Migration
Business Plans
A business plan written for the person assessing the nomination, not for an investor — built around the provisions it has to answer, with market research sourced and projections reconciled to the lodged financials.
No visa requires a business plan. That is why it matters how one is written.
It is worth starting with the thing nobody says. No provision of the Migration Regulations requires a business plan — not for a Subclass 482 nomination, not for a Subclass 186 or 494 nomination, and not for a labour agreement request. Regulation 5.19, which governs 186 and 187 nominations, does not mention one. The Department’s own labour agreement guide does not use the phrase. There is no published Departmental guidance on what a migration business plan should contain, because there is no Departmental requirement for one.
A business plan is purely evidentiary. It exists to discharge criteria that are expressed in entirely different language — genuine need, direct control, capacity to employ for two years, capacity to pay the annual market salary rate each year, lawfully and actively operating, financially viable.
Which is precisely the argument for having one drafted properly. Because there is no prescribed form, there is no form of words that is automatically sufficient. A plan is good only to the extent that a delegate can read it and find, without doing the work themselves, the answer to each thing they have to be satisfied of.
A plan written to raise money fails for different reasons than a plan written as evidence. An investor deck is built to persuade on upside. A nomination plan is built to be checked: every figure traceable, every market claim footnoted, every headcount reconcilable to the turnover, and the organisational chart agreeing with the position actually being nominated. The common failures are structural, not cosmetic — and each one is a question handed to the delegate.
What a 186 Direct Entry nomination actually has to establish
This is the clearest case for a business plan, because regulation 5.19(9) sets out a list of things that financial statements alone cannot prove — particularly the forward-looking ones.
| Requirement | Provision | What has to be shown |
|---|---|---|
| Actively and lawfully operating | reg 5.19(9) | A business operating in Australia, lawfully, now — not merely registered |
| Identified need, under direct control | reg 5.19(9) | The application identifies a need for the person to work in the position under the direct control of the nominator |
| Genuine need | reg 5.19(9) | A genuine need for that person in that position under that direct control |
| Two years, full time | reg 5.19(9) | The person will work full-time in the position for at least two years, and the terms must not expressly exclude extension |
| Capacity to employ and pay | reg 5.19(9) | The business can employ the person for two years and pay at least the annual market salary rate for the occupation each year |
| Not labour hire | reg 5.19(9) | If the nominator hires labour out, the position must be part of its own activities and not for hire to unrelated businesses |
| Equivalent conditions | reg 5.19(9) | Non-earnings conditions no less favourable than for an Australian doing equivalent work at the same location |
| Compliance record | reg 5.19(4) | A satisfactory record of complying with Commonwealth and State employment laws; no unpaid nomination charge debt |
“Genuine need under the direct control of the nominator” is the phrase to write to. Note what regulation 5.19 does not say — it contains no “genuine position” criterion of the kind that applies to a Subclass 482 nomination. The 186 test is genuine need, and direct control. A plan that proves the business is busy has not addressed either. What addresses them is an organisational structure in which the position sits under a named supervisor, with a workload that exists whether or not this particular person fills it.
The two-year capacity question is where plans are won
Regulation 5.19(9) requires the business to be able to employ the person for at least two years and pay the annual market salary rate each year. That is a forward-looking financial claim, and it is the single limb that historical financial statements cannot establish on their own.
For an established, stable business the answer may be arithmetic. For a growing business, a recently restructured one, or one whose last financial year was unrepresentative, it is an argument — and it has to be built from contracted revenue, pipeline, industry benchmarks and a staffing plan whose cost is visible against projected turnover.
A plan that asserts capacity and a plan that demonstrates it read very differently. The second one shows the salary, the on-costs, the superannuation and the position’s share of overhead against the revenue it is funded from, with the basis of each figure stated so the delegate can follow it rather than take it on trust.
A labour agreement request asks for a business case, not a business plan
This distinction is worth getting right, because it changes the document.
