Connecting migration policy, data and workforce strategy.

On 25 July 2026, the Australian Government introduced Ministerial Direction No. 119 (MD119), replacing Ministerial Direction 105 and changing the order in which many skilled visa applications are processed by the Department of Home Affairs.

While much of the discussion has focused on what changed, the more important question is what those changes reveal about Australia’s evolving skilled migration priorities and what they may mean for employer workforce strategy. The answer becomes clearer when MD119 is viewed alongside recently released Departmental application inventory data obtained under Freedom of Information.

What is Ministerial Direction 119?

Ministerial Directions are legally binding instructions issued under section 499 of the Migration Act 1958. They do not change visa eligibility requirements but direct the order in which eligible applications are processed. MD119 applies across key employer-sponsored and General Skilled Migration visa pathways.

Key Changes Under MD119

While MD119 retains many aspects of the previous Direction, it introduces several notable changes to processing priorities.

• New priority for defence and law enforcement: For the first time, employer-sponsored applications supporting Australia’s defence capability and law enforcement sectors receive the highest processing priority, reflecting the Government’s increasing focus on sovereign capability, national security and strategic workforce planning.
• Accredited sponsors: Accredited sponsors no longer receive dedicated processing priority, although accredited status continues to provide important administrative and compliance benefits.
• Regional employers: Regional employers no longer receive dedicated processing priority. Regional visa pathways remain unchanged, but employer location alone is no longer determines the Department’s processing hierarchy.
• Priority sectors: Healthcare, education and construction occupations continue to receive priority processing, reflecting the Government’s ongoing focus on critical workforce shortages.
• Onshore applications: Broadly speaking, the new framework prioritises defence and law enforcement occupations first, followed by designated healthcare, education and construction occupations. Remaining onshore applications are generally considered ahead of offshore applications, representing a notable shift in the Department’s overall processing approach.

Looking Beyond MD119

MD119 is only one part of the broader migration landscape. When considered alongside recently released Departmental application inventory data obtained under Freedom of Information, it provides valuable insight into the direction of Australia’s skilled migration program.

The Employer Nomination Scheme (subclass 186) remains one of Australia’s most sought-after permanent residence pathways. Departmental data shows the number of subclass 186 applications on hand increased from 15,669 applications in January 2024 to 48,352 applications by December 2025, with visa lodgements consistently exceeding visa grants during this period.

A similar trend is evident across the General Skilled Migration program, where the Department’s inventory data shows significant application volumes across occupations including registered nurses, civil engineers, early childhood teachers, carpenters and chefs.

These figures should not be viewed as predicting future processing times. Rather, they reinforce the continuing demand for skilled migration and the importance of planning sponsorship and permanent residence pathways well before visa expiry becomes a business-critical issue.

The MDU Take

Ministerial Direction 119 is more than a change to processing priorities. When considered alongside the Department’s latest application inventory data, it highlights how Australia’s migration program continues to evolve in response to changing workforce needs, infrastructure priorities and national interests.

For employers, the key question is not simply what has changed, but what those changes may mean for your workforce strategy.

Importantly, neither MD119 nor the Department’s inventory data should be viewed as predicting future processing outcomes. Processing times will continue to be influenced by a range of operational and policy factors.

What these developments do reinforce is that migration is increasingly becoming a strategic workforce capability issue rather than simply a recruitment solution.

Employers who regularly review their workforce needs, identify employees suitable for permanent residence early and incorporate migration into broader workforce planning are likely to be better positioned as Government priorities continue to evolve.

Practical Considerations for Employers

In light of these developments, employers should consider:

• reviewing employees who may become eligible for permanent residence over the next 12–24 months;
• identifying business-critical roles that may require future sponsorship;
• incorporating migration into broader workforce capability and succession planning;
• reviewing internal sponsorship and permanent residence policies;
• monitoring visa expiry dates well in advance; and
• seeking strategic migration advice early, particularly where migration forms part of longer-term workforce planning.

Partner with MDU

As Australia’s skilled migration program continues to evolve, early and strategic planning has never been more important.

MDU works with employers to assess sponsorship options, plan permanent residence pathways and align migration strategy with longer-term workforce needs.

If you would like to understand how these developments may affect your business, our Registered Migration Agents and Immigration Lawyers would be pleased to assist.