This proposal advocates for raising the current age limit for onshore applicants from 45 to 55 years, reflecting a more equitable and forward-looking approach to Australia’s skilled migration framework.
The attached reform paper outlines a comprehensive case for this change, supported by:
- Comparative analyses with international migration systems;
- Legislative review and context within the Migration Regulations 1994 (Cth); and
- Empirical evidence demonstrating the significant economic and social contributions of mature-age workers.
At the heart of this proposal lies a belief that age should not be a barrier to opportunity for skilled professionals who continue to make vital contributions to Australia’s workforce and communities. By broadening the age eligibility criteria, Australia can strengthen its talent retention, address critical skill shortages, and reinforce its reputation as a destination that values merit, experience, and diversity.
This policy paper was developed by Rehman Sheriff Group (RSG) as part of its ongoing migration research initiatives, with contributions from Victoria University interns — Antonio Fernandez, Jessica Bogdanovska, Betelihem (Betty) Brhane, Rose Buenaventura, Gardenia Alquozy, and Josephine Jarjis — who participated through RSG’s internship program under the supervision of Flora Dinh and Farhan Rehman.
Their collaborative research reflects RSG’s commitment to nurturing future migration and policy professionals and promoting evidence-based policy dialogue within the migration sector.
We invite stakeholders, policymakers, and the wider community to support this important reform initiative, ensuring that Australia’s migration system remains fair, inclusive, and responsive to the evolving nature of work and demographic change.
EXECUTIVE SUMMARY
Australia’s 186 Employer Nomination Scheme visa unfairly excludes skilled workers over 44, preventing experienced migrants from contributing to the economy. This proposal advocates raising the age limit to 55, unlocking a talent pool ready to address critical skills shortages. Other countries, including New Zealand, Canada, and the United Kingdom, demonstrate that flexible age policies retain expertise without compromising workforce planning. Reforming this cap promotes fairness, strengthens industries, and helps Australia remain competitive and inclusive in the global talent market.
INTRODUCTION
This proposal aims to address an ongoing issue in Australia’s migration system, primarily affecting the ability of older immigrants to apply for permanent residency as skilled workers. This arises from the restrictions imposed on the subclass 186 Employer Nomination Scheme (186 ENS). Currently, the enforcement of the 186 ENS has set strict age caps, preventing any skilled worker over the age of 44 from being eligible. Such limitations overlook the valuable expertise and experience that older skilled migrants can bring to Australia’s workforce. Therefore, we submit this proposal to gather support for law reform and to promote fairness within our system. This aims not only to improve the quality of life for older migrants but also to encourage further economic contributions.
By examining comparative international approaches, domestic workforce statistics, and case studies of individuals impacted by this restriction, we demonstrate that Australia is currently overlooking a highly skilled talent pool that is eager and qualified to contribute. This report outlines potential policy reforms and future strategies to address these gaps, fostering a more inclusive and efficient skilled migration framework.
Therefore, this document will guide the reader through the complexities and statistics that support our stance and explain why law reform is necessary. We respectfully request that you take the time to consider our reasoning and support us in implementing this important change.
OBJECTIVE
As law interns at the Rehman Sheriff Group (RSG) and students at Victoria University (VU), we are advocating for a reform that we believe will strengthen Australia’s migration system. We aim to raise the age limit for the 186 ENS visa, from 44 to 55 years of age enabling qualified individuals with the necessary skills and experience to be eligible to apply. Our proposal outlines practical steps to implement this change. We strive to foster more open discussions about the contributions of migrants in Australia regardless of age to prove their benefit to the economy, as well as contributions to the rich cultural landscape and social cohesion that promotes Australian democratic values.
BACKGROUND
The 186 ENS enables skilled workers nominated by an Australian employer to gain permanent residency. This visa comprises three streams, each tailored to different circumstances based on the applicant’s specific needs. Regardless of whether the applicant has already lived and worked in Australia or is a new applicant, in both situations, the visa provides a pathway to permanent residency and, if eligible, eventual Australian citizenship.