The Department’s published labour agreement guide asks for a compelling, evidence-based business case for the employment of overseas workers, an accountant’s statement that the business has been lawfully and actively operating for at least twelve months, financial viability evidence, a workforce profile showing current and projected overseas worker numbers, details of the training to be provided to the Australian workforce, and a separate business case for each concession sought. For a variation request it asks for an updated workforce plan.
What it never asks for is a business plan. So where a matter is heading for a labour agreement or a DAMA endorsement, the document we write is the business case and the workforce material — which is a different shape, occupation by occupation rather than business-wide. The labour agreement page sets that out in full.
What the plan contains
Business overview Structure, ownership, trading history, premises and the legal entity the nomination is actually made by
Products, services and revenue model How the business makes money, and from whom
Market analysis Industry data cited inline and footnoted to its source, not assembled from unsourced assertion
Competitor landscape And the position the business occupies in it
Operations Premises, equipment, suppliers, processes and worksites
Organisational structure With the nominated position shown in it, under a named supervisor, agreeing with the nomination form
Personnel plan Headcount by role and year, reconcilable to projected turnover
Marketing and customer acquisition
Three-year financial projections With every assumption stated openly, and the nominated position’s full cost visible in them
Risk analysis And the visa-specific overlay for the pathway named on the form
A criteria table Mapping each section to the provision it answers, so the delegate does not have to
New businesses, and businesses with an unrepresentative year
A business without trading history is not a problem, but it changes what the plan has to do. Projections are built from expected first-year sales, the contracts or pipeline that support them, and industry benchmarks — with the basis of each figure visible.
The same applies to an established business whose last financial year was distorted — by a one-off loss, a restructure, a change of premises, or a year in which the position being nominated was being covered by overtime. Saying so, with the numbers, is far stronger than presenting a bare set of statements and leaving the delegate to draw their own conclusion from the worst line in them.
There is no published list of refusal reasons, and we will not invent one. The Department’s procedures manual is not published, so no public Departmental list of common business-plan failings exists. What we work from instead is the text of the provisions and the gaps we see on files sent to us for review — projections unconnected to the lodged financials, an organisational chart that contradicts the nomination, and market sections with no sources.
The business and investor visa question, answered
If you are here because you were told you need a business plan for an Australian business or investor visa, the position has changed and it is better to know now.
The Business Innovation and Investment Program closed permanently to new applications on 31 July 2024. The Department’s own page confirms it, and provides for visa application charge refunds for Subclass 188 applicants, and for Business Talent Subclass 132 Significant Business History and Venture Capital Entrepreneur stream applicants, who withdraw on or after that date.
Two things follow. First, the closure was of the entry point: Subclass 188 applications lodged before 31 July 2024 are still being processed, the Business Innovation Extension and Significant Investor Extension streams remain open to existing 188 holders, and existing 188 holders can still apply for the permanent Subclass 888. If you hold a 188, there is still a pathway and a business plan may still have work to do.
Second, what replaced the old Global Talent visa is the National Innovation visa (Subclass 858) — a permanent visa for people with an internationally recognised record of exceptional and outstanding achievement. It is invitation-only, it runs on an Expression of Interest, and it does not require a business plan at any stage. If an innovative venture in Australia is part of that case, a plan or pitch document can support it, and the National Innovation visa page sets out how.
So what are migration business plans still for? Three things, mainly: evidencing the capacity and need limbs of a 186 Direct Entry nomination; supporting the business evidence behind a 482 nomination; and, in a different shape, the business case and workforce profile behind a labour agreement or DAMA request. Those are real, current, and what this page is about.
Turnaround and price
A$1,150 incl GST at 10 to 12 working days, or 5 to 7 working days for 30% more and 1 to 2 working days for 50% more — chosen on the form. Tell us your lodgement date on the form and we will confirm before you pay whether it can be met.
