Clarification on Work Experience Requirements for 186 TRT Applicants

Work experience requirements for 186 TRT applicants

Following our previous post on changes to work experience requirements for the Temporary Residence Transition (TRT) stream of the Employer Nomination Scheme (ENS) visa (subclass 186) from 29 November 2025, we have an important update regarding employer sponsorship requirements.

Regulation 186.227 Change: General Interpretation

The Department of Home Affairs has provided further clarification regarding regulation 186.227.

They have indicated that the work sponsor does not need to maintain sponsorship approval for the entire period of employment for the visa holder to count that work experience and remain eligible for the TRT stream.

What does this mean for 482 visa holders in general?

• An approved work sponsor is not required to maintain sponsorship approval throughout the visa holder’s entire employment for the experience to count towards TRT eligibility.
• The intent of the change to 186.227 is to ensure that work experience counted towards ENS TRT requirements is undertaken with an employer that has sponsored the visa holder in a role within their business.

This clarification aligns with existing policy guidance regarding changes of employer. Work experience can be counted from the time a nomination is lodged until the nomination is approved.

Interpretation for Medical Practitioners

Doctors being exempt from the requirement to work for their sponsoring employer, the long-standing interpretation allowed lawful, non-sponsored work in the same occupation to be counted toward the two-year period for TRT eligibility.

Initially, the amendment to 186.227 raised concerns that doctors would need to transfer sponsorship to ensure that all work experience continued to count toward TRT eligibility.

The Department has now confirmed that, for exempt occupations, changing employers without transferring sponsorship will not adversely affect subsequent TRT eligibility.

Regulation 186.227 amendment as currently worded appeared as a significant departure from long-established policy settings, contradicting more than a decade of consistent advice to medical practitioners. Our professional view was that this outcome did not reflect the intended purpose of the legislation and appeared inconsistent with the broader Skilled Visa Reform agenda, prompting us to advocate for clarification and reconsideration of this provision with the MIA.

We can now advise with reasonable confidence that:

• Regulation 186.227 amendment does not jeopardise the previous flexible arrangements as they applied to exempt occupations.
• Doctors’ TRT eligibility will not be adversely affected as a result.

482 visa holders considering applying for TRT down the line should continue to ensure that their work experience aligns with the ENS TRT eligibility requirements and that any employer-related changes are documented appropriately.

For tailored 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, please contact our in-house migration agents for a personalized consultation at: rms@wave.com.au.