Migration (Specification of Required Medical Assessment) Instrument 2025

This instrument, the Migration (Specification of Required Medical Assessment) Instrument 2025 (the instrument), prescribes which visa applicants must undertake which medical assessments, and who may conduct them, for the purposes of paragraphs 4005(1)(aa) and 4007(1)(aa) of Schedule 4 to the Migration Regulations 1994 (the Regulations). It was made on 26 November 2025 and commences on 29 November 2025 (see ss 1-2). The instrument is made under the authority of those specific paragraphs in Schedule 4 to the Regulations (s 3).

Mechanically the instrument does four types of things:

• It defines key terms it uses, notably “high hepatitis B risk jurisdiction”, “panel physician” and “provisional visa” (s 4). “High hepatitis B risk jurisdiction” is defined negatively as any country or jurisdiction not listed in Schedule 5. “Panel physician” is defined by location (outside Australia) and by contractual/engagement status with the Department as part of the Australian Panel Physician Network (s 4).

• It specifies the classes of persons who must undertake a medical assessment for the purposes of paras 4005(1)(aa) and 4007(1)(aa). The classes are built from two triggers: (a) citizenship of a listed country or (b) having spent three or more consecutive months during the last five years in one or more listed countries (s 6). Schedule 1 contains the list of countries that trigger class 6(a)/(b). The instrument also contemplates persons who are covered by both triggers (s 6(c)).

• It prescribes, by reference to country of citizenship/long-stay and to visa type/duration/age, which medical examinations and laboratory/radiological tests apply. That prescription is set out in a tiered structure: Schedule 1 applies to the countries listed in its Column 1 and provides Columns 2-5 that specify the assessments by temporary stay length, by permanent and provisional visas, and by additional circumstances (Schedule 1 table, and s 7(a)). Schedule 2 covers all countries not in Schedule 1 and sets parallel assessments (Schedule 2 table and s 7(b)). Schedule 3 lists additional assessments tied to intended occupation or specific circumstances (e.g. health professional, childcare worker, pregnancy, aged 75+ visitor) (Schedule 3 and s 7(b)(ii)-(c)(ii)).

• It specifies who is authorised to conduct an assessment. For medical assessments conducted in Australia, Bupa Australia Health Pty Ltd (trading as Bupa Medical Visa Services) is named (s 8(a)). For assessments conducted outside Australia for visa purposes, “panel physicians” are specified (s 8(b)). The instrument includes a Note reminding readers that paras 4005(1)(aa) and 4007(1)(aa) of Schedule 4 to the Regulations require assessment by the person specified in the instrument unless a Medical Officer of the Commonwealth decides otherwise (s 8, Note).

Procedurally, the instrument replaces (repeals) the whole of the previous instrument titled Migration Regulations 1994 - Specification of Required Medical Assessment - IMMI 15/144 (Schedule 6, item 1). It also establishes a Schedule (Schedule 5) listing “low hepatitis B risk” countries; the definition of “high hepatitis B risk jurisdiction” is then every jurisdiction not in that list (s 4 and Schedule 5). The Schedules supply precise test lists: medical examination, chest X-ray, serum creatinine/eGFR, HIV test, hepatitis B test (conditional on place of birth), hepatitis C test, TB screening/latent TB screening, and specific combinations depending on age, visa type and intended work/education in health or childcare environments (Schedules 1-3; see s 7).

The instrument therefore operates as a detailed specification layer under the Regulations, tying applicants’ travel/citizenship history, intended visa class and occupation, and age to a discrete set of required medical procedures, and naming the entities authorised to perform them.

The instrument relies on a small set of interlocking concepts and mapping rules. The principal concepts are:

• Specified classes of person (s 6). A “class” is not a visa subclass but a category defined by citizenship and travel history. Paragraph 6(a) covers persons who are citizens of, or who have spent 3+ consecutive months in the last 5 years in, a country that appears in Column 1 of Schedule 1. Paragraph 6(b) covers people who are citizens of, or who have spent 3+ consecutive months in the last 5 years in, a country not listed in Schedule 1 (i.e. the complement set). Paragraph 6(c) covers persons who meet both criteria across different countries (for example, a person who is a citizen of a Schedule 1 country who also spent 3+ months in a non‑Schedule 1 country). The significance of these classes is that the medical assessments specified differ depending on whether the applicant falls into 6(a), 6(b) or 6(c) (see s 7).

