Subclass 191 Permanent Residence (Skilled Regional) visa

GSM is a points, invitation, and nomination strategy, not a simple visa application. An expression of interest is only a statement of claims held in the selection system and is not a visa application. In the points-tested pathways, a primary applicant cannot lodge a valid application until a written invitation issues [Sch 1 1137(4B)] [Sch 1 1138(4)] [Sch 1 1241(4)]. Five stages must each be cleared: meeting the threshold requirements; being competitive enough to be selected; being nominated where the pathway needs a State/Territory or family role; being invited; and lodging a valid application within the invitation window. A person can clear one stage and still fail the next, and the score that matters is the one the applicant can prove, not the one typed into the system.

The pathways

Identify the pathway before discussing points: the independent point-tested permanent pathway (Subclass 189, no nomination); the State/Territory nominated permanent pathway (Subclass 190, nomination plus its small nomination point item); the regional provisional pathway by State/Territory nomination or by eligible-family sponsorship (Subclass 491); the progression from the regional provisional visa to permanent residence (Subclass 191), which is not a fresh points test but presently requires compliance and notices of assessment for the relevant income years [cl 191.222]; legacy regional progressions; and special streams. As at 12 July 2026, no minimum income amount is prescribed for cl 191.222, and current Home Affairs guidance states that there is no minimum income requirement. Each pathway has different occupation-list, invitation, nomination, residence, and post-grant consequences, and the nomination point items differ between them.

The Hong Kong stream

The Hong Kong stream is the clearest special stream: it turns on a qualifying passport plus a qualifying visa that must still be held at the time of application and have been held for the set period [sch 1 1137], together with a separate criterion of usual residence in Australia for a set continuous period immediately before the application [cl 189.242]: two distinct requirements, not one. It uses no points test, no skills assessment, no nominated occupation, no age-at-invitation limit, and no further primary-English test. Its health criterion also differs: the point-tested pathway uses a no-waiver health criterion while the Hong Kong stream's carries a waiver mechanism [cl 189.225] [cl 189.243]. Role swaps and aged-out dependants are analysed against the earlier visa and the primary-secondary relationship: the preservation rule generally depends on the same primary applicant carrying through, and if that link fails the person must qualify in their own right. Importing point-tested logic into the wrong stream is a recurring error.

The Subclass 191 is the permanent-residence step that a regional provisional visa (a Subclass 491 or 494 [reg 1.03]) leads to (the older Subclass 489 has its own separate progression, to the Subclass 887), and its defining feature is that it is a compliance-and-tax-notice pathway, not a second points test.

What it requires

In the Regional Provisional Visas stream, three things matter rather than a points score: holding the regional provisional visa for at least three years [Sch 1 item 1139(3)(c)]; compliance with the core regional condition [sch 8 cl 8579], which means actual compliance rather than merely substantial compliance [cl 191.221]; and notices of assessment for three relevant income years [cl 191.222]. Clause 191.222 allows an income amount to be specified, but as at 12 July 2026 no amount is prescribed and current Home Affairs guidance states that there is no minimum income requirement. A relevant income year is one that ended before the application and during which the qualifying visa was held for all or part of the year [cl 191.111]. No employer nomination is needed at this stage. The separate Hong Kong (Regional) stream instead uses its own substantial-compliance and residence criteria and has no cl 191.222 or condition-8579 requirement [cl 191.231] [cl 191.232].

The trap at lodgement

Lodging the Subclass 191 does not release condition 8579 while the regional provisional visa remains in effect (for a five-year 491 lodged in year three, typically until grant). After that visa ceases, the separate duty is substantial compliance with any subsequent bridging visa's conditions [cl 191.221] [sch 8 cl 8579]. A holder who treats lodgement as the finish line and moves out of the regional area while condition 8579 still binds creates both a refusal risk on the 191 and a cancellation risk on the provisional visa.