491-to-191 transition: PAM3 update clarifies income threshold and address continuity

The Department’s PAM3 Skilled Migration Operational Guidelines received an update covering the 491-to-191 transition. Three points worth noting:

Income threshold — applied per income year, not averaged

The threshold is AU$53,900 per income year (Australian financial year, 1 July – 30 June), and each of the three income years must independently meet it. Averaging is not permitted. A 491 holder who earns $80,000 in years 1 and 2 but $48,000 in year 3 does not qualify, even though the average is well above threshold.

Address continuity

The 491 visa requires the holder to live, work, and study in a designated regional area for the qualifying three years. PAM3 clarifies that “primary residence” must remain in a designated regional area continuously — short trips for personal or business reasons are permitted, but a primary address change to a non-regional area resets the qualifying period.

Evidence the Department actually requires

• Notice of Assessment (NoA) for each of the three income years showing taxable income
• Rental agreements, bills, or property ownership documents covering the residence period
• ATO myGov address history (now accepted as supporting evidence under PAM3)

Common failure modes

• Salary sacrifice arrangements reducing taxable income below $53,900 — even though gross pay was above
• Brief secondments to metropolitan offices (>90 days) reclassified as a primary address change
• Couples where one partner relocates back to a metropolitan area while the primary 491 holder remains regional