Ministerial Direction 119 replaced MD 105 on 25 July 2026. The headline most coverage led with was the occupation list. The part that will actually move your files is quieter: the applicant’s location at the time of application now sits above occupation for everyone below the law-enforcement and defence tiers.
This is a companion to our Australian visa processing times post, which tracks the published medians. Here we stay on the priority order itself.
The five bands
Highest priority first. Clause 8(3) governs visa applications; clause 7(3) sets the identical order for nomination applications.
| Band | Occupation | Applicant location at time of application |
|---|---|---|
| 1 | Law enforcement / defence interests | In Australia |
| 2 | Law enforcement / defence interests | Outside Australia |
| 3 | Healthcare, teaching, construction | In Australia |
| 4 | All other applications | In Australia |
| 5 | All other applications | Outside Australia |
Two mechanics that decide edge cases: priority is set by the primary applicant’s location, and combined family applications inherit the primary applicant’s priority (clause 8(4)).
Band 3 has no offshore twin — and that is the whole story
There is no band for “healthcare, teaching or construction, outside Australia.” Those applicants fall through to band 5, because band 3 requires the applicant to be in Australia and bands 4 and 5 split all other applications by location.
Follow that through with three 482 nominations lodged the same week:
| Client | Occupation | Location at application | Band |
|---|---|---|---|
| Priya | Registered nurse | In Australia (holds a 485) | 3 |
| Marco | Café manager | In Australia | 4 |
| Daniel | Registered nurse | Manila | 5 |
Priya and Daniel are the same occupation on the same visa and sit two bands apart. Marco — whose occupation carries no priority at all — sits above Daniel, a nurse.
Below the top two bands, being in Australia is worth more than being in a priority occupation. That is the sentence to have ready when a client asks why their offshore nurse is behind an onshore hospitality manager.
The top two bands are narrower than they sound
“Law enforcement and defence” reads broad. In the instrument it is very tight:
- Law enforcement — ANZSCO Unit Group 4413 (Police), and the applicant must be nominated or sponsored by the AFP or a named state or territory police force.
- Defence — occupations tied to AUKUS Pillar I or II, plus roles sponsored by the ADF or the Department of Defence.
For a general practice, bands 1 and 2 are effectively closed. Plan on the 3/4/5 split being the one that governs your caseload.
The middle band is broader than it sounds
Healthcare, teaching and construction are defined by ANZSCO groups, and they reach further than the labels imply. Extracts from the Direction’s definitions:
| Category | Includes (extract) |
|---|---|
| Healthcare | Sub-major Group 25 (Health Professionals), Minor Group 411 (Health and Welfare Support Workers), Medical Scientists, Counsellors, Psychologists, Social Workers, Medical Technicians, plus named roles including Aged or Disabled Carer, Nursing Support Worker and Personal Care Assistant |
| Teaching | Minor Group 241 (School Teachers), Child Care Centre Managers, plus School Principal, Vocational Education Teacher, Child Care Worker and University Lecturer |
| Construction | Sub-major Groups 33 and 82 (Construction Trades Workers; Construction and Mining Labourers), Construction Managers, Architects, Civil Engineering Professionals, Crane and Earthmoving Plant Operators, Structural Steel and Welding Trades Workers, plus Electrician (General) and (Special Class) |
Aged care, child care and general electricians all sit inside a priority category. That is worth checking before writing a client off as “all other” — and the Direction states occupations within a category are of equal priority, so there is no ranking inside band 3. These are extracts; check the client’s ANZSCO code against MD 119 itself.
It applies to files you lodged months ago
This is the part that turns it into work rather than reading. MD 119 applies to all on-hand applications, not just new lodgements. Nothing about an existing file changed — the Direction underneath it did.
| Under MD 105 (to 24 July) | Under MD 119 (from 25 July) | |
|---|---|---|
| Priya — nurse, onshore | Healthcare priority | Band 3 |
| Daniel — nurse, offshore | Healthcare priority | Band 5 |
| 482 applications | Not covered at all | Covered |
The 482 row matters on its own: Skills in Demand was outside MD 105 entirely. Every on-hand 482 nomination and visa application has just been brought into a priority framework it was never sorted by before.
Triaging a caseload against it
A practical order of work for on-hand skilled files:
- Record location at time of application on every file, if it isn’t already a field. It is now the single largest determinant of queue position, and it’s historical — it cannot be corrected later, only recorded.
- Re-check ANZSCO codes against the band 3 definitions. Aged care, child care and electrician files may have moved up without anyone noticing.
- Flag offshore files in priority occupations. These are the ones whose expected timeframe moved the most, and where a client is most likely to have been given an estimate that is now wrong.
- Reset expectations in writing on any file where you previously quoted a timeframe built on MD 105 assumptions.
Note what is not on that list: advising a client to change where they are. Location at the time of application is fixed for a lodged file, and for a prospective one it is bound up with visa status, work rights, cost and risk that have nothing to do with processing order. That’s a matter for advice on the individual case, not a queue-position tactic.
Students run on a different system entirely
Worth keeping straight, because the vocabulary is the same and the mechanics are not. MD 119 does not touch student visas. For subclass 500:
- Lodged inside Australia — assessed in lodgement order, by date. No priority tiers at all.
- Lodged outside Australia — Ministerial Direction 115 (or MD 111 for applications lodged before 14 November 2025), with Priority 1/2/3 set by the provider’s threshold status on the day of lodgement, not by the applicant.
So “onshore vs offshore” means something different on a student file than on a skilled one: for skilled it changes your band; for students it changes whether a priority system applies at all. The processing times post has the published commencement windows for each student priority level.
What nobody can tell you yet
Home Affairs publishes one median per visa category — it is not split by applicant location. There is no published figure for “onshore 482” versus “offshore 482”, and MD 119 is days old, so no data reflects it either way.
That means the honest position with a client is: the order of the queue has changed, and we can tell you which band you are in and why. How many weeks that converts to is not something anyone can source right now. Anyone quoting you a number for it is guessing.
What this means for your practice
Location at time of application has quietly become a field you need on the file, not a detail someone remembers. It sets the band, it applies retrospectively, and it is the first thing you will want to filter on when a client asks where they sit.
The practices that will handle this well are the ones that can answer “which of my on-hand skilled files are offshore in a band 3 occupation?” in one query rather than by opening thirty matters. When lodgement date, ANZSCO code and applicant location live on the client’s file, that’s a filter. That’s the kind of visibility Centrio is built around.
This is general information, not migration or legal advice. Priority bands affect the order applications are considered, not whether they are granted, and the criteria for grant are unchanged. Details were accurate at publication — always confirm against the Direction itself before advising on a specific file.
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