However, a disadvantage of this visa is the requirement that the applicant must be 44 years of age or younger at the time of application. This is the substance of our proposal, and we aim to increase this age limit to allow skilled workers, who are beyond this current age cap, the opportunity to continue to make significant contributions to our economy.
Migrants comprise more than one in four workers, holding 26.3 per cent of all jobs in Australia in 2019-20. Approximately 3.6 million to 5.3 million jobs are held by migrants daily, indicating that migrants make a significant contribution to the Australian economy. Additionally, 59 per cent of permanent migrants hold skilled visas in various working industries within Australia.
The 186 ENS has seen considerable demand through increased grants among other permanent visa schemes. In comparison with approximately 20,000 grants for the skilled nominated visa and less than 10,000 grants for business innovation and investment visas in the 2023-24 financial year, employer-nominated visas, such as the 186 ENS, received around 30,000 applications.2 This proves a greater need for the 186 ENS to be further accessible in its full extent, and the current age restriction is a prominent issue that requires attention within the area of migration law. Therefore, a proposal to amend this restriction is imperative to combat this ongoing issue and ultimately make a change that will benefit our older migrants seeking a better life as well as create further economic contributions.
PROPOSED LEGISLATIVE CHANGES
We aim to raise the age limit for the 186 ENS from 44 years to 55 years, reflecting increased life expectancy and the ongoing contribution of older workers to the workforce. While some may argue that age restrictions are reasonable for the Direct Entry and Labour Agreement streams for offshore applicants, as they have not yet demonstrated integration into the Australian labour market, these restrictions are less justifiable for onshore applicants, particularly under the Temporary Residence Transition (TRT) stream.
Applicants applying onshore have already demonstrated their work ethic in their nominated occupation for at least two years whilst being sponsored by the same Australian employer. They have also shown loyalty and employability. Extending the age limit for this group would allow Australia to retain experienced talents and maximise economic contributions, without undermining broader immigration planning considerations.
Increasing the age requirement would encourage highly skilled and experienced migrants 45 years and older, who make positive contributions to Australian society, to apply for permanent residency. Individuals who fall within this age demographic typically possess specialised skills and knowledge in their fields, extensive professional experience, and leadership potential, all of which can significantly benefit various industries across Australia.
Furthermore, the current scheme prevents employers from sourcing intentional talent solely due to this restriction. This creates risks for businesses, as they are unable to secure the necessary and relevant employees for specific industries. Employers can maintain continuity, enhance their organisational capabilities, and invest further in skilled workers. The eligibility for the 186 ENS visa should focus on maximising skills through higher contributions to economic growth. By assessing educational background, employment history, current skill set, and personal circumstances, the Minister of Immigration will identify workers who have the potential to make significant contributions to Australian society. This change promotes a more inclusive and efficient migration system by ensuring fairness and guaranteeing that visa allocation is based on merit rather than an arbitrary numerical cap.
RATIONALE FOR REFORM
The current framework for the 186 ENS visa requires applicants to be under 45 years old at the time of application, with limited exceptions for certain high-income earners, academic or scientific specialists, and regional medical practitioners. In Australia, the age pension requirement is 67 years old at the least, amongst other eligibility criteria.3 Yet migrant workers are restricted in comparison with their peers through this age restriction policy. Particularly, the 45-54 age group is the second most represented in the labour force of permanent migrants (78.9%) with only a 1.8 per cent difference with the 35-44 age group. While aimed at prioritising younger migrants with longer potential workforce participation, the restriction imposed is negatively affecting the older, more skilled migrants, and, in turn, resulting in age discrimination by excluding highly skilled and experienced individuals solely based on their age. This is contrary to analysing an individual based solely on their skills; it overlooks their qualifications, economic contributions, and ongoing employability and stands against the ethos of the national Age Discrimination Act that specifically grants an exception for matters of immigration.5 Hence, we must examine it from a different perspective and advocate for reform.
