What Are the Latest Changes to the Subclass 186 ENS Visa?

Australia’s Employer Nomination Scheme (ENS) Subclass 186 visa is one of the most popular visas, as it offers the opportunity to live permanently in Australia. The Australian Department of Home Affairs strictly regulates it for the same reason.

On November 29, 2025, the Department made some changes to the Subclass 186 Visa under the Temporary Residence Transition (TRT) stream.

This has probably stirred some anxiety among Subclass 186 Visa applicants as well as sponsoring employers. As both parties need to proceed correctly in order to remain aligned with the updated requirements. Naturally, questions have been raised about whether these changes introduce new risks or demand a more cautious approach.

According to the Department of Home Affairs, these updates are not intended to cause disruption. Instead, they serve to clarify the existing frameworks surrounding sponsorship and work experience.

Definitely, that’s the relief for everyone, but what exactly are these updates? Let’s find out.

Understanding the ENS Subclass 186 Visa

The Employer Nomination Scheme (ENS) Subclass 186 visa is a permanent residence visa that allows skilled international workers to live and work in Australia if nominated by an approved employer.

The visa is divided into three streams.

• Direct Entry (DE): For experienced skilled workers
• Labour Agreement: For workers sponsored under a labour agreement
• Temporary Residence Transition (TRT): For holders of eligible bridging visas

Thus, the ENS Subclass 186 (TRT) Visa is intended for applicants who are already working and living in Australia on an eligible temporary skilled visa. In order to qualify, visa applicants must:

• Hold a temporary visa, like Subclass 482, 457, or another eligible bridging visa.
• Have worked on a full-time basis for at least two years in their nominated occupation on the previous visa
• Have been sponsored by an Australian employer (approved sponsor)
• Meet all the requirements for skills, salary, character, English, and more.

What Prompted the Recent ENS Subclass 186 (TRT) Clarification?

As it is quite clear that the TRT stream of the Subclass 186 ENS Visa is way different from other points-tested visas. It hugely focuses on the applicant’s ongoing employment history with the sponsoring employer, as well as compliance and employment continuity. Hence, this is in contrast to other visas that rely on certain points, the applicant’s age, or external skills assessment criteria.

This uniqueness has always presented confusion among employers and applicants on the existing migration regulations related to sponsorship and work experience. Especially, how does the Department analyse the work periods under the TRT stream?

The update is not a policy change or restriction; rather, it aims to clarify how the law should currently be applied. This is especially crucial when figuring out whether work completed without active sponsorship counts toward permanent residency eligibility.

Key Points of the ENS 186 (TRT) Clarification

Go through the following to understand what exactly has been clarified:

Work Experience Must Be Under an Approved Sponsor

The Department will only count the work experience that was completed under the approved sponsor for the approval of the ENS 186 (TRT) visa.

If the employer is no longer approved during a particular period of the lawful employment of the worker, it will not be counted.

Sponsor Approval Must Exist at the Time of Employment

Even if the employer renews its sponsorship approval later, that doesn’t mean the work during the expired sponsorship would be counted in the total work experience.

As a result, work completed prior to sponsorship approval is ineligible for visa applicants.

Thus, it is important to note that the gaps in the employer’s sponsorship approval are relevant to the skilled worker’s TRT visa approval.

Continuous Sponsor Approval Is Not Necessary

The Department will still count “sponsored work experience” both before and after the active sponsorship, even if the sponsorship status expires in between.

Applications Before 29 November 2025 Are Not Affected

These clarifications would apply to applications lodged on and after 29 November 2025. This protects those who have already submitted an application from unanticipated outcomes.

What This Update Means for Sponsored Workers

If you are a sponsored Worker applying for the ENS 186 (TRT) visa, you need to know the following after the recent update:

• You can change employers while on your current visa, and your sponsored work experience will count towards the TRT eligibility period.
• Your new employer must be an approved sponsor for the relevant occupation.
• The sponsorship transfer must be completed correctly and legitimately.
• Work experience will be counted from the date you applied for the sponsorship transfer.

Thus, if you have been employed correctly, this clarification does not change your eligibility. It simply reinforces compliance standards that have already been in place.

Why Does This Update Matters for Employers?

This 29 November 2025 Clarification on ENS Subclass 186 (TRT) not only impacts the visa applicants but also employers.

Employers must:

• Keep their sponsorship active at all times, as it can directly impact the visa application of workers they have been sponsoring.
• Lodge their renewals well before expiry.
• Align employment contracts with the visa pathways they are sponsoring.
• Maintain full compliance with the Department of Home Affairs’ sponsorship obligations and employment conditions.

Conclusion

The ENS Subclass 186 (TRT) clarification of November 2025 has reduced uncertainty for applicants planning long-term settlement in Australia. It only benefits visa applicants who have stable employment, compliant sponsorship, and are willing to contribute to the long-term workforce.

Ozee Migration provides strategic guidance to help you navigate the ENS 186 (TRT) pathway with clarity and confidence. Our team includes skilled experts, and MARA agents work closely with clients to assist them at every stage of the visa application process. We stay up to date on Department of Home Affairs guidelines to ensure regulations compliance, correct documentation, and a smooth transition to Australian permanent residency. Contact us to schedule your consultation.

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