Where the plan supports a nomination we are also preparing a Genuine Position or Market Salary report for, order them together — the plan and the reports then draw on one set of financials and one organisational structure, and cannot contradict each other.
General information, current at October 2026. This page explains where a business plan sits in the nomination criteria and how we write one. Zeolla Solutions prepares migration documentation, research and reports — we are not a law practice and this is not immigration advice. Your registered migration agent or lawyer advises on your matter; we build the evidence.
Business Plan
Complete the form and you receive a case reference immediately. Nothing is payable until we confirm scope and price in writing.
Common questions
Is a business plan required for a visa nomination?
No provision of the Migration Regulations requires one. Regulation 5.19, which governs Subclass 186 and 187 nominations, does not mention a business plan, and the Department’s labour agreement guide does not use the phrase. A business plan is evidence — it exists to prove things the criteria do require, such as genuine need, direct control, and the capacity to employ the person for two years and pay the market salary rate each year.
What does a 186 Direct Entry nomination have to prove about the business?
Under regulation 5.19(9): that the nominator is actively and lawfully operating a business in Australia; that there is a genuine need for the person in the position under the nominator’s direct control; that the person will work full time for at least two years; that the business can employ them for two years and pay at least the annual market salary rate each year; and that non-earnings conditions are no less favourable than for an Australian doing equivalent work.
Do you build the financial projections?
Yes — from the actual financials, contracted revenue or pipeline, and industry benchmarks, with every assumption stated. The nominated position’s full cost, including on-costs and superannuation, is shown against the revenue it is funded from, because that is what the two-year capacity limb turns on.
Can one plan support more than one nominated position?
Yes. Give us the positions and occupation codes on the form and the organisational structure and personnel plan cover them all, with each position’s cost separately visible in the projections.
Is a business plan what a labour agreement request needs?
No — it needs a business case. The Department asks for an evidence-based business case for the overseas workers, an accountant’s statement of at least twelve months’ lawful and active operation, financial viability evidence, a workforce profile with current and projected overseas worker numbers, training plans for the Australian workforce, and a separate business case for every concession sought. See the labour agreement and DAMA page.
Can I still get a business or investor visa with a business plan?
The Business Innovation and Investment Program closed to new applications on 31 July 2024. Applications lodged before that date are still being processed, the 188 extension streams remain open to existing 188 holders, and existing 188 holders can still apply for the permanent Subclass 888 — so if you already hold a 188, a plan may still have work to do. For anyone starting now, the National Innovation visa (Subclass 858) that sits in that space is invitation-only, based on an internationally recognised record of exceptional achievement, and does not require a business plan at any stage.
Can you rescue a plan someone else wrote?
Often. Attach it on the form and we will tell you which provision each part of it is meant to answer, where the gaps are, and whether fixing it or starting again is faster.
Is this the same as a labour hire licence business plan?
No. That is a document written to a state licensing scheme rather than to the Migration Regulations, and Victoria now requires one by name for new labour hire businesses. See the labour hire licence business plan page.
Do you cite your market data?
Yes, inline and footnoted to the source. An unsourced market section is the easiest part of a plan for a delegate to discount, and discounting it tends to take the projections built on it along with it.
How long does it take?
10 to 12 working days as standard, with 5 to 7 working days and 1 to 2 working day options priced on the form. The clock starts from a complete intake, including the financials.
Often ordered with this
Labour Hire Licence Business Plan
A plan written to the labour hire licensing scheme in the relevant state - fit and proper person material, compliance systems, worker accommodation and workplace arrangements.
Genuine Position (GP) Report
The position, the business, the organisational structure and the tasks mapped to the ANZSCO unit group, with the findings table against the Department considerations.
Labour Agreement & DAMA Support Package
The submission and the supporting evidence: labour market testing, market salary rate analysis, the business case for each occupation and concession, and the compliance record.
FromEvery Service, Every Price
All seventeen services with their prices and intake forms sit on one page.