In practice, this rule narrows the scope and depth of Australia’s skilled migrant workforce, preventing employers from retaining or sponsoring exceptionally skilled individuals who are 45 years and older. In recent history, there was another proposed change from the Australian Government in 2012 to increase the ‘upper age limit’ from 45 to 50 years old as part of reforming the Permanent Employer-Sponsored Visa Program, the predecessor of the current 186 ENS but it only applied as exceptions for certain applicants on set eligibility. Without any exceptions, the age cap for visa streams such as the 186 ENS remains at 44 years old to this day despite proven evidence of older migrants having the necessary knowledge and skills to be productive workers. Thus, we are requesting changes be implemented and provide skilled migrants with the opportunity to showcase their work ethic and relevant skills as proven with comparisons from other developed countries that benefit from the productivity brought by older migrant workers.
COMPARATIVE ANALYSIS
International Approaches to Skilled Migration Age Limits
Different countries take varied approaches to age restrictions in skilled migration programs, often striking a balance between demographic needs, labour shortages, and long-term settlement goals. While Australia has an age limit of 44 years for most skilled permanent entry visas, comparable systems overseas demonstrate greater flexibility. There are higher age thresholds, points-based adjustments, or exemptions that prioritise skill over age. Examining these international models provides valuable insights into how Australia might reform its own framework to align migration policy with workforce realities better.
Canada
Canada adopts a points-based system under the Express Entry framework known as the ‘Comprehensive Ranking System’ (CRS). It assesses an applicant’s age, education, language ability, Canadian work experience, and other factors.7 This assessment is then used to rank candidates in the Express Entry pool.
There is no age limit in this model, however age does heavily influence point allocation under the CRS. Maximum points are given to those aged 20 – 29 with points decreasing with age increases, leaving those aged 45 and over to receive zero age-based points.8 Nevertheless, applicants can compensate with strengths in education, language proficiency, or work experience. Therefore, Canada’s system allows older skilled migrants to apply with strong non-age credentials, prioritising the country’s economic growth and evolving skills needs. By contrast, the current Australian policy bars many applicants outright, regardless of their skills or employer support.
United Kingdom
The United Kingdom similarly employs a points-based immigration system without a hard older age limit. The Skilled Worker visa is open to individuals who attain 70 points by meeting specific requirements such as skill and salary level, English language ability, and work for a UK employer that has been approved by the Home Office.10 The Skilled Worker route focuses on job offers, salary thresholds, and skill level. The UK’s more inclusive age policy offers flexibility, noticeably absent in an Australian context.
New Zealand
The process for obtaining a Skilled Migrant visa in New Zealand is interesting as it employs an age limit, but also utilises a points–based system. There is an age requirement in place, providing that a person must be under the age of 56 in order to apply for the visa. This is a highly relevant comparison as it aligns with our intention to change the age cap from 45 to 55 in the current Australian framework. New Zealand’s more lenient policy is ideal, allowing older applicants to qualify depending on their aggregate score across multiple factors. This higher threshold reflects a recognition that workers 45 years and older remain productive and valuable contributors, aligning more closely with Australia’s current workforce participation realities.
Lessons for Australia
Considering the different jurisdictions mentioned above, international policies with greater flexibility recognise the long-term value of mature workers and adopt policies that balance demographic challenges with labour market demands. By maintaining a rigid 44-year age limit, Australia falls behind comparable migration systems that embrace a more inclusive and economically responsive approach. This is supported by further evidence from domestic statistical findings and various employment studies.
