The Temporary Residence Transition (TRT) stream of the subclass 186 Employer Nomination Scheme visa has long been the most common pathway from temporary to permanent residency for sponsored workers in Australia. From 29 November 2025, the rules governing this pathway have changed in a way that directly affects how employers manage their sponsorship obligations.

This article outlines what has changed, why it matters, and what steps employers should take now to protect both their business and their sponsored employees.

What has changed

Under the previous framework, the TRT stream required an employee to have worked for their sponsoring employer for at least three years on a Skills in Demand (subclass 482) visa. The employer needed to be an Approved Sponsor at the time of nomination, but there was no explicit requirement for the employer to maintain approved sponsor status throughout the entire period of qualifying employment.

From 29 November 2025, the Department of Home Affairs requires that the nominating employer must have been an Approved Sponsor for the full duration of any employment being relied upon to satisfy the three-year work requirement. If the employer's sponsorship approval lapsed at any point during that period, even briefly, the employment during the lapse cannot be counted toward the qualifying period.

Why this matters for employers

This change has significant practical implications:

• Sponsorship renewals become critical. Standard Business Sponsorships are approved for a set term (typically five years). If a renewal lapses, any employment that falls within the gap cannot be counted toward the employee's TRT eligibility, potentially delaying their permanent residency by months or years.
• Historical gaps may affect current nominations. Employers who had a brief lapse in their sponsorship approval at any time during the employee's qualifying period may find that the employee no longer meets the three-year threshold, even if the total calendar time exceeds three years.
• Multiple employer scenarios are more complex. Where an employee has worked for more than one sponsor, each employer's sponsorship status during the relevant period must be verified independently.

What employers should do now

We recommend the following steps for any employer with workers on the TRT pathway:

1. Audit your sponsorship approval dates. Confirm the start and end dates of every sponsorship approval period you have held. Check for any gaps, however short, between approval periods.
2. Cross-reference employee timelines. For each sponsored employee approaching TRT eligibility, map their employment dates against your sponsorship approval periods. Identify any overlap issues now, before lodging a nomination.
3. Set renewal reminders early. We recommend initiating sponsorship renewals at least six months before expiry. The Department's processing times can be unpredictable, and a pending renewal does not guarantee continuity of approval.
4. Seek advice before lodging. If there is any doubt about whether a gap exists or whether qualifying employment has been affected, get professional advice before lodging a nomination. A refused nomination has consequences for both the employer and the employee.

A note on transitional arrangements

The Department has indicated that nominations lodged before 29 November 2025 will be assessed under the previous rules, provided the application was validly made before that date. However, any nomination lodged on or after 29 November 2025 will be subject to the new requirement, regardless of when the qualifying employment commenced.

This means that employers who were planning to nominate employees in the near future should consider whether it was advantageous to lodge before the cut-off. For those who did not, the new rules apply in full.

The bottom line

This is not a dramatic overhaul of the TRT pathway, but it is a meaningful tightening of the rules that catches out employers who have not been meticulous about maintaining their sponsorship status. The cost of a lapse, which may once have been purely administrative, now has a direct impact on employees' permanent residency timelines.

If you sponsor workers on the 482 visa and intend to nominate them for permanent residency through the TRT stream, maintaining continuous Approved Sponsor status is no longer just good practice. It is essential.

Becoming an Approved Sponsor under the Australian employer-sponsored visa program is only the first step. Once approved, employers take on a set of legally binding obligations that remain in force for the duration of the sponsorship, and in some cases, beyond it. Non-compliance can result in sanctions, infringement notices, civil penalties, and the cancellation of your sponsorship approval.

Despite this, many employers are not fully aware of what their obligations require in practice. Below, we outline the four core obligations that every Standard Business Sponsor must understand and actively manage.

