Does 190 Skills Assessment Have to Exist Before Invitation in 2026?
No — a suitable skills assessment does not have to be in your hands before you are invited, but you do have to declare one at the moment of invitation. According to the Australian Department of Home Affairs' official Skilled Nominated visa (Subclass 190) page (as of the July 2026 official page), the requirement is split in two: for your application to be valid you must declare that you have a suitable skills assessment for your nominated skilled occupation at the time of invitation, and delegates of the Minister will now accept a suitable assessment that was obtained within the 60-day invitation period. In other words, the declaration is due at invitation; the document itself can be finalised during the 60 days you are given to lodge.
So what is actually required at the moment of invitation?
The invitation itself is triggered by your Expression of Interest (EOI) in SkillSelect. You submit an EOI, state and territory government agencies can see it, and one of them may nominate you — the Department only invites applicants who have been nominated by a state or territory agency.
At the point of invitation, the official page sets these timing-sensitive requirements:
- You must declare that you have a suitable skills assessment at the time of invitation.
- You must be under 45 when you are invited (turning 45 after the invitation is fine; turning 45 after the EOI but before the invitation means you will not be invited).
- You must have at least competent English at the time of invitation.
- Your EOI must reach the 65-point threshold, and your invitation will state the score you must actually prove when the application is assessed.
The 60-day flexibility applies only to the skills assessment document — not to age, English, or points.
What is the 60-day window, and where does it come from?
Once you are invited, you have 60 calendar days to apply, and the page states clearly that this time cannot be extended. The same 60 days is the window in which a newly obtained skills assessment will be accepted.
This approach comes from the decision in Thapa v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2021] FCCA 686 (Thapa). The Department's stated position is that it will administer the Migration Regulations 1994 in accordance with Thapa — while expressly reserving the right to argue in a court that Thapa was wrongly decided. That reservation matters for planning: this is an administrative approach following a court decision, not a fixed date rule written into the visa criteria, so the most current wording on the official page should always be treated as the authority.
Can you simply wait for the invitation before starting?
The 60-day window is not a reason to sit still, and the official page gives you several reasons to treat it as a buffer rather than a plan.
First, the clock is short and non-extendable, and it is the same clock you need for everything else in the application: identity documents, police certificates, relationship and dependant documents, and evidence for every claim you made in your EOI. An assessment body that takes longer than your 60 days leaves you unable to lodge, and the invitation simply lapses.
Second, a state or territory agency decides whether to nominate you using its own criteria, and the Department's page states that each agency sets its own requirements for who it will nominate. Having an assessment in progress — or already in hand — is an ordinary part of making an EOI competitive, and nothing on the official page suggests you should hold back.
Third, the risk of an unused invitation is real. The page notes that if you do not apply after two invitations, your EOI will be removed from SkillSelect.
What timing rules still apply to the assessment itself?
The 60-day concession does not replace the currency rules. The official page also states:
- Your skills assessment must have been obtained in the 3 years before the date of your invitation. If the assessment was issued for a shorter period, that period must not have passed.
- If your skills were assessed on the basis of a qualification you obtained in Australia while you held a student visa, that qualification must come from a course registered on CRICOS.
- You must provide a copy of the skills assessment with your application — the document is still a lodgement requirement, not something you can add later at the Department's invitation.
Because the page states both the 3-year rule and the 60-day acceptance, read them together and check the current official wording before relying on a marginal case.
Doctors and lawyers have parallel options instead of a standard assessment: full, unconditional or general registration with the Australian Health Practitioner Regulation Agency (AHPRA), or conditional specialist registration that lets you practise in your specialty with no further training or supervision; for legal practitioners, admission to practice law in the relevant state or territory. For these groups the registration or admission must be in place at the time you are invited.
How this plays out in practice
Assume an applicant submits an EOI in SkillSelect with a complete set of claims, is nominated by a state agency, and receives an invitation on a given date with 60 calendar days to lodge. Under the current approach, that applicant can declare the suitable assessment at invitation, then finalise and obtain it during the 60 days and attach it to the application. If the assessment body takes longer than 60 days, the applicant cannot lodge a valid application within the deadline, and the invitation expires.
Assume instead an applicant who already holds an assessment issued more than three years before the invitation date. The 60-day window does not revive that document; the assessment needs to fall within the currency rule the page sets out.
This article is general information, not personalised migration advice, and the Thapa approach is administered policy that the Department has said it may contest in court — so confirm your own timing against the current official page or a qualified professional before you act on it.
Frequently Asked Questions
Do I need a skills assessment before I submit my EOI?
The official page ties the declaration to the time of invitation, not to the time you submit your EOI, and it says nothing about an assessment being required to create an EOI. Submitting an EOI is free and is not a visa application.
Do I need the skills assessment in hand on the day I receive the invitation?
No. You must declare at the time of invitation that you have a suitable skills assessment, and delegates will accept a suitable assessment obtained within the 60-day invitation period. You then need to provide a copy of it with your application.
Can the 60-day deadline be extended if my assessment is delayed?
No. The page states you have 60 calendar days from the date of your invitation to apply and that this time cannot be extended. A delayed assessment that runs past day 60 leaves you unable to lodge on that invitation.
Does the 3-year validity rule still apply if I use the 60-day window?
The page states both rules: an assessment obtained within the 60-day invitation period is accepted, and the assessment must have been obtained in the 3 years before the date of your invitation (or, if issued for a shorter period, that period must not have passed). The two should be read together against the current official wording.
Does this flexibility apply to doctors and lawyers?
Partly differently. Medical practitioners can rely on AHPRA registration (including certain conditional specialist registration) and legal practitioners on admission to practice, but for these groups the registration or admission must already be in place at the time you are invited rather than obtained during the 60 days.
Is the Thapa approach permanent?
The Department says it administers the Migration Regulations 1994 in accordance with Thapa, but explicitly reserves the right to argue in a court that Thapa was wrongly decided. Treat it as current administrative practice and check the latest official page.