Page last updated: 21 May 2025
At Work Visa Lawyers, we are committed to contributing to a fairer, more efficient, and responsive Australian migration system. As part of this commitment, we have made a series of formal submissions to the Department of Home Affairs and other relevant government bodies.
Drawing on our extensive experience working with employers, skilled migrants, international students, and regional communities, our submissions aim to address practical challenges and propose meaningful reforms. These include improvements to skills assessment processes, occupation lists, regional migration pathways, and access to permanent residency, among others.
Our goal is to ensure the migration system better meets the needs of the Australian economy—particularly in addressing skill shortages—while also supporting individuals and families who wish to contribute to life in Australia.
Below, you can explore the key points from each of our recent submissions.
Submission: ‘A Migration System for Australia’s Future’
Date of the submission: 15 December 2022
Purpose of Submission
The submission offers expert feedback from Chris Johnston and the Work Visa Lawyers team on how Australia’s migration system can be reformed to address labour shortages, boost productivity, and support regional growth—while warning against the risks of radical proposals.
Key Issues Identified
- Migration aims must go beyond tax revenue – It should address skill shortages, regional development, humanitarian obligations, and nation-building.
- Current system is overly complex and discriminatory – Particularly against women, people with disabilities, and lower-skilled migrants.
- Severe and ongoing labour shortages – Especially in aged care, agriculture, hospitality, and regional industries.
- Grattan Institute’s recommendations are harmful – Their focus on high-income earners could deepen labour shortages in critical but lower-paid sectors.
Main Risks Highlighted
- Focusing only on high-income migrants will ignore essential lower-paid jobs (e.g. aged care, cleaning, truck driving).
- Abolishing the Skilled Occupation List and BIIP could harm sovereign capabilities and innovation.
- Crowding major cities with skilled professionals while neglecting regional Australia.
- No PR pathway for many 482 visa holders, especially in regional occupations.
- Barriers like the SAF levy, TSMIT, GTE, and skills assessments hinder access to much-needed migration streams.
Recommendations
- Revise Skilled Occupation List to include more lower-skilled roles in sectors with critical shortages.
- Create regional migration incentives and simplified visa pathways.
- Provide PR pathways for 482 visa holders on the Regional Occupation List.
- Simplify employer-sponsored migration, lower SAF levy for small/regional businesses.
- Balance temporary and permanent visas, avoiding a swing too far toward PR-only models.
- Remove the GTE requirement for Student visas.
- Streamline skills assessment and allow alternatives for those with Australian qualifications.
- Modernise professional registration, especially for health workers.
- Introduce a new visa for vulnerable persons affected by exploitation or family violence.
Conclusion
The current system needs sensible, inclusive reforms that support Australia's economic and regional needs—not radical overhauls that favour high earners at the expense of essential workers. Simply increasing permanent visas is not enough. The government must act to modernise migration pathways, especially for regional and lower-paid occupations, or risk deepening the very challenges it hopes to solve.'
Submission: Core Skills Occupation List
Date of the submission: 10 May 2024
Purpose of the Submission
This submission was proposed before the implementation of the Core Skills Occupation List in December 2024. The submission urges the government to ensure the Core Skills Occupation List (CSOL) is broad, inclusive, and reflective of regional and national labour needs, particularly as the CSOL will replace the Regional Occupation List (ROL) with the new Skills in Demand visa (replacing the subclass 482 visa) in late 2024.
Key Points and Concerns
- The draft CSOL is too narrow and risks excluding essential roles, especially in regional Australia.
- Grattan Institute’s influence is seen as problematic—its recommendations overly focus on high-income, high-skilled migrants, ignoring real labour shortages in lower-paid but critical roles.
- Abolishing the ROL without integrating regional needs into CSOL will cripple key sectors like agriculture, aged care, disability support, hospitality, and construction.
Main Recommendations
- Expand the CSOL to include essential roles across:
- Agriculture (e.g., Dairy Farmers, AgTech Technicians)
- Health & Care (e.g., Aged Carers, Disability Support, Registered Nurses for disabilities)
- Construction & Infrastructure (e.g., Draftspersons, Estimators)
- Hospitality (e.g., Chefs, Cooks, Hotel Managers)
- Education (e.g., Special Needs Teachers, Regional Teachers)
- STEM & ICT (e.g., UX Designers, Data Scientists, Web Developers)
- Preserve regional visa streams like subclass 494 and reform them to reduce burdens such as mandatory skills assessments and long experience requirements.
- Ensure CSOL supports sovereign capabilities such as food production, logistics, and essential services, not just fiscal returns through high-tax-paying migrants.
- Include occupations that meet real industry needs, not just those aligned with central city demand or high wage thresholds.
Risks Highlighted
- Over-centralisation: Focusing migration to big cities like Sydney and Melbourne worsens urban congestion and leaves regional areas under-served.
- Erosion of critical services: By sidelining roles like aged carers, child care workers, and disability officers, the system fails its social responsibilities.
- Loss of productivity: Industries like manufacturing, agriculture, and hospitality risk losing competitiveness due to labour shortages.
Conclusion
The submission strongly advocates for a realistic, inclusive, and regionally attuned CSOL that supports diverse sectors and job levels—not just high-income, city-based professionals. A comprehensive, balanced approach will better serve Australia's long-term economic stability, regional resilience, and social well-being.
Submissions: The Best Practice Principles and Standards for Skilled Migration Assessing Authorities
Date of the submission: 20 October 2023
Purpose of the Submission
The submission highlights serious concerns with Australia's current skills assessment system for skilled migration and offers key recommendations for reform to make the system more responsive, transparent, and aligned with real-world labour needs—especially for Australian graduates, regional employers, and health professionals.
Key Issues Identified
- Overly strict skills assessment criteria exclude qualified and experienced candidates, especially those without a formal degree.
- Monopoly by large assessment bodies (e.g. VETASSESS) leads to poor service, slow processing, and little accountability.
- Health professionals face long, outdated registration processes, even during crises like COVID-19.
- Australian-trained graduates are still required to complete unnecessary assessments, duplicating existing checks by national registration boards.
- Visitor visas are being refused for overseas nurses coming to sit mandatory exams in Australia due to strict GTE (Genuine Temporary Entrant) criteria—undermining efforts to address health sector shortages.
Recommendations
- Exempt Australian graduates from needing a separate skills assessment for certain skilled visas.
- Break monopolies by accrediting more skills assessment authorities to improve efficiency and competition.
- Align assessment criteria with actual industry needs (e.g. allowing experience to substitute for formal qualifications).
- Streamline health registration, including more frequent exam sittings and online access.
- Remove or modify GTE requirements for health professionals needing to enter Australia for exams.
Case Study: “Jasmeen” the Nurse
- A qualified nurse from India was twice denied a visitor visa to sit her required nursing exam in Australia, despite strong ties to her home country.
- This refusal reflects how federal visa policy directly blocks urgently needed workers from entering critical sectors like healthcare, while state governments offer financial incentives to attract them.
Conclusion
Australia’s migration and skills assessment system needs urgent reform to:
- Reduce unnecessary red tape,
- Address long-standing inefficiencies,
- Support regional and national labour needs, and
- Enable qualified migrants to contribute without facing arbitrary barriers.
