0055 American Chamber of Commerce in Australia

General information

Submitterʼs name
American Chamber of Commerce in Australia
Submitted on behalf of
Professional body or industry association

About the submission

Is your organisation an Approved Sponsor for any of the following programs?
  • Temporary Work (Skilled) (Subclass 457) visa program
  • Employer Nomination Scheme (Subclass 186) visa program
  • Regional Sponsored Migration Scheme (Subclass 187) visa program
  • Labour agreements
Please identify which occupations your submission relates to:
Certain categories of occupations (eg professionals, managers or tradespeople)
What occupation categories does your submission apply to?
Technicians and Trades Workers
Machinery Operators and Drivers


1. Are there additional labour market factors, for which there are national datasets available (ideally aligned to 6-digit ANZSCO occupation level), that are relevant to future refinements to the Departmentʼs analysis and methodology?

What is the frequency of data release?


2. The Department is also seeking submissions on suitable datasets that are disaggregated by region. Please provide details if you are aware of such a dataset, including whether it is aligned to ANZSCO occupations and how often the dataset is updated.


3. Is there any other advice or evidence that the Department should consider in its review of the methodology?

We represent a large community of legitimate users of the skilled migration program. Many of our members depend on the ability to bring these skills and occupations to Australia. We appreciate the opportunity to continuously or periodically have input into which skills and occupations should be on these lists.

It is imperative Australia has a workable system in place to attract to Australia skills and occupations that are in short supply here. Ongoing revisions to the 457 skilled migration program may have:

o a direct and major impact on our ability to attract investment / innovation / manufacturing / talent to Australia; and

o the potential to interrupt or slow our members operations by denying temporary talent needed to accomplish their respective missions in Australia.

The Labour Market Factors set out in the methodology fail to take into account external sources of classification outside the ANZSCO Classifications. As such, it is likely occupations classed differently outside of Australia may be omitted from the list thereby deterring outside investment, innovation and talent.

A key challenge in having abolished the 457 program will now be providing clear and steady signals to potential temporary migrants that the rules will not change again significantly during their planned temporary stay in Australia. In addition, a sufficiently long validity period is required so that talented workers and their families have the assurance of continuity in their status in Australia. For example, two years is too short a notice to entice many senior executives or experts to uproot their families many of whom have issues around their schooling – to come here in the first place. The proposed traffic light bulletin model outlined in the methodology fails to provide any degree of certainty around the time periods for any proposed changes to come into effect or whether such changes will, like the Australian Citizenship Legislation Amendment (Strengthening the Requirements for Australian Citizenship and Other Measures) Bill 2017, also be retrospective in nature.

Below is a list of current occupations removed from the list, vitally important for our member’s business operations, which we submit should be reinserted:

Occupations Current List Required List
Driller (712211) Removed STSOL
Marine Transport Professionals NEX (231299) Irrelevant Visa List STSOL
Ship’s Engineer (231212) Irrelevant Visa List STSOL
Ship’s Master (231213) Irrelevant Visa List STSOL
Ship’s Officer (231214) Irrelevant Visa List STSOL

Thank you for your consideration, and for this opportunity to submit AmCham’s views on this important facet of the US-Australia economic and trade relationship.

Yours sincerely,

April Palmerlee
Chief Executive Officer
Do you have any supporting material for your submission?
Yes (see attachments)

These files have not been modified and are published as supplied

If you have trouble accessing this document, please contact the Department to request a copy in a format you can use.

Last modified on Friday 10 November 2017 [39071|92581]