EVIDENCE OF MATURE AGE WORKFORCE CONTRIBUTIONS
Data from the Australian Bureau of Statistics and Jobs and Skills Australia highlights the strong attachment of mature age workers to the labour market, emphasising the need for reform. With an employment-to-population ratio of 80.5% and a participation rate of 86% in July 2025, the vast majority of people in the 45 – 54 age range are either working or actively looking for work.12 The Labour Force Total for this cohort stood at 2,867,623 people, with
2,786,600 employed.13
Similarly, employees aged 55 and older have proven to be remarkably reliable. In June 2024, their unemployment rate was 2.8%, compared to 4.3% for those aged 15 – 54.14 Their continued engagement is further reflected in the 69.6% participation rate for people aged 55 – 64.15 The data suggests continued labour market attachment, reliability, and productivity among mature age workers.
Beyond the statistics, employers have reported that mature age workers were valued for their experience, reliability, positive attitude, strong work ethic, qualifications, and skills.16 All things considered, this data underscores the necessity of raising the 186 ENS visa’s age limit to match labour market reality with migration policy better and avoid arbitrarily excluding talented workers. There must be considerations of the repercussions of the age restriction policy in the 186 ENS that must be highlighted not only in the area immigration law but also in wider socio-political and socioeconomic contexts.
STAKEHOLDER IMPACT
Migrants
Raising the age limit can allow skilled migrants aged 45-55 to access opportunities currently denied to them, despite their proven experience and productivity. This change will reduce the exclusion of mature workers from pathways to permanent residency, thereby promoting fairness and equality. It will also prevent underutilisation of their expertise and qualifications in the Australian labour market.
Economy and Workforce
The broader Australian economy will gain from the reform through higher workforce participation, productivity, and knowledge sharing. Increasing the pool of eligible migrants encourages sustainable growth and reduces pressure on industries facing ongoing skills gaps. The older migrants who secure permanent residency are more likely to make long term contributions through taxes, community engagement, and support of Australia’s social and cultural diversity.
IMPLEMENTING THE CHANGE
To implement this change, we aim to maximise our reach across multiple social media platforms. We will also build connections within the community to gather support and collaborate with various government and non-government organisations. We aim to create a petition that will enable other individuals to have an input without typically having an associated background in law or the migration framework.
In particular, we will begin by engaging with advocacy groups focused on migrant communities and industry representatives who can provide valuable opinions on this issue. Through these collaborations, we can raise public awareness about community ideas supporting the reforms and highlight a positive outlook on older migrants by emphasising their valuable assets and contributions. Community members could also be encouraged to
contact their Members of Parliament to strengthen the proposal.
We intend to submit our proposal to the Department of Home Affairs, which we hope will be assigned to the cabinet’s agenda during their next session. This reform can be carried out successfully if the minister for immigration presents this issue to other Cabinet members. Meanwhile, we plan to involve Parliament in our efforts to advance reform through amendments to existing migration laws.
A primary suggestion is a bill which amends the Migration Regulations 1994 (Cth), particularly the sections within Volume 2 that specify the age limit of 44 years for the eligibility criteria of the three streams of the 186 visas:
- Section 186.221(a).
- Section 186.231(a); and
- Section 186.241(a).
This would be successful if the Migrations Regulations are to be amended and receive royal assent. Age increase can be effectively implemented on 186 visas, which satisfies our objective, not only for migrant workers but also the broader Australian workforce, positively impacting both the economy and society.
BENEFITS & CHALLENGES
Benefits
Expand the talent pool: By raising the age limit, firms can employ highly qualified and experienced workers who might not otherwise be able to work, helping to retain talent and effectively address labour shortages.
Economic contribution: Older migrants bring extensive experience, leadership, and knowledge transfer, enhancing industries, regional economies, and organisational capacity across Australia.
Promotes fairness: By eliminating direct age discrimination, the reform ensures visa decisions are based on merit, considering qualifications, talents, and potential contributions rather than arbitrary age limitations.
Challenges
Policy resistance: Some argue that younger migrants contribute to longer workforce participation, which could face political or administrative pushback (delay changes or prevent changes). However, the younger workforce does not possess decades of expertise in particular industries.
