The Australian Government has announced a significant change affecting the Subclass 186 Temporary Residence Transition (TRT) stream. These changes specifically impact workers in exempt occupations, such as doctors, who have been building work experience for the purposes of transitioning to permanent residency.
Here’s what you need to know.
What has changed?
From 29 November 2025, only time spent working for an approved sponsor will count towards the two-year work requirement for the 186 TRT stream.
Previously, some workers in exempt occupations were able to count work experience with non-sponsoring employers toward their TRT eligibility. Under the new rules, this is no longer permitted.
How does this affect you?
1. Applicants immediately affected - only some can realistically apply before 29 November 2025
If you have already completed two years of full-time work and some of it was with non-sponsoring employers, you should consider applying for the 186 TRT stream visa by 29 November 2025 only if your sponsorship has already been properly transferred to your current employer (i.e. your current employer has lodged a TSS/SID nomination to transfer sponsorship, and it has been approved).
Realistically, a new SID nomination that would be initiated now to facilitate 186 TRT eligibility by 29 November 2025, won't be approved on time (unless the employer holds an accredited sponsor status and is therefore eligible for SID nomination auto-approval).
Applications lodged before 29 November 2025 will be assessed under the old rules, therefore these 482 visa holders may want to consider applying for the 186 TRT stream before the cut-off date.
2. Applicants not immediately affected who have not yet reached two years with a sponsor
After 29 November 2025, any work done with a non-approved sponsor will no longer count.
This is particularly relevant to doctors who may have changed employers without lodging a sponsorship transfer nomination. If that's your case and you are considering applying for the 186 TRT stream, we recommend asking your new employer to lodge a SID nomination to transfer sponsorship of your current 482 visa to them.
To preserve eligibility, ensure all future work is undertaken for an approved sponsor and that a nomination transfer is lodged if you change employers.
Even if you are currently compliant or have not yet reached the two-year threshold, any future change of employer must now involve a sponsorship transfer to ensure your work counts toward TRT eligibility.
3. Applicants not affected who have reached two years with their sponsor
If you have only worked for your approved sponsor, your eligibility for the 186 TRT stream is not affected. You may still proceed to lodge your 186 TRT stream visa application either before or after 29 November 2025, subject to eligibility.
Our Professional Opinion
From a workforce and policy perspective, this change is concerning. It removes well-established flexibility that hospitals, clinics, and regional health services depend on. The ability for medical practitioners to work across multiple sites is not a loophole, it is a core feature of how healthcare is delivered in Australia.
The new rule contradicts the principles of the Migration Strategy and disproportionately affects doctors who acted lawfully under long-standing guidance. We consider this an unintended shift and hope to see clarification or a return to a more practical, flexible approach.
Key takeaways
Only approved sponsor employment counts for TRT after 29 November 2025.
Exempt occupations—particularly doctors—should review their work history carefully and seek professional advice.
Employer changes without a nomination transfer will adversely affect eligibility timing for TRT.
Consider lodging your 186 TRT application before the deadline if part of your experience is with non-sponsoring employers only if your sponsorship has already been properly transferred to your nominating employer.
Plan ahead: any future work under TRT should be aligned with sponsorship requirements.
What you should do now
Review your work history: identify periods of employment with non-sponsoring employers.
Check your sponsorship status: if your sponsorship is not current, arrange for your employer to lodge a SID nomination to transfer the sponsorship of your 482 visa to them as soon as practical.
Seek professional advice: speak with your registered migration agent to clarify eligibility and plan your application strategy.
Disclaimer: The information provided in this article is for general informational purposes only and does not constitute professional advice. Immigration laws and policies change frequently, and the applicability of the information may vary based on individual circumstances. For advice tailored to your situation, feel free to contact our in-house migration agents for a personalized consultation at: rms@wave.com.au.
Sep 27
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