• Specified medical assessments (s 7; Schedules 1-3). The instrument does not leave assessment content to free department policy; it prescribes particular clinical items. Core elements recurred throughout the Schedules are:

  • Medical examination (general clinical examination for visa medicals).
  • Chest X‑ray and TB screening or latent TB screening.
  • Serum creatinine/eGFR (renal function).
  • HIV test.
  • Hepatitis B test (required in some circumstances, often conditional on place of birth).
  • Hepatitis C test (required for certain health professional streams).
  • Additional items depending on age, visa length and intended occupation (see Schedule 3).

• High/low hepatitis B risk jurisdiction (s 4 and Schedule 5). The instrument separates jurisdictions into “low hepatitis B risk” (listed in Schedule 5) and implicitly “high hepatitis B risk” (any jurisdiction not in Schedule 5 per s 4 definition). That classification triggers hepatitis B testing obligations for some applicants over specific ages and visa classes (Schedules 1-2, Column 4 and Schedule 3 where applicable).

• Panel physician (s 4). A “panel physician” is defined as a doctor or radiologist who is outside Australia and who performs medical assessment services for visa applicants under the Migration Act and Regulations, and who either (i) has entered into and continues to be party to an arrangement with the Department as part of the Australian Panel Physician Network; or (ii) is employed or otherwise engaged by a clinic or other entity that has such an arrangement. That definition links who can perform overseas assessments to contract/arrangement status with the Department.

The instrument affects multiple categories of people and entities. The immediate legal targets are visa applicants; the instrument ties medical requirements to:

• Applicants by nationality and travel history: Section 6 specifies that an applicant is in scope if they are a citizen of, or have spent 3 or more consecutive months during the last 5 years in, a listed country in Schedule 1 (s 6(a)), or if they are a citizen of or have spent 3+ months in a country not listed in Schedule 1 (s 6(b)). In practice that construction sweeps in essentially all applicants because Schedule 1 lists a particular set of countries and Schedule 2 covers all others; s 6(c) addresses persons who fall within both categories for different countries. The “3 or more consecutive months in the last 5 years” trigger is a discrete documentary fact practitioners must establish when advising applicants.

• Applicants by visa type and stay duration: The medical requirements vary by whether the applicant seeks temporary stay up to six months, temporary stay of six months or more, permanent visa or provisional visa (Schedules 1-2). Schedule 4 lists which visa subclasses are treated as provisional visas for the purposes of Schedule 1 Column 4 (for example, Subclasses 160, 188, 300, 309 and 820 among others). In a practical sense applicants for visitor visas, partner visas, skilled regional provisional visas and certain business and investment provisional visas appear in Schedule 4.

• Applicants by age: The Schedules specify different sets of medical tests depending on age brackets: under 2, 2-10, 11-14, 15 and older, and 75 or older (Schedules 1-3). For example, Schedule 1 Column 4 prescribes no chest X‑ray for under 11s; chest X‑ray becomes mandatory from age 11 in many pathways; serum creatinine/eGFR and HIV/hepatitis tests are tied to the 15+ bracket for permanent/provisional applicants (Schedule 1 Column 4).

• Applicants by intended occupation or placement: Schedule 3 imposes additional medical assessments for persons intending to work or train as a doctor, dentist, nurse or paramedic (item 1); for other health care workers or people intending to work within a health care/hospital/aged care/disability care facility (item 2); for persons likely to work in an Australian childcare centre (item 3); and for persons likely to enter a health care or hospital environment (item 4). These items apply in addition to the baseline assessments that flow from country, duration and age.

• Pregnant applicants intending to give birth in Australia and older visitors: Schedule 3 item 5 requires a hepatitis B test for a person who is pregnant and intends to give birth in Australia, and item 6 requires a medical exam and serum creatinine/eGFR for an applicant aged at least 75 applying for a Subclass 600 visa.

The instrument creates prescriptive duties applicable to assessment routing and to who may perform assessments. It also leaves particular rights and discretions in other hands.

Duties set by the instrument

• Duty to undergo specified assessments if in a specified class: The instrument identifies classes of persons for the purposes of paras 4005(1)(aa) and 4007(1)(aa) of Schedule 4 to the Regulations (s 6). Subject to those paragraphs in the Regulations, an applicant in a class specified by the Minister must be assessed by the person specified in the instrument unless the Medical Officer of the Commonwealth decides otherwise (s 8 Note). The instrument therefore supplies the “which tests” element and (in s 8) the “who must do them” element.

