Subclass 482 to 186 TRT Pathway: Requirements Explained

Eligible Subclass 482 (and certain Subclass 457) visa holders can apply for permanent residence through the Subclass 186 Temporary Residence Transition (TRT) stream once they have held one of those visas for a total of at least 2 years within the 3 years immediately before the visa application is made, worked full-time in Australia for an approved sponsor in the nominated occupation for that period, and meet age, English and character requirements at the time of application.

This article sets out what the TRT stream actually requires, quotes the operative clause wording rather than paraphrasing it, explains the timing of the age test with a worked example, and corrects several claims that circulate in general commentary about this pathway.

The Subclass 186 (Employer Nomination Scheme) visa has three streams: Temporary Residence Transition, Direct Entry and Labour Agreement. Where an applicant applies in the Temporary Residence Transition stream, the primary criteria for grant of the visa are the criteria in Subdivisions 186.21 (common criteria) and 186.22 (TRT-specific criteria) of Schedule 2 to the Migration Regulations 1994. All criteria must be satisfied at the time a decision is made on the application, not merely at the time of lodgement.

TRT is built around continuity: the applicant has already been performing the nominated occupation for a sponsoring employer on a Subclass 457, Subclass 482 (Temporary Skill Shortage) or Subclass 482 (Skills in Demand) visa, and the employer now nominates them for a permanent position in that same occupation. This is distinct from Direct Entry, which is built for applicants who have not accumulated that sponsored history and instead rely on a skills assessment and broader work experience — covered in detail further below.

Clause 186.211 is a common criterion that applies to every Subclass 186 applicant, regardless of stream. It reads:

In practice, this clause bites hardest for regulated occupations — trades requiring state licensing, health professions requiring registration, or roles requiring membership of a professional body. If the occupation the applicant is nominated for carries a mandatory licensing, registration or professional membership requirement in the State or Territory where the position is located, the applicant must hold that licence, registration or membership — or be eligible to obtain it — at the time the visa application is made. For occupations with no such mandatory requirement, clause 186.211 imposes no additional condition.

Beyond 186.211, the common criteria in Subdivision 186.21 also require that the position will provide the applicant the employment described in the nomination (clause 186.212), that the applicant has not engaged in relevant fraud-related conduct under the Migration Act in the previous 3 years unless the Minister considers it reasonable to disregard (clause 186.212A), and

The 2-year rule sits in clause 186.226(1), which sets the visa-holding requirement:

Clause 186.226(1)(d) also allows certain bridging visas held on the basis of being an applicant for one of those visas (or for a Subclass 186 or Subclass 187 visa) to count toward the total. The Minister may, by legislative instrument, specify different periods for particular classes of persons.

This dual structure means the assessment looks at both visa status and actual sponsored employment across the 3-year reference period ending immediately before the visa application is lodged.

A common misreading of the TRT stream is that the 2 years must be served continuously with one employer. That is not what the regulations say. Clause 186.226(1) refers to holding the relevant visa or visas, and clause 186.227(1) refers to being 'employed by an approved work sponsor' in the relevant occupation — not by a single named sponsor. The operative text is:

Two points follow directly from this wording. First, the 2 years can be accumulated across more than one approved sponsor, provided the applicant was employed in the same occupation for which the visa (or visas) were granted, and the roles were full-time and undertaken in Australia. Someone who changed employer part-way through their Subclass 482 visa, and was sponsored by both employers as an approved work sponsor in the same nominated occupation, can add the periods together toward the 2-year total. Second, the clause explicitly excludes 'any periods of unpaid leave' from the qualifying total. The regulation does not distinguish between types of unpaid leave (parental, sick, personal or otherwise) — it simply excludes periods of unpaid leave from the count. Where leave was paid, it is not carved out by this wording and would ordinarily form part of continuing full-time employment; where leave was unpaid, that period does not count toward the 2 years, regardless of the reason for it. Applicants and employers who need certainty about how a specific period of leave was recorded and whether it was paid or unpaid should check their own payroll and leave records against this clause, since the calculation turns on that distinction rather than on the reason for the absence.

Clause 186.227(2) applies a parallel test — 2 years' employment in the occupation, again excluding unpaid leave — for occupations specified in an instrument made under subregulation 2.72(13), which covers a narrower category of arrangements.

It reads:

Paragraph (b) allows the Minister to specify, by legislative instrument, classes of persons who are exempt from that standard limit. Check the current age, skill and English exemption conditions with the Department of Home Affairs.

