Changes To Employer Sponsored Visas From 29 November 2025
From 29 November 2025, some quiet but important “tidy up” changes come into effect for the new Subclass 482 Skills in Demand visa and the 186 Employer Nomination Scheme visa. These are not a brand new visa overhaul, but they do sharpen how the system works in practice for employers, sponsored workers and people planning a pathway to permanent residence.
Here is what you need to know:
What is changing?
The Migration Amendment (Skilled Visa Reform Technical Measures) Regulations 2025 update the Migration Regulations 1994 to better “fit” the new Skills in Demand (SID) 482 visa.
In simple terms, the regulations:
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- Extend existing cancellation powers to the SID 482 visa when a sponsor breaches its obligations.
- Clarify who counts as a “primary” and “secondary” sponsored person under labour agreements.
- Clarify when an employer’s sponsorship obligations end for SID 482 holders and their family members.
- Confirm that offshore refusals of SID 482 visas are reviewable migration decisions.
- Tighten the 186 ENS Temporary Residence Transition (TRT) rules so your qualifying work must be for an approved work sponsor.
1. Stronger cancellation settings when sponsors do the wrong thing
The law already allowed the Minister to cancel certain visas if specific “events” occurred, for example if a sponsor gave false information, breached sponsorship obligations or had their sponsorship approval cancelled. The new instrument now explicitly includes the Skills in Demand 482 visa in this cancellation ground.
What this means in practice
If you hold a SID 482 visa and your sponsoring employer:
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- fails to meet sponsorship obligations
- provides false or misleading information
- has their approval as a sponsor cancelled or barred
- loses or terminates a labour agreement
then your visa can be considered for cancellation under these provisions, even if it was granted before 29 November 2025.
However, the explanatory statement confirms current policy settings continue. Visa holders are usually given an opportunity to find a new sponsor where they are not at fault or have been a victim of the sponsor’s non-compliance, before cancellation action is taken.
If you are a worker:
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- Treat this as a reminder to keep good records and stay in touch with a migration professional if anything feels “off” with your sponsorship.
- If your employer is investigated or loses their approval, you should seek advice immediately about options to transfer to a new sponsor or move onto a different visa.
If you are an employer:
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- These changes highlight that poor compliance can now more clearly affect your sponsored staff’s visas.
- It is critical to understand and meet your sponsorship obligations around pay, duties, record keeping and not providing false or misleading information.
2. Clearer definitions of primary and secondary sponsored people under labour agreements
The regulations update the definitions of “primary sponsored person” and “secondary sponsored person” so they clearly include holders and dependants of the SID 482 visa under labour agreements, just as they already did for the old TSS 482.
Why this matters:
These definitions are used throughout the sponsorship obligations framework. For example:
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- Ensuring the sponsored worker only works in the approved occupation.
- Making sure family members are treated in line with sponsorship rules.
- Clarifying who is covered when it comes to travel cost obligations.
For visa holders, nothing “new” is being added here. The government is essentially rewriting the law so that it consistently refers to the Skills in Demand 482 visa wherever it already referred to the TSS 482 visa.
For employers using labour agreements, it removes ambiguity about which SID 482 holders and their family members are covered by your obligations.
3. When travel cost obligations and other sponsorship duties end
Approved sponsors can be required to pay travel costs to allow primary and secondary sponsored persons to leave Australia. The amendments clarify that, for SID 482 visa holders, this obligation ends in the same way as for TSS 482 holders.
In particular, the obligation ends where:
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- The primary sponsored person’s last substantive visa was a SID 482, and
- They leave Australia holding a Bridging B visa, and
- That Bridging B visa later ceases.
This is a technical point, but it is important for sponsors planning around their financial and legal exposure when a sponsored worker and family members depart.
4. Clear review rights for offshore Skills in Demand refusals
The regulations confirm that if a Skills in Demand 482 visa is refused while the applicant was outside Australia, that refusal is a reviewable migration decision.