• Duty to receive the prescribed tests: For each class the instrument prescribes tests mapped to age, visa type and duration. For example, Schedule 1 Column 4 requires for applicants aged 15 or older applying for permanent or provisional visas: medical examination, chest X‑ray, serum creatinine/eGFR, HIV test, hepatitis B test if born in a high hepatitis B risk jurisdiction, and any additional assessments specified in Column 5 of Schedule 1 (Schedule 1 Column 4). Those are mandatory as per the instrument’s specification.

• Duty on overseas doctors/radiologists to be part of approved arrangements to be specified panel physicians: Under the definition in s 4, a person outside Australia qualifies as a “panel physician” only if they are party to and continue to be party to an arrangement with the Department as part of the Australian Panel Physician Network, or are employed/engaged by a clinic/organisation that has such an arrangement. That creates a practical duty for overseas providers to hold the necessary contractual status to perform visa medicals for the Department.

• Duty to consider additional occupation-linked assessments: Schedule 3 identifies additional tests for people intending to work or train in specific health professions or settings, or in childcare. If an applicant indicates such an intention, those additional assessments apply on top of baseline testing.

Discretions and rights recognised or left intact

• Medical Officer of the Commonwealth discretion: The instrument expressly contemplates that the Medical Officer of the Commonwealth can decide that the person specified in the instrument need not be the assessor (s 8 Note). That is a statutory discretion that can alter who conducts the assessment in individual cases. The instrument does not further qualify or limit that discretion.

The instrument itself does not create criminal offences, monetary penalties or express administrative sanctions. It is a specification instrument that operates under the statutory framework set out in the Migration Regulations 1994 and the Migration Act 1958 (s 3). Its enforcement and the consequences of non‑compliance therefore depend on the parent legislative scheme rather than on provisions within this instrument.

What the instrument does say about enforcement and decision‑making:

• It is made under paras 4005(1)(aa) and 4007(1)(aa) of Schedule 4 to the Regulations (s 3). Those paragraphs in the Regulations (which are not reproduced in this instrument) are the legal basis for requiring applicants in classes specified by the Minister to be assessed by specified persons. The instrument therefore operates as the Minister’s written specification of classes, tests and specified persons under those paragraphs (see s 6-8).

• The Note at s 8 makes explicit that the statutory effect of paras 4005(1)(aa) and 4007(1)(aa) is that an applicant in a specified class must be assessed by the person specified in the instrument unless a Medical Officer of the Commonwealth decides otherwise (s 8 Note). That Note ties the instrument’s prescription to the decision‑making and enforcement mechanics of the Regulations.

• Absent from this instrument are express sanction clauses or procedural enforcement steps (for example, it does not state that non‑compliance will lead to visa refusal in this instrument). Any such consequence would be found in the Regulations or in the Migration Act. Practitioners must therefore consult those instruments for the remedial or coercive consequences of failing to undertake a required medical assessment.

Practical enforcement pathway (as a matter of administrative architecture, grounded on the instrument’s text)

• The Department specifies the medical requirements via this instrument (s 6-7), names who may conduct them (s 8), and maintains arrangements with Bupa and overseas panel physicians consistent with the definitions in s 4 and s 8. Where an applicant has not supplied the specified medical assessment, the parent regulatory framework governs whether the application is taken to be incomplete, refused, or delayed pending compliance. The instrument itself provides the content that decision‑makers will expect to see in applicants’ medicals.

• The Medical Officer of the Commonwealth retains discretion to direct exceptions to the “specified person” requirement (s 8 Note), which is an operational enforcement lever available to the Department.

The instrument is a subordinate legislative instrument made under the Migration Regulations 1994. Its interaction with other laws and instruments takes place primarily through that parentage and via the Department’s contractual arrangements.

Foundational interaction

• Made under the Regulations: The instrument states it is made under paragraphs 4005(1)(aa) and 4007(1)(aa) of Schedule 4 to the Migration Regulations 1994 (s 3). Those paragraphs provide the statutory power to require specified classes of applicants to be assessed by specified persons. Consequently, the instrument must be read as a specification under, and operating within, the Regulations’ framework. Any effect on visa eligibility, on how the medicals feed into visa decision‑making, or on sanctions for non‑compliance, is governed by the Regulations and the Migration Act 1958 rather than by the instrument itself.

Interaction with Department contracts and administrative arrangements

• Australian Panel Physician Network and contractual relations: The instrument’s “panel physician” concept ties persons outside Australia to the Department’s arrangements. That means the Department’s procurement, contract management and clinical engagement instruments (contracts, service level agreements, clinical guidelines) will determine the operational modalities for overseas medicals. The instrument’s effect is to condition who may be a specified person outside Australia on contractual status (s 4 and s 8(b)).

