The first person to read your entry on the sponsor register may be a buyer's lawyer. The Migration Amendment (Combatting Migrant Exploitation) Bill 2025 proposes a public register of approved work sponsors. It would list each nominating sponsor's name, ABN, postcode, nomination count and nominated occupations. In a sale of business, that entry is due diligence before the data room opens. It tells the buyer how much of the workforce depends on sponsorship, and it invites questions the vendor should be able to answer.
This note explains what the register would show, who would read it and the housekeeping we recommend before it goes live. Our commercial practice and the migration team run that review together, because most of the fixes sit in contracts.
In short: The proposed Approved Work Sponsor Register would publish each nominating sponsor's name, ABN, postcode, nomination count and nominated occupations, but not worker names. Sponsors should check that every contract, nomination and payroll record agrees, and that each salary still clears $79,423.
Who would read it, and what they would see
A buyer reads the nomination count against headcount and asks what happens at completion. In an asset sale the sponsorship does not transfer, so every sponsored worker needs a fresh nomination by the buyer. The register makes that exposure visible before the vendor has framed it.
A competitor sees which occupations you nominate and how often. A union sees a nomination pattern it can raise in bargaining or in the press. Neither sees salaries, names or outcomes. What they see is enough to ask questions, and a sponsor should have a short, accurate answer ready.
A worker checks whether an employer actually holds approval and has nominated similar roles before. An employer that claims to sponsor but does not appear would warrant careful questions. The register would show nothing about individual workers, so a worker's exposure is only through the occupation description against the employer.
The register would cover Standard Business Sponsors and accredited sponsors who lodge nominations under the subclass 482 visa and related employer pathways. Small businesses are not exempt. A sponsor with one nomination sits beside a sponsor with a hundred.
When it would start
The register operates only once the Bill passes and commences. The Bill provided for commencement on a day fixed by proclamation, or six months after Royal Assent if no earlier day is fixed. Check the Bill's current status before relying on a date. The sensible course is to treat the review as due now.
Where does your file sit today?
Which describes your sponsorship records?
The house-in-order checklist
The register does not publish compliance results. It draws attention, and attention leads to scrutiny. Work through these items and your browser will remember what you have confirmed.
Figures verified against Home Affairs visa pricing as at 1 July 2026.
Why most of the fixes are contract fixes
When we run these reviews, the migration file is usually in better shape than the contracts. The nomination was prepared carefully. The contract was signed a year earlier from a template, and it has drifted. A salary that cleared the threshold at lodgement now sits under it after indexation. A duties clause lets the business move the worker anywhere. A repayment clause for training costs reads, to an inspector, like recovery of sponsorship costs.
Our commercial practice fixes those by variation rather than by re-papering the workforce. Our note on employment contracts for sponsored staff sets out the clauses we change. The obligations themselves are explained in our note on becoming a standard business sponsor.
The register in a sale of business
Once the register is live, a vendor's sponsorship activity is public before the first meeting. We recommend three things. First, complete the review above before going to market, so the answers are ready. Second, expect the buyer to ask for warranties that the sponsorship obligations have been met, and be able to give them. Third, plan the completion date against the visa position of each sponsored worker. The buyer needs its own approval and fresh nominations before they can work for it.
Our guide to selling a business with sponsored employees works through the timing for both sides. The commercial practice handles the sale agreement, and the migration team handles the nominations that follow.
What the register would not do
It would not replace monitoring, site visits or sanctions. Those continue as before, and a public register is likely to increase referrals. It would not publish names, salaries, visa outcomes or compliance history. And it would not offer an opt-out. A business that does not want its sponsorship activity public should weigh that before its next nomination.
Frequently asked questions
Will the register show our postcode if the business runs from a home address?
The Bill proposed publishing the business postcode, without an exception for home-based businesses. The detail sits in regulations and administrative arrangements that follow the Bill, so watch for those before commencement.
Does a sale of business change our register entry?
In an asset sale the vendor's entry stays with the vendor entity and the buyer builds its own once it nominates. In a share sale the entity survives, so the entry continues under the same name and ABN. Any change of control is notified to the Department.
Should sponsorship compliance appear in vendor warranties?
Yes, where the vendor holds sponsorship approval. Buyers already ask for it in larger deals, and the register will make the question routine. A vendor that has completed the review above can give it with confidence.
Would accredited sponsor status show on the register?
The Bill listed five data items and did not specify accreditation. Whether status appears will depend on the final legislation and the Department's arrangements. Accreditation still matters, because it brings priority processing and signals a compliance record.
Can a union rely on the register in bargaining?
Nothing in the Bill prevents it. The nomination count and occupations would be public information. A sponsor should be ready to explain its local recruitment and its pay position without breaching any worker's privacy.
General information as at 2 September 2026. Not legal advice. The register depends on legislation that may change before commencement, so check the current status and obtain advice before acting.