• By Saurabh Smar, Principal Solicitor, Global Vision Migration Lawyers
  • 31 Jul, 2026

On 25 July 2026, the Australian Government introduced Ministerial Direction 119, replacing Ministerial Direction 105 entirely and restructuring how the Department of Home Affairs processes every skilled visa application in the system. This includes applications already lodged and waiting.

Where you are located when you apply, and what occupation your application is linked to, now determines your position in the queue. If you have an application pending or are about to lodge one, this matters to you right now.

The Five Priority Tiers

Priority 1
Law enforcement or defence occupations where the applicant is in Australia.
Priority 2
Law enforcement or defence occupations where the applicant is outside Australia.
Priority 3
Construction, healthcare, and teaching occupations where the applicant is in Australia.
Priority 4
All other skilled visa applications where the applicant is in Australia.
Priority 5
All other skilled visa applications where the applicant is outside Australia.
Practical Effect
A nurse already in Australia sits at Priority 3. The same nurse applying from overseas sits at Priority 5. An onshore software engineer sits at Priority 4, while offshore they drop to Priority 5. The gap between these positions is measured in months.

Lawyer Insight (GVM Strategy)

The most important strategic shift is the onshore versus offshore distinction. If you are currently in Australia on any substantive visa and your occupation does not fall in the top three priority categories, lodging your application before you depart moves you from Priority 5 to Priority 4 at minimum. For construction, healthcare, or teaching applicants, that same decision moves you from Priority 5 to Priority 3. This is a real, actionable advantage worth discussing with a lawyer before you travel.

What Makes This Change Significant

Two things set Ministerial Direction 119 apart from what came before.

First: for the first time, the Skills in Demand (Subclass 482) programme is captured within a processing priority framework. Every 482 application now has an explicit priority tier. Previously there was none.

Second: the Direction applies to all applications currently on hand, not just those lodged after 25 July 2026. If your application was sitting in the queue before the commencement date, your position in that queue has just changed.

The visas covered include the Subclass 482, 186, 189, 190, 191, 491, 494, 887, and 888, among others. Every major skilled migration pathway is within scope.

Current Processing Times: What to Expect

These figures are indicative, based on recently decided applications, and will shift under the new priority framework.

Visa50th percentile90th percentile
Subclass 189Approximately 6 monthsApproximately 8 months
Subclass 190Approximately 13 monthsApproximately 17 months
Subclass 491Approximately 15 monthsApproximately 23 months

Important: Applicants at Priority 4 and 5 should plan for timelines at the longer end of these ranges as higher priority applications absorb processing capacity ahead of them.

Lawyer Insight (GVM Strategy)

Employers sponsoring workers who are currently offshore in non-priority occupations need to revise their workforce planning timelines. A commitment to a worker about their start date that was based on prior processing patterns may no longer be realistic. We are advising employer clients to review all pending offshore nominations in light of the new framework.

Who Is Most Affected

Offshore applicants in non-priority occupations face the most material change. They now sit at Priority 5, the bottom of the queue, regardless of how long their application has been pending.

Onshore applicants in construction, healthcare, and teaching are the clear beneficiaries. Their applications have moved to Priority 3 under the new framework.

Subclass 482 holders and their employers are experiencing the Direction in a new way, since the programme was not previously subject to any processing priority order.

Real-World Scenarios

The nurse onshore: A registered nurse in Melbourne on a Subclass 482 visa has a permanent employer-sponsored application pending. Under Ministerial Direction 119 she sits at Priority 3. This is a meaningful improvement in her queue position.

The engineer offshore: An ICT professional applying from India for a Subclass 189 sits at Priority 5. His expected processing timeline has effectively lengthened under the new framework.

The construction worker who can apply onshore: A Filipino welder currently in Australia on a student visa can lodge his 482 visa application before his visa expires, placing him at Priority 3 instead of Priority 5. The difference in processing time is significant.

Frequently Asked Questions

Does Ministerial Direction 119 apply to my existing application?

Yes. It applies to all on-hand applications from 25 July 2026, including those already lodged.

Does a higher priority tier guarantee faster processing?

No. Priority determines order of processing, not outcome or a guaranteed timeframe.

Does the Direction affect the Subclass 482 programme?

Yes. The Skills in Demand (Subclass 482) visa was not previously included under Ministerial Direction 105. It is now fully within scope.

Can I improve my priority by applying onshore?

If you are already in Australia on a substantive visa, lodging onshore moves you from Priority 5 to Priority 4 at minimum, and to Priority 3 if your occupation is in construction, healthcare, or teaching.

What was replaced?

Ministerial Direction 119 replaced Ministerial Direction 105 in full from 25 July 2026.

Speak to an Immigration Lawyer Today

Ministerial Direction 119 is live, and its effects on processing timelines are already being felt. Whether you are an employer with offshore nominees, a skilled worker with a pending application, or someone planning to lodge soon, the strategic implications of the new priority framework are real and immediate.

Immigration lawyer Saurabh Smar and the GVM team of admitted legal practitioners are advising clients across Australia on the practical impact of the new Direction. We review pending applications, assess whether strategic adjustments are available, and advise employers on revised workforce planning timelines.

Call Global Vision Migration Lawyers on 0430 081 804 or visit Book an Immigration Consultation in Australia | GVML to book a consultation.

We are available across Melbourne, Sydney, Canberra, Perth, and the Gold Coast.