Summary
- Changes to the Employer Nomination Scheme (subclass 186) Temporary Residence Transition visa mean only work completed for an approved work sponsor counts toward the two-year PR requirement.
- Medical practitioners risk losing access to age exemptions and health waivers if any period of employment was under a non-approved sponsor or different ABN.
- Doctors on 482/Skills In Demand visas should urgently review their sponsorship history and seek professional migration advice to protect their permanent residency pathway.
Significant changes to Australia’s employer-sponsored permanent residency pathway have now taken effect, and they directly impact medical practitioners working on a Skills in Demand visa/ subclass 482 visa.
As at the 29th of November 2025, amendments to the Migration Regulations 1994, under the Migration Amendment (Skilled Visa Reform Technical Measures) Regulations 2025, remove long-standing flexibility for doctors transitioning to PR through the Subclass 186 Employer Nomination Scheme (ENS) Temporary Residence Transition (TRT) stream.
These reforms affect how the two-year qualifying period is calculated and may jeopardise eligibility for doctors relying on age exemptions or health waivers.
This SEO-optimised guide explains the changes, who is affected, and what medical practitioners must do now to protect their PR pathway.
What is the new rule for Employer Nomination Scheme (subclass 186) Temporary Residence Transition visa holders?
Under the new legislation:
Only employment with an “approved work sponsor” counts toward the two-year requirement for the subclass 186 TRT pathway.
This means:
- Time spent working for a different employer, even in the same occupation, does not count toward the two-year period
- If the sponsor was not approved, or their sponsorship lapsed, those months become ineligible
- The change applies even to exempt occupations, including medical practitioners
Previously, doctors could often combine periods of work across multiple clinics, hospitals, or networks. That flexibility has now been removed.
Why the new subclass 186 TRT legislation affects Medical Practitioners the most
Medical practitioners commonly work:
- Across multiple hospitals or clinics
- In rotational or split-site roles
- Under third-party employment models
- In regional or multi-location practices
- Through different ABNs or corporate structures
Under the previous rules, this mobility rarely created problems for the subclass 186 TRT pathway.
Under the new rules, however:
A doctor may believe they have completed two years of eligible work, when in reality, a portion of that time no longer qualifies. This can result in doctors unintentionally falling short of the two-year requirement, delaying or preventing their transition to permanent residency.
How the subclass 186 TRT changes impact age exemptions and health waivers
For many medical practitioners, the subclass 186 TRT stream is not only a preferred pathway, it is often the only viable option due to age or health considerations.
1. Age Expemption Risks
Doctors aged over 45 rely heavily on the age exemption available through the TRT stream.
If their two-year eligibility period is disrupted, they may lose access to that exemption entirely.
2. Health Waiver Access
Some practitioners depend on a health waiver, which is available under certain 186 TRT scenarios.
If the practitioner becomes ineligible for 186 TRT due to employment gaps or sponsor issues, their ability to obtain a health waiver may also disappear.
Losing either concession can drastically alter a doctor’s migration prospects.
Who is most at risk under the new subclass 186 TRT changes?
You may be affected if:
- You changed employers while on a 482/Skills In Demand visa
- You worked for a hospital or clinic that was not your formal sponsor
- Your employer’s sponsorship expired or changed ABNs
- You performed locum, rotation, or multi-site work
- Part of your work occurred under a contractor or management company
- You need an age exemption or health waiver
- You are planning to lodge a subclass 186 TRT application soon
Even small inconsistencies in sponsorship arrangements can now cause major eligibility problems.
What Medical Practitioners should do now
- Check your sponsorship history: confirm that every month of yur employment was under a valid, approved sponsor.
- Seek advice before changing employers: even brief employment with a non-approved entity can reset your timeline.
- Review your Permanent Residency strategy early: doctors may benefit from exploring alternative pathways beforee committing to the Employer Nomination Scheme (subclass 186) Temporary Residence Transition visa.
- Get professional support: these legislative changes are technical, but their consequences are significant.
Concerned about your eligibility? Cntact us for a strateegy session
If you are a medical practitioner on a subclass 482 or Skils In Demand visa and think these new subclass 186 TRT changes may affect your permanent residency pathway, contact our office immediately.
This is particularly urgent if:
- You need an age exemption to lodge 186 TRT
- You require a health waiver
- You have worked for more than one employer during your two-year period
Our team at Regional Migration Australia specialises in visa strategies for doctors and can help you assess your options, repair potential eligibility gaps, and pursue the strongest possible PR pathway.