In practical terms, this means:
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- If you applied offshore for a SID 482 visa and it is refused, you may be able to lodge a merits review application with the Administrative Review Tribunal, provided the usual requirements are met.
- The law now spells this out more clearly, which reduces uncertainty for applicants and their employers.
This is a positive clarification for both businesses and workers because it confirms that there is a proper review avenue if errors are made in the initial decision.
5. Changes to the 186 ENS Temporary Residence Transition stream
Perhaps the most significant change for many skilled workers is to the Employer Nomination Scheme (Subclass 186) visa in the Temporary Residence Transition (TRT) stream.
Previously, the regulations could be interpreted to allow certain non-sponsored work to count towards the required employment period, as long as it was in the same occupation. The new regulations now make it explicit that your qualifying work experience must have been with an approved work sponsor.
What the new rule actually requires
For 186 ENS TRT applicants:
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- You still need to have held an eligible sponsored visa (which now includes the SID 482) for the required period.
- You must have been employed in Australia, in the nominated occupation, for the required period on a full time basis.
- Under the amendment, that employment period must be with an approved work sponsor, not just any employer.
Why this matters for your PR strategy
If you are planning to move from a Skills in Demand 482 visa to a 186 ENS TRT visa:
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- Staying with an approved work sponsor (or another approved sponsor through a proper transfer) becomes even more critical.
- Time spent working in a similar role for a non-sponsor is unlikely to count towards the TRT employment requirement.
- Job hopping into roles that are not properly sponsored could set your permanent residency timeline back.
If you are an employer sponsoring staff and promising a PR pathway:
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- You must understand that your status as an approved work sponsor is now central, not just for the temporary visa but also for the permanent pathway.
- Losing your sponsorship approval could seriously affect your employees’ ability to transition to permanent residency under the TRT stream.
6. Human rights and fairness
Every migration regulation must be checked against Australia’s human rights obligations. The explanatory statement confirms that these amendments are considered compatible with human rights, especially the right to work and the right to non-discrimination.
The government’s position is that:
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- Australia is allowed to set objective criteria for who can enter and work in the country.
- These measures help ensure only genuinely skilled workers with the correct sponsored experience can access the permanent skilled program.
- Limits on counting non-sponsored work are seen as reasonable and proportionate to keeping the migration system fair, protecting Australian workers and maintaining program integrity .
7. What you should do now
If you are a current or future SID 482 visa holder
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- Review your pathway: Check whether your work history and future plans meet the new requirement that TRT work must be with an approved work sponsor.
- Stay alert to your sponsor’s status: If you hear of investigations, compliance issues or loss of sponsorship approval, seek advice quickly.
- Keep records: Contracts, payslips, position descriptions and correspondence are all vital evidence later when you apply for ENS TRT.
If you are an employer sponsoring workers
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- Confirm your obligations: Make sure your internal HR and payroll processes are aligned with sponsorship obligations, including correct occupation, salary and record keeping.
- Plan PR pathways honestly: When you talk to potential hires about “PR after two years” or similar, build that plan around the reality that the work must be with an approved work sponsor.
- Consider risk management: Poor compliance can now more clearly translate into cancellation powers and reviewable decisions involving your staff’s visas.
Seek migration advice
If you hold a Skills in Demand 482 visa, are thinking about applying, or you are an employer who relies on overseas talent, this is a good moment to review your strategy.
If you like, we can help you:
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- map your 482 to 186 ENS TRT timeline under the new rules
- review your sponsor obligations and risk exposure
- stress test your permanent residence plan so that today’s decisions do not accidentally delay tomorrow’s PR outcome
Whenever you are ready, we can go through your situation in detail and design a pathway that works within these new regulations while protecting your long term goals.
Book a consultation to seek immigration advice: https://betterlifemigration.com.au/book-a-consultation/
Disclaimer: The information in our posts are general in nature you should always seek professional immigration advice for your matter.