• Named Australian provider: By naming Bupa Australia Health Pty Ltd as the specified person to conduct assessments in Australia (s 8(a)), the instrument connects to whatever contractual relationship exists between the Department and Bupa. Those contracts and associated policies will specify reporting formats, appointment systems, fees and logistics. The instrument establishes legal specification; operational detail will be in the relevant contracts and administrative guidance.

Interaction with public health law and clinical regulation

• The instrument prescribes clinical tests and radiology (Schedules 1-3). It does not purport to alter public health powers in state/territory public health legislation, or to modify clinical regulation regimes that govern privacy, consent, pathology reporting and professional standards. Practitioners and providers must therefore manage compliance with health practitioner regulation, privacy law and public health obligations in performing the assessments, albeit the instrument prescribes which tests to undertake.

This instrument itself contains a limited, self‑contained amendment history. The instrument records its making on 26 November 2025 and its commencement on 29 November 2025 (ss 1-2). It is made under paras 4005(1)(aa) and 4007(1)(aa) of Schedule 4 to the Migration Regulations 1994 (s 3).

The only explicit amendment action recorded within the instrument is the repeal of an earlier specification instrument. Schedule 6 contains one item:

• Item 1 in Schedule 6: “The whole of the instrument Migration Regulations 1994 - Specification of Required Medical Assessment - IMMI 15/144 , Repeal the instrument.” That is an express and complete repeal of the earlier IMMI 15/144 specification instrument (Schedule 6).

Beyond that repeal, the instrument constructs a fresh set of Schedules (Schedules 1-5) and defines the relevant classes, assessments and specified persons. The Schedules themselves should be read as the operative replacement text for the instrument being repealed.

What is not present in the instrument

• There is no catalogue of prior amendments to the instrument itself because the instrument is framed as a new, stand‑alone specification (with an explicit repeal of IMMI 15/144). The instrument does not provide a legislative history beyond its own making and the repeal of the earlier instrument.

• The instrument does not include transitional provisions, grandfathering clauses or staged implementation rules beyond the commencement date (s 2). Practitioners should therefore assume the instrument’s provisions apply from 29 November 2025 unless a Departmental practice note or transitional rule says otherwise; any such transitional arrangements would be found in Departmental guidance or in the explanatory material accompanying the instrument, but they are not included in the text provided here.

Practical implication for practitioners

• Because the older instrument IMMI 15/144 is repealed in full (Schedule 6), advisers and providers will need to map any differences between the previous specification and the new Schedule 1-3 matrices to identify what has changed in required tests, country lists, and provider specifications. The instrument itself does not provide a change log; such comparison must be done by reading the prior instrument (IMMI 15/144) against the new Schedules.

The instrument as provided contains no litigation history. It is a legislative specification and does not record any court or tribunal challenges, nor does it cite any cases. The text makes no reference to judicial review outcomes, litigation by providers or applicants, or past determinations that bear on the interpretation of its provisions.

What practitioners should note about litigation risk and review avenues (grounded in the instrument’s role)

• Because the instrument is a specification under the Migration Regulations (s 3), decisions made under the Regulations that rely on medical assessments (for example, visa refusals or requirements to supply medical evidence) remain amenable to whatever merits and judicial review pathways the Migration Act and Regulations create. The instrument itself does not close off judicial review.

• The instrument recognises the Medical Officer of the Commonwealth’s discretion over who may be the assessor (s 8 Note). That is an administrative decision and is therefore theoretically reviewable where relevant grounds exist; whether a particular decision is reviewable in a merits review or judicial review forum depends on the statutory scheme in the Act and Regulations, which are not reproduced here.

• Any contest about whether a medical was properly conducted, whether the tests required were correctly specified for a particular applicant, whether a person qualified as a “panel physician” for the purposes of the Regulations, or whether Bupa was properly named as the specified Australian provider would require examination of the instrument in conjunction with the Regulations, the Migration Act and the Department’s contracting records. The instrument provides the normative criteria that would be used in such disputes, but the instrument itself records no pre‑existing litigation.

Recommendation for practitioners seeking litigatory history

• If you need to know whether this instrument or the way it is applied has been subject to litigation after commencement, search Federal Court, Federal Circuit and Family Court, Tribunal and Administrative Appeals Tribunal records and the relevant migration lists for cases involving medical assessment specification, panel physician practices, or Departmental naming of providers. The instrument text gives the legal criteria by which such litigation would be judged, but it contains no litigation narrative itself.