A blanket 'under 50' statement conflates the general rule with an instrument-based exemption category that applies only to specific, defined persons meeting particular conditions — it should not be treated as the general TRT age rule.

Check the current conditions for the regional medical practitioner exemption class with the Department of Home Affairs. Applicants who believe they may fall within an age exemption class should confirm the full set of conditions that apply to that specific class rather than assuming income or occupation alone is decisive.

The age test is fixed 'at the time of application', and all criteria must be satisfied at the time a decision is made on the application. Read together, the operative moment for the age requirement is when the visa application is decided, not when the nomination is lodged, and not the date the visa application is filed if a decision follows later.

Under clause 186.223(5), the applicant then has up to 6 months from that approval date to lodge the visa application. The nomination having been approved while the applicant was still 44 does not preserve eligibility under the standard age criterion; what matters is the applicant's age at the point the criterion is assessed. An applicant approaching 45 should treat the visa application date — not the nomination date — as the deadline that matters for this criterion, and should not assume that lodging (or having approved) the nomination before turning 45 locks in eligibility.

Clause 186.222 sets the English standard for TRT primary applicants:

The term 'competent English' is a defined term under the Migration Regulations, with its meaning set out in regulation 1.15C, referenced in the interpretation section for Part 186. As with the age requirement, paragraph (b) allows the Minister to specify, by instrument, classes of persons exempt from the standard competent English requirement — a 2017 instrument addresses classes of TRT applicants not required to satisfy the Minister of competent English. Applicants relying on such an exemption should confirm which class they fall within and what conditions attach to it, rather than assuming exemption applies generally to TRT.

Competent English under clause 186.222 is a requirement for the primary applicant. Secondary applicants — family unit members included on the same application — are assessed under the secondary criteria in Subdivision 186.3, which set out separate public interest, family unit and special return criteria for those applicants. The secondary criteria structure in clause 186.311 defines who qualifies as a secondary applicant (family unit members of a primary applicant, or in defined former-relationship circumstances) and imposes its own set of conditions distinct from the primary applicant's competent English requirement. The distinction that matters in practice is that the standard applied to the primary applicant under clause 186.222 is not the same standard, nor governed by the same clause, as whatever English-related condition may attach to a secondary applicant under the secondary criteria — each applicant type sits under its own subdivision of Schedule 2 Part 186, and the requirements should not be assumed to be interchangeable.

The nomination itself is a separate application from the visa application, made under regulation 5.19, and is assessed against its own requirements before the visa criteria in clause 186.223 can be met. Clause 186.223 requires, among other things, that the Minister has approved the nomination, that the nomination has not since been withdrawn, that there is no adverse information known about the nominating person (or that it is reasonable to disregard such information), and that the position is still available to the applicant.

The nomination-side requirements — genuine position, business viability, and the employer's standing as an approved work sponsor — are assessed under regulation 5.19 rather than under Schedule 2 Part 186 itself, and the specific figures currently applied to nomination salary and levy obligations are addressed in the next section, since dollar figures in general circulation for these requirements are inconsistent and require direct confirmation.

Check the current nomination salary threshold, market salary rate requirement and SAF levy obligations with the Department of Home Affairs. Beyond that structural point, the actual dollar figures currently quoted for the Core Skills Income Threshold (CSIT) and the SAF levy differ across sources circulating publicly: figures ranging from $73,150 to $76,515, $79,423 and $79,499 have all been cited for the CSIT, with some sources attaching effective dates of 1 July 2026 and others not specifying one, and SAF levy figures of $3,000 (small business) and $5,000 (large business) have also been cited. These figures come from general commentary rather than a single authoritative published figure, and they do not agree with one another.

Because the nomination must also meet the Annual Market Salary Rate for the specific position — and the AMSR can sit above the CSIT for many occupations and locations — a nomination that only reaches the CSIT figure quoted by any given source will not necessarily be sufficient if the market rate for that role is higher. Treat any CSIT, AMSR benchmark or SAF levy amount seen in general commentary as unconfirmed until checked against the current position for the specific nomination.

The Department's own guidance on the skilled occupation list states plainly that the Temporary Residence Transition streams in the subclass 186 and 187 programs do not have an occupation list — occupation eligibility is instead based on the occupation from the applicant's most recently held temporary skilled visa. This directly corrects a common implication in general commentary that TRT eligibility depends on checking an occupation against a published list; for TRT, the relevant occupation is whatever occupation the applicant's Subclass 457 or Subclass 482 visa was granted in relation to, not a separate list.

