Employers · Group recruitment
Sponsoring several workers at once: one round of labour market testing for multiple nominations, the four-month window, the charges per worker, and showing you need the number
A single vacancy is one nomination; a new venue, a contract won or a facility opening is a workforce, and the employer asks whether the programme can bring six or ten workers at once. It can, on the standard programme, with one nomination per worker and one round of labour market testing for all of them where the positions are the same, provided the advertising sought the number of positions nominated and each nomination is lodged within four months of it. The costs scale with the number, the charge and the levy on every nomination, and so does the scrutiny: a business nominating ten chefs shows it needs ten, with the lease, the bookings, the roster and the financials, and a business that let Australians go in the occupation shortly before is read hardest. This guide sets out what the instrument allows and does not, the nomination per worker and the budget, the genuine need for the number and its evidence, the redundancy rule, accredited status for volume sponsors, the labour agreement where the numbers exceed the programme, and the sequence from the advertisement to the grants.
By Keshab Chapagain, registered migration agent (MARN 1576536) since 2015 · WIDEN, Sydney · Reviewed October 2026
Keshab Chapagain · MARN 1576536 · Registered since 2015 - Nominations
- One per worker, each with its own charge and levy
- Testing
- One round can support multiple nominations in the same occupation
- Conditions
- The advertising sought that number of positions; each nomination lodged within four months of it
- Genuine need
- Shown for the number: contracts, bookings, roster, financials
- Redundancies
- Testing must post-date any retrenchment of Australians in the occupation
- Volume
- Accredited status for priority; a labour agreement for numbers beyond the programme
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One sponsorship, many nominations
A standard business sponsorship, once approved, covers every nomination the business makes in its five years, with no limit on the number in the approval itself; each worker is nominated separately, in a nomination that identifies the position, the occupation, the salary, the location and the worker, carries its own charge and its own levy, and is decided on its own criteria, so that eight workers are eight nominations and eight visa applications under one sponsorship. The Department processes nominations from the same sponsor together where they are lodged together, and a group recruitment is lodged as a set, with a covering submission that explains the business's need for the number and attaches the common evidence once. The sponsor guide covers the approval that comes first.
One round of testing for multiple nominations
The labour market testing instrument requires the sponsor to have advertised the nominated position in the manner and for the period it sets, within the four months before the nomination, and it allows the same advertising to support more than one nomination where the nominations are for the same occupation and position and the advertising sought the number of positions nominated; a business that advertised for six welders and received no suitable Australian applicants lodges six nominations on that advertising, each attaching the same advertisements, the same applicant records and the same outcome. The advertising must have been for positions of the kind nominated, at the salary and in the location nominated, and the records must show how many applied and why none, or fewer than the positions, were suitable; an advertisement for one position used for six nominations is testing for one, and the other five are refused on the criterion. The testing guide covers the requirements for any nomination.
The advertisement that names the number
The advertisement states the title and the occupation, the duties and the skills required, the salary or the salary range, the location, and, for a group recruitment, the number of positions, as "six positions available" or "multiple positions", on at least the platforms and for at least the period the instrument requires; the number is stated so that the advertising is for the positions nominated, and a later nomination for a seventh position needs advertising that sought seven. The applicant records are kept per advertisement, with the number who applied, the shortlist, the interviews and the reasons each was not suitable, and a group recruitment that produced three suitable Australians and hired them nominates the remaining positions with the records showing that. The advertisement guide sets out what the advertisement must contain.
The four-month window
Each nomination must be lodged within four months of the advertising it relies on, and for a group recruitment that means every nomination in the set inside the window; a business that advertised in February and lodges four nominations in May and two more in July has two nominations outside the window, which need fresh advertising. The practical sequence is to advertise, close the advertising, assess the applicants, recruit the overseas candidates, assemble their documents, and lodge every nomination together well inside the four months; a business whose overseas recruitment will take longer than that advertises later, when the candidates are nearly ready, or runs a second round for the later nominations. The window is counted from the advertising's dates to the nomination's lodgement date, and the submission states both.
The charges and the levy per worker
Each nomination carries the nomination charge and the Skilling Australians Fund levy for each year of the visa nominated at the rate for the business's turnover, paid at lodgement, and each visa application carries its charge, paid by the worker; for a group of eight on four-year visas the levy alone is a multiple of the single-worker figure that the business budgets before advertising, and the levy for a nomination refused other than for false information is refundable, while the nomination charge is not. The sponsorship charge is paid once. The agent's fee for the employer's side is per nomination or per group as the agreement says, and the business's own costs, the overseas recruitment, the relocation it chooses to offer, the health cover it agrees to pay, are added. None of the sponsorship, nomination and levy costs may be recovered from the workers. The cost guide gives the figures to multiply.
Showing you need the number
- The event that created the need: the new venue's lease and fit-out, the contract won with its scope and term, the facility's opening, the expansion plan with the board's approval.
- The demand: the bookings, the orders, the client's forecast, the occupancy, the production schedule.
- The roster or the organisational chart with the positions marked, showing where each nominated worker sits and what they do.
- The existing workforce in the occupation, the Australians employed, and the gap the nominations fill.
- The financials: revenue, projections and the capacity to pay the nominated salaries for the number at the threshold and the market rate.
- The recruitment history: the advertising, the agencies, the applicants, and why the gap remains.
A business nominating many workers for the first time, or nominating a number out of proportion to its size, is examined for whether the positions are real, and the submission answers the question before it is asked; the genuine position guide covers the test, and the small business guide the size the Department expects for the positions nominated.