Several practical and legal pitfalls arise from the instrument’s drafting and structure. These are not evaluative judgments; they are operational or interpretive issues that arise from the text and that advisers should flag to clients.

1. Dual‑coverage rule and 6(c) mapping (critical routing effect)

• Section 6(c) covers persons who are “covered by both paragraphs 6(a) and (b)”. The consequence under s 7(c) is that a person covered by both will be assessed under the medical assessments specified in columns 2-4 of Schedule 2 and Schedule 3 (s 7(c)). That means a person who, for example, is a citizen of a Schedule 1 country but also has spent 3+ consecutive months in the last 5 years in a non‑Schedule 1 country will not be assessed under Schedule 1 but will instead be assessed using Schedule 2 plus Schedule 3. This routing is easily missed because a practitioner might assume Schedule 1 applies by virtue of one trigger; the instrument’s express 6(c) rule produces a different outcome.

2. “Born in” vs citizenship or travel for hepatitis B test triggers

• The hepatitis B test is required in particular circumstances only “if born in a high hepatitis B risk jurisdiction” (see Schedule 1 Column 4 and Schedule 2 Column 4). The instrument defines “high hepatitis B risk jurisdiction” negatively as any jurisdiction not in Schedule 5 (s 4 and Schedule 5). Consequence: an applicant’s place of birth (not their nationality or travel history) is the relevant fact for some hepatitis B test triggers. Advisers must therefore collect birthplace details separately from citizenship and travel history.

3. The effective breadth of “high hepatitis B risk jurisdiction”

• Schedule 5 is a substantial list of named low‑risk jurisdictions. All jurisdictions not listed in Schedule 5 are, by definition, “high hepatitis B risk” for the instrument’s purposes (s 4). Practitioners must therefore treat the absence of a jurisdiction from Schedule 5 as meaning the hepatitis B test may be required under the age/visa mapping. The negative definition creates an asymmetry: the explicit list is low risk, everything else is high risk.

4. Bupa as the sole named Australian provider

• Section 8(a) specifies Bupa Australia Health Pty Ltd as the specified person for in‑Australia assessments. That has immediate operational consequences: unless the Medical Officer of the Commonwealth decides otherwise (s 8 Note), assessments in Australia must be conducted by Bupa. Practitioners should not assume the Department will accept medicals done by other Australian providers, and should allow clients time to book with Bupa. The instrument does not supply any transitional arrangements for existing bookings or reports.

This section gives a practical compliance checklist and procedural steps, grounded on the instrument’s text and the Schedules. It assumes you are advising an applicant or administering a visa file and need to determine and procure the correct medical assessment and provider.

Step 1 , Gather the triggering facts (s 6; s 4)

• Establish citizenship. Is the applicant a citizen of any country? Record the country name verbatim as it will be matched to Schedule 1 Column 1 or will fall into Schedule 2 if absent.

• Establish travel history. Has the applicant spent 3 or more consecutive months during the last five years in any country or jurisdiction? You must document dates and the continuous nature of the stay (three consecutive months) and obtain supporting evidence (e.g. passports, entry/exit stamps, travel itineraries). The instrument uses this travel history as an independent trigger (s 6).

• Establish place of birth. For hepatitis B test triggers for 15+ applicants, the instrument conditions testing on whether the applicant was “born in a high hepatitis B risk jurisdiction” (Schedule 1 Column 4; Schedule 2 Column 4). Record place of birth exactly.

• Establish age. Different tests apply at under 2, 2-10, 11-14, 15+ and 75+ (Schedules 1-3). Confirm date of birth.

• Establish intended visa type and intended length of stay. Is the application for a provisional visa listed in Schedule 4, a permanent visa, or a temporary visa? For temporary visas, determine whether intended stay is likely to be up to 6 months or 6 months or more (Schedules 1-2). Special rules apply to Subclass 600 visitors and to provisional visas listed in Schedule 4 (s 4 and Schedule 4).

• Establish intended occupation, placement or pregnancy status. Does the applicant intend to work or study as a doctor, dentist, nurse, paramedic, health care worker, or to work in childcare, or to give birth in Australia? These intentions trigger Schedule 3 additional assessments (Schedule 3).

Step 2 , Identify which Schedule and columns apply (s 6-7; Schedules 1-3)

• If the applicant is a citizen of, or has spent 3+ consecutive months in the last five years in, a country listed in Schedule 1 Column 1, they fall within s 6(a) and Schedule 1 tests apply per s 7(a), unless they are also covered by s 6(b) which triggers s 7(c) treatments (see Step 3).