In Migration Amendment (Skilled Visa Reform Technical Measures) Regulations 2025, a key clarification has been added for the Subclass 186 ENS – Temporary Residence Transition (TRT) stream:
👉 Only employment with an approved work sponsor can count toward the 2 years of required work experience.
This is the only change that directly affects the 482 → 186 TRT pathway.
📝 Full Explanation
The new regulation updates the wording of clause 186.227 to state that:
The required 2 years of employment must have been completed “with an approved work sponsor.”
This confirms the Government’s intention that:
- only sponsored employment counts
- only employment under sponsor obligations and salary standards is eligible
- non-sponsored jobs cannot be used to meet the TRT experience requirement
Why was this needed?
Previously, some visa holders could count additional non-sponsored employment in the same occupation.
This amendment removes that potential gap and aligns the system with policy intentions announced in the 2023 Migration Strategy.
What it means for visa holders
To qualify for 186 TRT:
- You must hold a qualifying sponsored visa (SID 482, etc.)
- You must complete 2 years full-time in the nominated occupation
- Your employment must be only with your approved sponsoring employer
This aims to:
- protect skilled workers from exploitation
- ensure the experience is at the correct skill level
- maintain integrity of the skilled migration system
🔍 Analysis
This is a functional clarification, not a new rule.
It strengthens the pathway by ensuring that only genuine, sponsored skilled work counts toward permanent residency under the TRT stream.
Applicants currently working under an approved sponsor should not be negatively affected.
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