1. Ensure terms and conditions are no less favourable

Sponsored workers must receive employment terms and conditions that are no less favourable than those provided to an equivalent Australian worker. This extends beyond salary to include:

• Leave entitlements
• Working hours and overtime
• Superannuation contributions
• Access to training and professional development
• Workplace health and safety protections

Where there is no directly comparable Australian worker in the business, the comparison is made against industry standards for the occupation and location. This obligation exists to prevent the exploitation of visa holders and to ensure a level playing field with the local workforce.

2. Keep records and cooperate with the Department

Sponsors must maintain accurate records relating to the sponsored worker and must be able to produce these records if requested by the Department of Home Affairs. The types of records required include:

• Employment contracts and any variations
• Pay slips and evidence of salary payments
• Evidence of superannuation contributions
• Records of working hours
• Tax-related documents (group certificates, payment summaries)

Additionally, employers must cooperate with any monitoring, investigation, or audit conducted by the Department. This includes providing information or documents within the timeframes specified by the Department, which can be as short as 14 days.

3. Notify the Department of certain changes

Sponsors are required to notify the Department of specific events within 28 days (or 10 business days in some cases) of the event occurring. These include:

• The sponsored worker ceasing employment
• A change to the business's legal structure, ownership, or address
• The business becoming insolvent, ceasing to trade, or being subject to adverse information
• Any change to the terms and conditions of the sponsored worker's employment that may affect compliance

Failure to notify is itself a breach, even if the underlying change does not amount to non-compliance. Many employers are caught out by this obligation, particularly where an employee resigns and the employer does not realise that a notification is required.

4. Pay travel costs if required

If a sponsored worker's visa is cancelled, or the worker is required to leave Australia for reasons related to the sponsorship, the employer may be required to pay the reasonable costs of the worker (and their dependants) travelling to their home country. This obligation can apply even after the employment relationship has ended.

While this obligation arises less frequently than the others, it can be a costly surprise for employers who are unaware of it, particularly in cases where the employment ended on unfavourable terms.

What happens if you get it wrong

The Department of Home Affairs has a dedicated Sponsor Monitoring Unit that conducts both random and targeted audits. The consequences of non-compliance are tiered:

• Administrative sanctions: barring from sponsoring additional workers for a specified period
• Infringement notices: financial penalties for specific breaches
• Civil penalties: court-imposed penalties for serious or repeated breaches, which can be substantial
• Cancellation: loss of approved sponsor status, affecting all current and future sponsored workers

The Department has shown an increasing willingness to enforce these provisions, particularly in industries where exploitation of sponsored workers has been identified as a systemic issue.

Practical steps for compliance

Managing sponsorship obligations does not need to be burdensome, but it does need to be deliberate. We recommend that employers:

1. Maintain a sponsorship register that tracks each sponsored worker, their visa conditions, salary, and key dates
2. Conduct an annual salary review against current market rates for each nominated occupation
3. Establish an internal process for notifying the Department of relevant changes within the required timeframes
4. Keep employment records in an organised, accessible format that can be produced at short notice
5. Engage a migration adviser to conduct a periodic compliance review, particularly before nominating new workers or renewing sponsorship approval

Designated Area Migration Agreements (DAMAs) have become one of the most important tools for regional employers struggling to fill positions through standard visa pathways. By allowing concessions to the standard requirements of the Skills in Demand (subclass 482) and Employer Nomination Scheme (subclass 186) visas, DAMAs open doors that would otherwise remain closed, particularly for occupations that fall outside the standard skilled occupation lists or for roles that do not meet the standard salary thresholds.

As of early 2026, there are 13 active DAMAs operating across Australia. Each is negotiated between the Australian Government and a regional authority (typically a local council, state government body, or regional development organisation), and each has its own list of eligible occupations and specific concessions. Below, we provide an overview of the key DAMAs currently in operation and the concessions that make them stand out.