Implementation costs: Employers in the Department of Home Affairs may need to make small operational or administrative changes to include older candidates gradually. As with these visas, there are often high costs involved. Though with any visa, there are fees that are to be paid regardless of age.
CASE STUDIES
Individual stories impact by Age limits
Australia is currently facing significant challenges in its skilled migration program due to the strict age restriction imposed on permanent residency visas. As stated previously, under the subclass 186 ENS visa, applicants must be under the age of 45, regardless of their experience or contribution to the workforce. This policy excludes a wide pool of skilled and experienced workers many of whom are already in Australia filling critical shortages in sectors such as aged care, healthcare, teaching, and construction. As a result of this, Australia risks losing valuable workers, the age limit not only undermines workforce planning but also creates unfair barriers for individuals who have invested years of service in Australia yet are denied a pathway to permanency purely because of their age.
The harsh reality of Australia’s restrictive age limit policy is better illustrated through the ABC News (2023) case experience of Ozioma Onyekwere, a 57-year-old aged care worker in Queensland. Despite having lived in Australia for eight years and holding a master’s degree alongside qualifications in early childhood and disability support, Ms Onyekwere is ineligible for permanent residency under the 186 ENS visa because she is over 45. Her story is not one of a temporary worker passing through Australia, it is one of a dedicated, long-term contributor to a sector that is under severe strain. Aged care providers themselves acknowledge the urgent need for experienced staff, yet the current visa framework systematically excludes individuals like Ms Onyekwere, depriving the nation of precisely the skills it claims to need.17 This case demonstrates the structural problem at the heart of the age restrictions: it does not assess works on their merit, contribution, or the needs of the community, but instead imposes an inflexible age gap. The result is a policy that punishes loyalty and experience. It forces out highly skilled professionals who have already proven their value to Australian society, while employers are left scrambling to fill chronic labour shortages. In this way, the age cap is more than a regulatory barrier it is a systemic obstacle that undermines Australia’s economic and social goals by driving away those who are willing and able to contribute.
The courts have previously recognised the injustice of arbitrary age exclusions in employment. In ABCC v CoreStaff WA Pty Ltd [2020] FCA 893, a 70-year-old applicant was unlawfully discriminated against purely due to age. This case highlights that skills, experience, and capacity to work should outweigh chronological age. Yet, the 186 ENS visa replicates this discrimination systemically by cutting off all applicants at 44, regardless of merit or contribution. This gap shows how migration law embeds age bias that the courts have explicitly condemned in other contexts. Skilled migrants are denied opportunities, leaving Australia to miss out on the very expertise and leadership it most needs.
The Gutierrez v MUR Shipping Australia Pty Ltd (No 2) [2023] FCA 567 case further illustrates the harm of age assumptions. The Federal Court awarded damages where an employee was unfairly assumed to be approaching retirement due to age. This ruling emphasises that stereotyping older workers is unjust and costly. The 186 ENS visas, however, institutionalises precisely this type of assumption: anyone over 45 is considered ineligible irrespective of their ongoing capacity to contribute. This systemic restriction reveals a profound gap between Australia’s domestic protections against age discrimination and its migration policy, leaving a segment of the workforce excluded purely because of age rather than ability.
Finally, the High Court in Qantas Airways Ltd v Christie [1998] HCA 18 confirmed that age-based exclusion is only justifiable where age is genuinely inherent to the role. The decision demonstrates that broad age limits are rarely necessary. Yet, the 186 ENS visa enforces a sweeping, indiscriminate cut-off, failing to evaluate whether age genuinely affects employability. This creates a systemic barrier: highly skilled migrants, particularly in critical sectors like healthcare and education, are excluded without consideration of their actual ability to perform. The visa’s age restriction exposes a structural flaw: a policy that blocks contribution and experience based on arbitrary numbers rather than genuine occupational needs.
