📅 Originally published: 2023 | Last reviewed and updated: June 2026
Introduction
The Subclass 491 Skilled Work Regional (Provisional) visa is a temporary visa designed as a direct pathway to the Subclass 191 Permanent Residence (Skilled Regional) visa. As of 2026, the first cohort of Subclass 491 holders who were granted their visa from November 2019 have completed their three-year regional living and working requirement and are now actively lodging Subclass 191 applications. This guide explains the full eligibility requirements, the ATO Notice of Assessment obligations, regional living conditions, processing times in 2026, and the key mistakes to avoid before lodging.
Understanding the Pathway: Subclass 491 to Subclass 191
The Subclass 491 Skilled Work Regional visa provides skilled migrants with an opportunity to live and work in a designated regional area of Australia on a provisional basis for up to five years. The Subclass 191 is the permanent residency pathway that follows, provided the applicant meets three core requirements: living in a designated regional area, working in that area, and lodging ATO Notices of Assessment for three of the five years of the provisional visa.
The Subclass 191 also accepts holders of the Subclass 494 Skilled Employer Sponsored Regional (Provisional) visa (https://augustineandco.com/services/skilled-regional-work-visas/) under the same regional stream. All references to the 491 pathway in this guide apply equally to 494 holders.
Transitioning as a Primary or Secondary Applicant
A secondary applicant on a Subclass 491 or Subclass 494 visa (for example, a spouse or partner included in the original application) can apply as the primary applicant for the Subclass 191 visa, provided they independently meet all eligibility requirements. This includes their own three-year regional living and working requirement and their own three ATO Notices of Assessment.
This flexibility is particularly relevant for couples where one partner may have changed occupation or circumstances during the provisional visa period. Each individual’s eligibility is assessed independently.
Subclass 191 Processing Times in 2026
The Subclass 191 visa has seen increasing application volumes as the first cohort of 491 holders (granted from November 2019) became eligible from late 2022 onwards. Processing times as of mid-2026 are:
Benchmark | Processing Time
50% of applications | 7 months
90% of applications | 14 months
These timeframes apply from the date of visa application lodgement. Applications that are missing ATO Notices of Assessment, have incomplete regional evidence, or require additional health or character checks will take longer. Always verify current processing times at immi.homeaffairs.gov.au before planning your lodgement timeline.
For context on how other permanent residency documentation requirements compare, see our guide on common mistakes to avoid when applying for permanent residency in Australia.
Practical tip: Lodge your application as soon as you have completed your three-year regional requirement and have three ATO NOAs available. There is no benefit to waiting, and lodging earlier means you receive permanent residency sooner while your provisional visa remains valid as a bridging visa.
Eligibility Criteria for Subclass 191 Visa
To be eligible for the Subclass 191 visa, the primary applicant must meet all of the following requirements:
Hold an eligible provisional visa
You must currently hold, or have held, a Subclass 491 or Subclass 494 visa.Live and work in a designated regional area for at least three years
You must have lived and worked in a designated regional area of Australia for at least three years while holding your eligible provisional visa. Living or working in Sydney, Melbourne, Brisbane, Perth, or the Gold Coast puts you in breach of your provisional visa conditions (condition 8579) and makes you ineligible for the 191.ATO Notices of Assessment for three income years
The primary applicant must provide ATO Notices of Assessment (NOAs) for any three income years within the five-year provisional visa period. There is currently no legislated minimum income threshold for the Subclass 191. However, the NOAs must reflect genuine taxable income earned in Australia. The Department of Home Affairs may request further information if the income declared appears inconsistent with genuine employment in the nominated occupation and regional area.Meet health and character requirements
All applicants (primary and secondary) must meet standard health and character requirements, including medical examinations and police clearances.
For a broader overview of errors that affect all permanent residency applications, see our guide on common mistakes to avoid when applying for permanent residency in Australia.
Common Mistakes to Avoid Before Lodging the Subclass 191
Not confirming your regional area qualifies
Not all regional locations count for Subclass 191 eligibility. The Department of Home Affairs maintains a specific list of designated regional areas. Living in a regional town that is not on the approved list, or regularly commuting to work in a metropolitan area, can jeopardise your eligibility. Check immi.homeaffairs.gov.au for the current list before lodging.Missing or incomplete ATO Notices of Assessment
The NOAs must be issued by the ATO and must cover three separate income years during your provisional visa period. NOAs from before your provisional visa grant date do not count. If you have not lodged a tax return for one or more years, resolve this with the ATO before lodging the 191 application.Gaps in regional living evidence
The Department may request evidence of continuous regional living beyond the NOAs, including rental agreements, utility bills, bank statements, and school enrolment records for dependent children. Applicants who cannot produce this evidence risk a request for further information or refusal.Waiting until the provisional visa expires
Your Subclass 491 or 494 visa must be valid (or you must be on a related bridging visa) at the time you lodge the 191 application. If your provisional visa has expired and no bridging visa is in place, you may be unlawfully in Australia. Lodge the 191 well before your provisional visa expiry date.