Understanding the core concessions

Before looking at individual DAMAs, it helps to understand the types of concessions that are typically available:

• Occupation concessions: access to occupations not on the standard skilled occupation lists (such as ANZSCO Level 4 and 5 roles)
• Salary concessions: a lower Core Skills Income Threshold (CSIT), allowing sponsorship at salaries below the standard $76,515 threshold
• English language concessions: reduced English language requirements for visa applicants
• Age concessions: flexibility on the age requirement for permanent residency pathways
• Skills and qualifications concessions: alternative pathways to demonstrating skills, such as accepting relevant work experience in place of formal qualifications

Northern Territory DAMA

The NT DAMA was one of the earliest and remains one of the most comprehensive. It covers a broad range of occupations, from hospitality and tourism to healthcare, trades, and agriculture. It is administered by the NT Government and is available to employers across the entire Northern Territory.

Key features include access to over 100 occupations with salary threshold concessions, English language concessions for certain occupations, and a permanent residency pathway through the 186 visa with age concessions up to 54 years. The NT DAMA is particularly useful for hospitality and aged care employers who struggle to meet standard salary thresholds.

Far North Queensland DAMA

Covering the Cairns and Far North Queensland region, this DAMA is well-suited to the tourism, hospitality, and agriculture sectors that drive the local economy. It includes occupations such as cooks, accommodation managers, and agricultural workers that are difficult to fill in the region.

The FNQ DAMA offers salary threshold concessions for most occupations and English language concessions for applicants who can demonstrate functional workplace English. It also includes a permanent residency pathway with age concessions.

South Australia Regional DAMA

South Australia operates one of the more structured DAMA arrangements, with concessions that vary by region and occupation. It covers a wide footprint across regional South Australia and includes occupations in healthcare, aged care, hospitality, meat processing, and trades.

The SA DAMA is notable for its relatively generous salary concessions and a clear permanent residency pathway. Employers in aged care and meat processing have found it particularly valuable given the persistent shortages in those sectors.

Orana Region (NSW) DAMA

Centred on Dubbo and the surrounding Orana region of New South Wales, this DAMA targets the labour shortages in agriculture, healthcare, and hospitality that affect inland NSW. It was one of the first DAMAs outside the Northern Territory and has been well utilised by regional employers.

Key concessions include access to a broad list of occupations, salary threshold concessions, and English language concessions. The Orana DAMA also offers a pathway to permanent residency under concession arrangements.

Other notable DAMAs

Several other DAMAs are worth noting for employers in specific regions:

• Great South Coast (VIC): focused on meat processing, dairy, aged care, and hospitality, with strong salary concessions for lower-skilled occupations
• Goldfields (WA): tailored to the mining and resources support sectors, as well as regional hospitality and health services
• South West (WA): covering the Bunbury and Margaret River regions, with a focus on tourism, agriculture, and aged care
• Adelaide City Technology and Innovation DAMA: unique in that it targets metropolitan Adelaide and focuses on technology, professional, and innovation roles rather than traditional regional occupations
• East Kimberley (WA): one of the more remote DAMAs, with significant concessions reflecting the difficulty of attracting workers to the region

Which DAMA is right for your business?

The right DAMA depends on several factors: where your business is located, what occupation you need to fill, what salary you can offer, and whether a permanent residency pathway is important for attracting and retaining workers.

Not all DAMAs are created equal. Some offer deeper salary concessions but a narrower list of occupations. Others provide access to a wider range of roles but with fewer concessions on English or age. The key is to match your specific needs against what each agreement provides.

It is also worth noting that accessing a DAMA is not automatic. Employers must enter into a labour agreement with the Department of Home Affairs under the umbrella of the relevant DAMA. This requires demonstrating that you have a genuine need for overseas workers, that you have made efforts to recruit locally, and that you will comply with all the terms of the agreement.

The outlook for 2026

The Australian Government has signalled its continued support for DAMAs as a tool for addressing regional labour shortages. Several existing DAMAs are expected to be expanded or renewed in 2026, and there is ongoing discussion about new agreements in regions that are not currently covered.

For regional employers, DAMAs remain one of the most practical solutions to chronic labour shortages. If you have not explored whether a DAMA applies to your region and your workforce needs, now is a good time to start.