.

These changes significantly narrow the availability of the Management Consultant pathway under the 186 visa. They are designed to ensure that nominated roles reflect genuine skill needs, that employers prioritize hiring appropriately qualified Australians where possible, and that positions are supported by businesses of appropriate scale and capacity.

Employers and applicants should carefully review these conditions to avoid refusals relating to business structure ineligibility.

Goldfields DAMA Transitioning to the WA DAMA

Western Australia is undertaking significant consolidation of its regional migration agreements. The Goldfields DAMA is a designated area migration agreement that covers specific DAMA regions and active DAMA regions within Western Australia. The Goldfields DAMA will formally transition into the new WA DAMA on 4 April 2026.

Key points:

  • The standalone Goldfields DAMA will be absorbed into the broader state-based WA DAMA framework, under the DAMA head agreement.
  • Existing labour agreements remain valid for their full duration, some extending up to five years.
  • Businesses and visa holders will retain all current concessions under their existing agreements.
  • New Goldfields DAMA labour agreement applications and variations can still be lodged before the transition date and will continue to be processed.
  • Regional employers and regional authorities, including the designated area representative, play a key role in the transition process and management of the DAMA head agreement.
  • The City of Kalgoorlie–Boulder will directly communicate with all current agreement holders about their transition obligations.

This ensures continuity and stability for businesses that have already invested in the Goldfields DAMA pathway.

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South-West DAMA Transitioning to the WA DAMA

The South-West DAMA will also transition into the WA DAMA, with changes scheduled for December 2026. The South-West DAMA is one of several regional DAMAs and local regional DAMAs being consolidated to better serve regional Western Australia and regional WA.

Similar to the Goldfields transition:

  • The South-West DAMA will be consolidated under the unified WA DAMA framework.
  • Existing labour agreements will continue to operate with their current concessions, even after the head agreement expires.
  • Visa holders sponsored under the South-West DAMA will not be impacted and will retain full visa validity.
  • The Shire of Dardanup has issued detailed guidance to existing labour agreement holders outlining upcoming changes.

As with the Goldfields transition, this consolidation does not by itself change the occupation lists or concessions available, it changes the administrative framework the agreements sit under, cross-referenced against the same head agreement structure described in the earlier Townsville DAMA article reviewed this session for consistency in how DAMA transitions generally operate.

For employers, this transition means long-term planning can continue with confidence, knowing existing workforce arrangements will remain intact. These changes reflect Western Australia's commitment to supporting local workforce needs.

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Frequently Asked Questions

1. Why are Subclass 186 processing times so delayed?

The Department has experienced a significant increase in application volumes, placing pressure on the employer sponsored program. This has resulted in extended assessment periods across multiple streams. Since March 2026, processing priority is also determined by occupation type, employer status, and location under Ministerial Direction 119, rather than strict lodgement order, which means the queue position of any individual application can shift over time. Processing times can also vary depending on the specific visa programs, with the DAMA process involving additional steps such as government agreements and tailored occupation lists, which may impact overall timelines.

2. Do the new Management Consultant requirements apply to all Subclass 186 applicants?

Yes. Any nomination for a Management Consultant under the Employer Nomination Scheme visa subclass (Subclass 186) must meet the minimum turnover and staffing requirements.

3. Will existing Goldfields or South-West DAMA visa holders lose their concessions after the transition?

No. All existing DAMA labour agreements—and the concessions attached to them—remain valid for their full duration, protecting both employers and visa holders. Existing visa holders may still be eligible for permanent visas, as the DAMA framework provides specific visa pathways to permanent residency for eligible applicants, including permanent residents.

4. Can new applications still be made under the Goldfields DAMA before transition?

The transition date of 4 April 2026 has now passed. New Goldfields-region applications are now made under the consolidated WA DAMA framework rather than the standalone Goldfields DAMA.

Depending on the employer's needs, a new application may include a labour agreement request for either individual labour agreements or an industry labour agreement.

5. Will the WA DAMA offer different concessions compared to the current regional DAMAs?

The WA Government will outline available concessions as part of the consolidated agreement. Current concessions remain in place for existing agreements.

The WA DAMA offers visa concessions to eligible businesses, making it easier to employ skilled migrants and attract skilled migrants to the region.

Nicholas Merlin Esq.

With 15 years of experience in United States law and public administration, followed by 5 years practising Australian migration law, Nick brings a depth of cross-jurisdictional legal expertise to his work as an Australian migration lawyer.

Nick holds a Bachelor of Arts in Political Science from Florida State University (2000), a Juris Doctorate from St. Thomas University School of Law (2004), and a Master of Public Administration from Florida State University (2007). He has been a member of the Florida Bar since 2006 and the District of Columbia Court of Appeals Bar since 2007, establishing a distinguished international legal career before relocating to Melbourne in 2021.

After completing his Australian legal studies at La Trobe University and The College of Law, he was admitted as an Australian lawyer by the Supreme Court of Victoria in 2022. He subsequently obtained Legal Practitioner Number 5513285, through which he practises in migration law. He is a member of the Law Institute of Victoria.

Nick offers expert guidance on a wide range of migration matters. Having personally navigated the migration process himself, he brings both professional expertise and genuine understanding of what clients experience throughout the process.

Nick serves clients nationally, including in Melbourne, Sydney, Brisbane, Perth, and Adelaide, providing comprehensive support.  

He has represented clients in proceedings before the Administrative Review Tribunal (ART), bringing tribunal advocacy experience to complex and contested migration matters.

Outside his professional life, Nick enjoys reading, travel, and exploring Melbourne's coffee culture.

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LEGAL DISCLAIMER: Articles and blog posts published by Australian Migration Lawyers provide general information only and do not constitute migration or legal advice. Reading this content does not create a lawyer-client relationship, and any reliance on it is strictly at your own risk. Because migration laws change frequently, please consult a registered Australian Lawyer for professional advice tailored to your specific circumstances before making any migration decisions or applications.

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