If your application has been refused or your visa has lapsed, our immigration lawyers in Melbourne and Sydney can advise on your options. You may also find our guide on the CSOL and Skills in Demand visa useful if your occupation circumstances have changed during your provisional visa period.
Benefits of Subclass 191 Permanent Residency
Obtaining the Subclass 191 visa grants the following advantages:
Permanent residency: You can live, work, and study anywhere in Australia permanently, with no regional living restriction after the grant.
Medicare access: Permanent residents are eligible for Medicare, Australia’s public health system.
Sponsoring family members: Permanent residents can sponsor eligible relatives for certain visa categories, including partner and family visas (https://augustineandco.com/services/family-and-partner-visas/).
Pathway to citizenship: After meeting the residence requirements (generally four years in Australia including at least one year as a permanent resident), you become eligible to apply for Australian citizenship.
No more regional restrictions: Once the Subclass 191 is granted, you are no longer required to live or work in a regional area. You may relocate to any part of Australia.
For a complete overview of how Australia’s skilled migration system is evolving, read our Australia’s Migration Strategy Reform guide.
Frequently Asked Questions
Q. How long do I need to live in regional Australia before I can apply for the Subclass 191?
You must have lived and worked in a designated regional area of Australia for at least three years while holding a Subclass 491 or Subclass 494 visa. The three years do not need to be continuous, but they must fall within the five-year provisional visa period.
Q. Is there a minimum income requirement for the Subclass 191 visa?
As of June 2026, there is no legislated minimum income threshold for the Subclass 191. However, you must provide ATO Notices of Assessment for any three income years within your five-year provisional visa period. The income declared must reflect genuine employment in Australia.
Q. How long does the Subclass 191 take to process in 2026?
As of mid-2026, the Subclass 191 processes 50% of applications within 7 months and 90% within 14 months from the date of lodgement. Always verify current processing times at immi.homeaffairs.gov.au before planning your timeline.
Q. Can I apply for the Subclass 191 if I was a secondary applicant on my Subclass 491?
Yes. A secondary applicant on a Subclass 491 or 494 visa can apply as the primary applicant for the Subclass 191, provided they independently meet all eligibility requirements including the three-year regional living requirement and three ATO Notices of Assessment.
Q. Can Subclass 494 holders also apply for the Subclass 191?
Yes. The Subclass 191 accepts both Subclass 491 and Subclass 494 visa holders. The eligibility requirements are the same for both pathways.
Q. What happens if my Subclass 491 expires before I lodge the Subclass 191?
If your Subclass 491 expires before you lodge the 191 application and no bridging visa is in place, you may be unlawfully in Australia. Lodge your Subclass 191 application before your provisional visa expiry date to receive a Bridging Visa A (BVA), which allows you to remain lawfully in Australia while the 191 is being processed. If you are in this situation, contact our immigration lawyers in Melbourne immediately.
Conclusion
Transitioning from the Subclass 491 Skilled Work Regional visa to the Subclass 191 visa is a well-defined pathway to permanent residency in Australia for skilled regional migrants. Meeting the three-year regional requirement, having three ATO Notices of Assessment available, and lodging before your provisional visa expires are the three most critical factors for a successful application.
At Augustine and Co. Immigration Lawyers, we understand the complexities of regional migration and the importance of getting the 191 application right. Our team of experienced immigration lawyers is available to review your provisional visa history, assess your ATO documentation, and guide your application from lodgement to grant.
You may also find our guide on expanding access to the Subclass 186 TRT stream useful if your circumstances have changed during your provisional visa period. For a full overview of all skilled regional work visas available in Australia, visit our services page.
Disclaimer: This blog post is intended for informational purposes only and should not be construed as legal advice. The information provided is subject to change, and individuals should consult with a qualified immigration lawyer or consultant for personalized guidance regarding their specific circumstances.
Author
Calvin Augustine is the founding solicitor of Augustine & Co. Immigration Lawyers. He graduated with Honors from the University of London law school, before being admitted to practice in Malaysia and Australia (admitted in SA, appears in all Victorian Courts and Tribunals, at trial and appellate levels).