The redundancy rule
The instrument provides that where the sponsor has made Australian citizens or permanent residents in the same or a similar occupation redundant or retrenched in the four months before the nomination, the labour market testing must have been undertaken after the redundancies, and the nomination must disclose them; the Department reads a business that reduced its Australian workforce in the occupation and then nominated overseas workers for it as one whose need is doubtful, and the submission explains the change, a restructure, a new site in another location, a different skill set, with the evidence. A group recruitment that follows redundancies is the case the Department examines most closely, and the advertising is run after the last redundancy with the records showing the Australians who applied.
Accredited status for volume sponsors
An employer that sponsors in volume applies for accredited sponsor status where it meets the criteria of one of the categories, which include a trading history, a proportion of Australian employees, a compliance record, a corporate structure and for some categories a turnover or a number of sponsored workers, and accreditation gives priority processing of the employer's nominations and visas, which for a group recruitment with a venue opening date is worth the weeks it saves; the accreditation application is lodged with or after the sponsorship, takes weeks, and is renewed with the sponsorship. A first-time sponsor does not qualify, and a business that expects to sponsor again builds the record for the next time. The accreditation guide covers the categories.
When a labour agreement is the route
The standard programme has no cap on the number a sponsor may nominate, and a group recruitment in an occupation on the list at the threshold salary runs on it; a labour agreement is the route where the occupation is not on the list, where the workers available do not meet the English or experience standards, or where the business is in a sector with an industry agreement that provides the terms, and an agreement sets a ceiling on numbers as part of its terms. A business whose group recruitment needs an occupation off the list, or concessions, reads the company-specific agreement guide and the labour agreements guide, and plans for the months an agreement takes.
The sequence for a group recruitment
- Fix the number, the occupation, the salary at the threshold and the market rate, and the start date the business needs.
- Apply for sponsorship approval if the business is not a sponsor, and for accreditation if it qualifies.
- Assemble the evidence of the need for the number.
- Check for redundancies in the occupation in the preceding months, and time the advertising after them.
- Advertise for the number of positions, on the platforms and for the period the instrument requires, and keep the records.
- Recruit the overseas candidates in parallel, through the channels the finding workers guide describes, and have each start their skills assessment, English test and police certificates.
- Lodge every nomination inside the four-month window, as a set, with the covering submission and the levies.
- Have each worker lodge the visa as the nominations are lodged, so the grants follow together.
- Set up the files, the contracts and the payroll for each worker before the start dates, and read the first 90 days guide.
General information only, current at October 2026; not advice on your own case. The nomination criteria in regulation 2.72 of the Migration Regulations 1994, the labour market testing requirements in section 140GBA of the Migration Act 1958 and the legislative instrument made under it, including the provisions on advertising for multiple positions, the period before nomination and redundancies, the Skilling Australians Fund charges legislation, and the Department’s accredited sponsor criteria, as in force at the date above; the instrument and the criteria change and the current published position governs. Outcomes depend on the Department’s assessment of each nomination; no registered migration agent can guarantee a result (Code of Conduct, Migration Agents Regulations). Keshab Chapagain, MARN 1576536.
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We need to sponsor eight workers in the same occupation. Do we advertise eight times?
No. The labour market testing instrument allows one round of advertising to support multiple nominations in the same occupation, provided the advertising sought the number of positions you nominate, or more, and each nomination is lodged within the four-month window after the advertising; you run the advertisements once, stating that there are eight positions, consider the applicants, and lodge the eight nominations inside the window. An advertisement for one position does not support eight nominations, and nominations lodged after the window need fresh advertising.
Is it one nomination or one for each worker?
One for each worker. Every nomination identifies the position and the worker nominated for it, carries its own nomination charge and its own Skilling Australians Fund levy for the years of the visa, and is decided on its own; eight workers means eight nominations, eight levies and eight visa applications, under one sponsorship approval. The business budgets the charges and the levy per worker, which for eight workers on four-year visas is a significant sum, and reads the cost guide before committing.
Will the Department believe we need eight chefs?
If the business shows it. The genuine position test applies to each nomination, and a business nominating eight positions at once shows the need for eight: the new venue's lease and fit-out, the contract won, the bookings or the orders, the roster that the positions fill, the existing staff and the gap, the financials that can pay eight salaries at the threshold and the market rate, and the recruitment that failed to find Australians. A business with three staff and no new contract nominating eight is refused on the number, and a business that has just opened a second restaurant with the bookings to show is not.
We made some Australian staff redundant earlier this year. Does that matter?
Yes. Where the sponsor has made Australian workers in the same or a similar occupation redundant or retrenched in the four months before the nomination, the labour market testing must have been undertaken after those redundancies, and the Department reads a business that let Australians go and nominated overseas workers in their occupation as one whose need is not genuine unless it shows why. The advertising is run after the redundancies, and the nomination explains the change in the business.
Should we become an accredited sponsor, or get a labour agreement?
Accredited status is for employers who sponsor in volume and meet the category criteria, a trading history, a proportion of Australian staff, a clean record, and a corporate structure, and gives priority processing of nominations and visas, which for a group recruitment is worth weeks; a labour agreement is for numbers or occupations the standard programme does not allow, and takes months to negotiate. A business sponsoring eight in an occupation on the list uses the standard programme, applies for accreditation if it qualifies, and considers an agreement only where the standard route cannot deliver.
What does the consultation cost?
A$330 inc. GST for 30 minutes by video with Keshab Chapagain (MARN 1576536), credited in full against the engagement. For a group recruitment the session sets the sequence, the advertising for the number, the window, the nominations and the budget, and says whether accreditation or an agreement is worth pursuing.
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