In late 2024, the Department of Home Affairs quietly updated five occupations in the Medium and Long-term Strategic Skills List (LIN 19/051: MLTSSL) using ANZSCO 2022 titles, despite the law clearly prescribing ANZSCO 2013 for these visas.
The change, made through a legislative instrument, conflicts with the Department’s own legal definition of ANZSCO, leaving these occupations technically incorrect under the Migration Regulations.
The Misaligned Five
| ANZSCO Code | ANZSCO v1.2 (2013) | ANZSCO v2022 (2022) |
| 322211 | Sheetmetal Trades Worker | Sheetmetal Worker |
| 332211 | Painting Trades Worker | Painter |
| 333211 | Fibrous Plasterer | Plasterer (Wall and Ceiling) |
| 333212 | Solid Plasterer | Renderer (Solid Plaster) |
| 334113 | Drainer / Drainlayer | Drainer |
The Issue You Need to Know About
On 13 December 2024, the Department registered LIN 24/083 – Migration Amendment (Relevant Assessing Authorities and Other Matters) Instrument 2024.
Among other amendments, it updated LIN 19/051 – Specification of Occupations and Assessing Authorities, which contains the MLTSSL, replacing five occupation titles with their ANZSCO 2022 equivalents.
Yet the explanatory statement to LIN 24/083 made no mention of these title changes or of any underlying update to the ANZSCO version.
Just a week earlier, on 6 December, the Department had registered LIN 24/105 – Migration (ANZSCO Definition) Specification 2024, which defined ANZSCO v1.2 (2013) as the operative version for all skilled programs under regulation 1.03 — except for regulations 2.72, 2.73 and 5.19(5) (covering subclasses 482 and 186).
In other words, although LIN 24/105 had already established ANZSCO v1.2 (2013) as the governing definition for skilled visas, LIN 24/083—issued only a week later—introduced ANZSCO 2022 titles into the MLTSSL. This has created a significant inconsistency between the version of ANZSCO that is legally in force and the titles now displayed in LIN 19/051 for GSM visas (189, 190, 491, and 485).
Extent of the Inconsistency
The inconsistency is not limited to a single data source; it extends across the Department’s own official sources.
Taking the occupation 332211 – Painting Trades Worker (v1.2) / Painter (v2022) as an example, here’s how it currently appears across official sources for GSM visas (189, 190, 491, and 485).
SkillSelect: autoloads the occupation as Painting Trades Worker (v1.2):
Department’s website: displays Painting Trades Worker (v1.2):
ImmiAccount (Visa Application System): autoloads the occupation as Painter (v2022):
LIN 19/051: Within the Medium and Long-term Strategic Skills List (MLTSSL), the occupation appears as Painter (v2022) — reflecting the update made through LIN 24/083.
LIN 19/051: In the same legislative instrument, the occupation still appears as Painting Trades Worker (v1.2) in the Assessing Authorities table.
This inconsistency is replicated across all five affected occupations.
The Department’s systems and instruments are effectively referencing two different ANZSCO versions for the same roles, depending on where the information is accessed.
Applicants may see the 2022 title (e.g. Painter) in visa application forms, while the legislation that governs eligibility for GSM visas continues to rely on ANZSCO 2013 (e.g. Painting Trades Worker).
Why does this matter?
This is more than a technical oversight; it represents a legislative misalignment.
Under LIN 24/105, ANZSCO 2013 is the prescribed version for all GSM visas. However, by introducing ANZSCO 2022 titles into LIN 19/051, the Department effectively blurred the line between what is legally enforceable and what is operationally displayed.
When government systems, instruments, and state agencies start reflecting different ANZSCO versions for the same occupation, it creates uncertainty and inconsistency.
A clear example can be seen in the Queensland State Nomination lists published by Migration Queensland.
In the latest updates:
- The Queensland Onshore Skilled Occupation List refers to 322211 – Sheetmetal Worker (the ANZSCO 2022 title).
- The Queensland Offshore Skilled Occupation List refers to 322211 – Sheetmetal Trades Worker (the ANZSCO 2013 title).
Both lists refer to the same occupation code, but each uses a title from a different ANZSCO version.
Department’s Response
Following the identification of this inconsistency, we sought clarification directly from the Department of Home Affairs.
In its official response, the Department confirmed that LIN 24/105 – Migration (ANZSCO Definition) Specification 2024 establishes ANZSCO 2013 as the version defined under regulation 1.03 for all skilled programs, except for regulations 2.72, 2.73, and 5.19(5), which apply to subclasses 482 and 186.
In other words, GSM visas (189, 190, 491, and 485) continue to operate under the ANZSCO 2013 classification, while employer-sponsored visas (482 and 186) utilise the ANZSCO 2022 classification.
The Department also confirmed that there are no current plans to amend the legislation to align these definitions.
Our Analysis
While the legislative inconsistency is now confirmed, the underlying cause appears to be technical rather than intentional.
In our view, the issue likely stems from the coexistence of two distinct ANZSCO data frameworks — version 1.2 (2013) and version 2022 — being used simultaneously across different visa programs.
Each version represents an independent catalogue with separate occupational datasets, and integrating both within the same system introduces inevitable complexity and inconsistency.
When the Department introduced ANZSCO 2022 for subclasses 482 and 186, this likely created compatibility challenges in the software platforms and databases that power SkillSelect, ImmiAccount, and the legislative occupation tables.
While this is, of course, our humble interpretation, it highlights the broader difficulty of maintaining legislative and technical consistency when two classification systems must coexist within the same regulatory framework.