Both streams sit under the same Subclass 186 visa and share the common criteria in Subdivision 186.21 — the licensing/registration/professional membership requirement applies regardless of which stream an applicant uses. Where the two streams differ is in how the applicant establishes their entitlement to skip or satisfy the skills-assessment step, whether an occupation list applies, and how the qualifying employment history is measured.

Clause 186.223(5) states:

This is a criterion for the grant of the visa in the TRT stream, tied to the specific nomination identified in the visa application. If the visa application is not made within that 6-month window, the visa application cannot rely on that nomination to satisfy clause 186.223. Check the current position on missed nomination-to-visa deadlines with the Department of Home Affairs or a registered migration agent.

What is actually required varies with individual circumstances — the occupation, whether an age or English exemption is relied on, and whether more than one sponsor is involved all change which documents matter most. Confirm the specific document list that applies with a registered migration agent or the Department before lodgement.

The most consequential mistakes in TRT applications tend to cluster around timing and assumptions rather than paperwork:

Assuming the qualifying employment must be continuous with one employer, rather than recognising that clause 186.227(1) allows periods with more than one approved work sponsor in the nominated occupation to be added together. Treating unpaid leave as automatically included in the 2-year count, when clause 186.227(1)(a) expressly excludes periods of unpaid leave from the total. Lodging the visa application close to the applicant's 45th birthday without accounting for the fact that age is tested at the time the decision is made, and that clause 186.223(5) allows up to 6 months between nomination approval and visa lodgement — a gap that can push the visa application past a birthday if not planned deliberately. Assuming a published occupation list governs TRT eligibility, when the Department's own guidance states TRT streams have no occupation list and instead follow the occupation from the applicant's most recently held temporary skilled visa. Relying on a specific CSIT or SAF levy dollar figure seen in general commentary without confirming it, given that figures currently in circulation disagree with one another.

Myth: All employment during the 482 visa counts toward the 2 years. Fact: only employment by an approved work sponsor in the occupation the visa was granted for counts, on a full-time basis, undertaken in Australia — and periods of unpaid leave are expressly excluded under clause 186.227(1)(a).

Myth: Every TRT applicant must be under 45, with no exceptions. Fact: clause 186.221(a) sets the standard threshold at under 45, but clause 186.221(b) allows the Minister to specify, by legislative instrument, classes of persons exempt from that standard — including classes tied to regional medical practitioners and to earnings at or above the high income threshold, each with its own additional conditions.

Myth: TRT and Direct Entry applicants face identical skills assessment and occupation-list requirements. Fact: TRT streams have no occupation list and occupation eligibility follows the applicant's most recently held temporary skilled visa, and a skills assessment is only required in TRT if the Minister requires it under clause 186.225; Direct Entry generally requires a positive skills assessment from the relevant assessing authority, subject to validity periods, unless the applicant is in a specified exempt class.

Myth: Meeting a quoted salary or CSIT figure guarantees the nomination will meet salary requirements. Fact: the nomination must meet the Annual Market Salary Rate for the specific position, which can sit above whichever CSIT figure is quoted, and the currently circulating CSIT figures are inconsistent across sources.

Myth: Employer nomination approval guarantees the visa will be approved. Fact: nomination approval is one precondition among several listed in clause 186.223 — the nomination must also not have been withdrawn, adverse information must be absent or reasonably disregarded, the position must remain available, and the visa application must be lodged within 6 months of nomination approval, with all Schedule 2 Part 186 criteria assessed separately at decision time.

Before an employer commits to a Subclass 186 TRT nomination, gather the applicant's full visa and employment history against the 3-year reference period, identify which sponsor(s) the applicant worked for and whether any unpaid leave interrupts the count, check the applicant's age and English position against clauses 186.221 and 186.222 including any exemption class that might apply, and confirm the current Core Skills Income Threshold, Annual Market Salary Rate and SAF levy figures directly with the Department of Home Affairs or a registered migration agent rather than relying on a figure seen online. For guidance specific to an individual's employment history, age-exemption eligibility or nomination structure, speak with a registered migration agent — see Global Migrations for further information.

This article provides general information about the Subclass 186 Temporary Residence Transition stream based on the Migration Regulations 1994 and related legislative instruments as in force at the time of writing. It is not a substitute for professional migration advice tailored to individual circumstances, and it should not be read as official Department of Home Affairs policy.