Changes to ENS 186 TRT Work Experience Rules

If you are a doctor, nurse or healthcare employer using the 482 / Skills in Demand (SID) visa as a pathway to permanent residency, 29th November 2025 is an important date.

The Australian Government is tightening the rules in the Employer Nomination Scheme (ENS) Subclass 186 Temporary Residence Transition (TRT) stream and the rules around which work can be counted towards the qualifying period become more defined. This will shape how doctors and nurses move between employers and how rural services share staff, potentially impacting the "two year PR pathway" many clinicians are working through.

So what is actually changing on 29th November 2025?

Under the current framework, 457 and 482 / SID visa holders using the TRT stream generally need to show at least two years of full time work in their nominated occupation in Australia within a specified period before applying for ENS 186.

Until now, there have been circumstances where work done for a non sponsoring employer could still be counted. That has been particularly relevant for doctors in exempt occupations and some senior roles, whose work often spans multiple employers and sites.

From 29th November 2025, the Migration Amendment (Skilled Visa Reform Technical Measures) Regulations 2025 tighten this significantly. The key idea is simple:

• The work experience you rely on for ENS 186 TRT must be undertaken for an approved work sponsor - typically a standard business sponsor or an employer operating under a labour agreement.

If you spend part of your qualifying period working for an employer who is not an approved sponsor, or you move jobs without a valid sponsorship transfer, that time is expected to no longer count for TRT work experience purposes on applications lodged from 29th November 2025 onward. Although applications lodged before that date will continue to be assessed under the earlier, more flexible settings.

Why healthcare feels this change more than most

Australia leans heavily on internationally trained doctors and nurses, particularly in regional and remote areas. At the same time, the way care is delivered - with clinicians working across multiple hospitals, clinics, aged care homes and outreach services - rarely fits neatly into a single employer box.

Under the outgoing interpretation, some doctors and other exempt occupations could count relevant work done with non sponsoring employers towards their two years for ENS 186 TRT. For example, a GP might combine time with a sponsoring practice and time with a non sponsoring clinic in the same occupation.

From 29th November 2025, that flexibility disappears. Time with non sponsoring employers will no longer be recognised for the TRT work requirement.

For non exempt roles such as most nursing and allied health positions, the expectation has already been that your two years sit with an approved sponsor. The amendment still matters though, because it makes the requirement explicit and reduces any room to argue borderline periods of employment.

Doctors and other exempt occupations

Most of the legal commentary on this change has focused on medical practitioners; Previously, doctors in exempt occupations could, in some situations, rely on relevant employment with non sponsoring employers to reach the two year TRT requirement.

For doctors who have legitimately built their careers across a mix of sponsored and non sponsored settings, this can have real consequences. A practitioner who was on track yesterday might find that, by operation of the new rules, half of their carefully accumulated experience is no longer recognised.

Nurses, midwives and other clinicians

Nurses and midwives are not usually labelled as exempt occupations, but they are among the heaviest users of the 482 / SID to 186 TRT pathway. Public and private hospitals, aged care providers and mental health services all lean on overseas nurses who expect a genuine route to permanent residency.

For most nurses, the story is a little more straightforward:

• The Department has long expected the TRT work requirement to be met with your sponsoring employer in your nominated occupation.
• Many nursing pathways have already been structured around two solid years with a single approved sponsor.

The risk creeps in where arrangements blur at the edges - for example, where a nurse moves homes within a group and payroll shifts to another entity, but nominations do not keep pace, or where a clinician spends time working for a facility or agency that never held sponsorship approval at all. Under the amended regulations, those gaps matter more, because any time outside a clean, approved sponsorship trail is unlikely to be counted for ENS 186 TRT.

For employers

For hospitals, practices, aged care providers and health corporates, this change goes straight to workforce planning. Employers will now need to maintain valid sponsorship or labour agreements throughout a visa holder's employment if they want that time to count for TRT. If sponsorship lapses, work performed during that gap is likely to fall away for ENS 186 purposes.

This means:

• Transfers between entities within a group must be backed by proper nomination action, not just internal HR paperwork.
• Informal arrangements, such as doctors or nurses effectively working for another hospital or practice while still technically sponsored by the original employer, need to be examined very carefully.

For employers that market a "two year PR pathway", the message is clear: the pathway relies on consistently accurate sponsorship, HR and payroll processes that line up with what will be scrutinised in a future ENS 186 TRT application.

What clinicians can do now

If you are a doctor, nurse or allied health professional on a 482 / SID visa and you intend to use ENS 186 TRT, this is a good moment to pause and take stock.

Start by writing out your work history in Australia: who you have worked for, where, and when. Then compare that against your visa grant and nomination letters to see who has actually been listed as your sponsor at each point. Any period where your day to day employer was not an approved sponsor, or where you started with a new employer before a sponsorship transfer was approved, is a red flag to discuss with a professional adviser.

If you are already comfortably over the two year mark and your history sits neatly with one approved sponsor, you may simply be looking at the usual ENS 186 TRT planning. If, instead, your pathway relies on a mix of sponsored and non sponsored roles, you will want tailored advice about whether it makes sense to lodge before 29th November 2025 or whether more time under an approved sponsor is needed.

Either way, the earlier you understand your position, the more options you are likely to have.

What employers can do next

For employers, the first practical step is to get a clear picture of your sponsored workforce. Identify which doctors, nurses and other clinicians are on 482 / SID visas, and which of them are counting on ENS 186 TRT.

From there, it is worth working with your migration advisers to:

• Confirm that your sponsorship approvals are current and robust.
• Check that every move between entities or sites has been backed by appropriate nomination action.
• Align your contracts, HR records and rosters with what you would eventually need to demonstrate in a TRT application.

For services outside the cities, where sharing staff across towns and facilities is almost a necessity, this may also be the time to think more strategically about which entities in your network should hold sponsorship approval and how you structure roles that come with a PR promise.

Verus People can support this kind of thinking by connecting you with migration professionals who understand both the legislation and the realities of running a health service, and by helping you design roles and rosters that keep patient care, compliance and long term retention in balance.

This article is published by Verus People for general information only. It does not constitute legal or migration advice and should not be used as a substitute for personalised guidance. Migration rules change frequently, and how they apply will depend on your specific visa history, role, location and employer.



Before making decisions about your visa pathway, sponsorship or workforce strategy, you should seek advice from a registered migration agent or immigration lawyer.