Breaking News: Only 'Sponsored' Employment Now Counts Toward 186 Visa PR

A major change to Australia’s Employer Nomination Scheme (subclass 186 visa) took effect on 29 November 2025, and it’s something every skilled worker and employer needs to understand. See the relevant Migration Institute notice here:

MIA Notice 30 - 21 November 2025.pdf

Download PDF • 368KB

From now on, only employment under an approved Standard Business Sponsor (SBS) will count toward the two-year work requirement for the 186 visa.

Previously, the Sponsorship approval was only required at the time a nomination application was granted and not through the whole visa period.

Experts have raised concerns, and the Migration Institute of Australia is seeking clarification from the Department of Home Affairs.

What Exactly Changed?

The update to subclauses 186.227(1) and (2) of the Migration Regulations 1994 makes it clear:

Only work performed while your employer holds a valid sponsorship approval will count toward your eligibility for the subclass 186 permanent residency visa.

If your employer’s sponsorship expires or lapses — even briefly — any work you do during that time will not count toward your PR requirement.

That means if you’ve been working for two years but part of that time was under an expired sponsorship, you might have to work longer before you can apply for PR.

Why It Matters

For years, there’s been confusion about whether work done after a sponsorship expired could still count toward PR. Some applicants believed that if they stayed with the same company, it would still qualify.

This update removes all doubt. Unsponsored employment will not be counted — even if you’re still working full-time for the same employer.

In practice, this could delay some PR applications by months or even years.

What Employers Need to Do

If you’re an employer who sponsors skilled workers on subclass 482 or 457 visas, keeping your sponsorship active is now more important than ever.

If your business’s sponsorship approval expires or isn’t renewed in time, it could directly affect your employees’ PR plans — and cause frustration, uncertainty, and even resignations.

Here’s how to stay compliant:

✅ Check your sponsorship expiry date regularly

✅ Renew early — don’t wait until the last minute

✅ Update your business details with the Department of Home Affairs

✅ Keep clear communication with your sponsored employees

By staying proactive, you protect your business reputation, support your team, and ensure smooth PR transitions for your skilled staff.

What Skilled Workers Should Know

If you’re on a Temporary Skill Shortage (subclass 482 visa) and planning to apply for the 186 PR pathway, this rule directly affects you.

To stay on track for PR:

• Confirm that your employer is still an approved Standard Business Sponsor

• Keep your own records of start dates and sponsorship approval periods

• Ask your employer to renew their sponsorship before it expires

• Speak to an immigration lawyer if you’re unsure about your timeline

Even a short lapse in sponsorship may mean you’ll need to renew your 482 visa in order to meet the two-year requirement, delaying your PR eligibility.

Why the Change Was Introduced

This update is designed to strengthen integrity in the employer-sponsored migration program.

By ensuring that only approved sponsors can support PR pathways, the Department aims to:

• Keep the sponsorship system transparent and fair

• Prevent misuse of temporary and permanent visa pathways

• Hold employers accountable for maintaining sponsorship obligations

It’s also meant to give clarity — so both employers and visa holders know exactly what counts toward PR and what doesn’t.

Key Takeaway

The November 2025 update is a wake-up call for anyone on the road to PR through employer sponsorship.

• For workers: Always confirm your employer’s sponsorship status

• For employers: Keep your sponsorship approval up to date

• For both: Communication and compliance are the key to a smooth 186 PR process

At Fast Visa Australia, we help both employers and skilled workers understand their obligations and stay on track for permanent residency.

If you’re unsure how this change affects your situation, our migration team can help you review your eligibility and sponsorship status.