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

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 team has reported a significant rise in Subclass 186 Employer Nomination Scheme (ENS) applications. As a result, processing times remain extended, and the Department has outlined the cohorts currently under assessment.

• Regional occupation applications: The Department is assessing nomination and visa applications lodged in April 2025.
• Healthcare and teaching occupations: Also currently assessing April 2025 lodgements.
• Accredited sponsors: Processing is slightly ahead, with applications from October 2024 under review.
• All other applicants: The Department is still assessing March 2024 applications.

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 noted that while no definitive future timeframes can be provided, the listed dates reflect the cohorts currently under active assessment.

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.

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.

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 cohorts. 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?

Yes. New applications and variations can continue to be lodged before 4 April 2026 and will be processed as usual.

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.