These examples collectively illustrate the systemic gap caused by the 186 ENS visa’s age restriction. By prioritising age over merit, Australia excludes skilled, experienced, and loyal workers now they could make significant contributions. The policy contradicts anti-discrimination principles recognised in domestic law, perpetuates labour shortages, and undervalues proven expertise. Reforming the age limit is essential not just for fairness, but to align migration policy with economic, social, and ethical priorities, ensuring that Australia can retain the talent it needs while upholding principles of equity and inclusion.
LEGISLATIVE AND POLICY FINDINGS
To ensure Australia’s skilled migration framework remains competitive and inclusive, this proposal recommends increasing the age restrictions for the 186 ENS (TRT) from 44 to 55 years. These reforms recognise that experience, stability, and professional maturity are invaluable assets in Australia that would align its migration policy with the realities of an ageing population and a growing need for experienced professionals in critical industries as
valuable.
The Australian Human Rights Commission’s Willing to Work report (2016) makes it abundantly clear that older Australians face systemic discrimination in employment. Employers are hesitant to hire them, citing fears about reduced productivity and increased costs. These bases have contributed to persistent underemployment among older workers, despite their proven expertise and reliability. Expanding the age limit for skilled migration could serve as complementary policy measures to counteract this imbalance. It would not only recognise the economic and social value for older workers but also promote a diverse labour market.
Exceptions to discrimination laws exist for procedural reasons such as enabling the Ministry for Immigration to establish the age restriction for the 186 ENS. Legal scholars reflect broader government priorities that can inadvertently disadvantage older workers. Such policies contribute to higher retirement ages, stricter access to pensions and superannuation, and workplace practices that often prioritise younger employees over their older counterparts. Adjusting the migration age threshold would not conflict with the principles of equality. Rather, it would extend opportunities more fairly to those excluded by arbitrary limits, advancing the border intent of anti-discrimination law to ensure equitable access to work for all qualified individuals, regardless of age.
There are other economic factors alongside labour outputs that relate to older aged skilled migrants. European-based studies have identified that older migrants contribute to economic growth through increased disposable income, which benefits other parts of the economy via active consumer practices such as tourism. This is influenced by their more stabilised personal lives, in comparison to younger migrants who are still establishing themselves, and higher earnings as a reward for their specialised, high-quality expertise and skillsets. Australia could experience similar benefits if the socioeconomic culture towards older migrants shifts towards a more open and accommodating approach.
This ongoing issue also prompted debate in 2013, when the Australian Law Reform Commission conducted an inquiry into the legal barriers faced by older persons in the workforce. The inquiry highlighted the challenges associated with an ageing population and emphasised the need to expand workforce participation among older individuals.24 Despite this, there remains no clear definition of ‘older persons’ as being 45 years or above. It is evident that this issue must be addressed to enable the ageing population to contribute meaningfully to the workforce while also removing the legal barriers that continue to persist.
Therefore, raising the age limit is a legislative adjustment that aligns with Australia’s broader anti-discrimination framework, supports equitable workforce participation, and strengthens the economic and social contributions of older migrants.
CONCLUSION
This report has demonstrated that the current age limit of 44 years for the 186 ENS visa under the Migration Act 1958 (Cth) is an outdated barrier that undermines Australia’s capacity to attract and retain highly skilled workers. Through case studies, we have shown the real-world human and economic costs of this restriction. Our comparative analysis with Canada, the United Kingdom, and New Zealand highlights that Australia is held behind its peers in adopting inclusive migration policies. Legislative and policy findings further confirm that the rationale for the age cap no longer aligns with modern workforce needs, where experience and skills are valued as much as youth.
Accordingly, we recommend reform to raise the age limit from 44 to 55 years old, ensuring that Australia can remain competitive in the global talent market while promoting fairness and opportunity for all skilled migrants. Removing this barrier is not economically sound, but also consistent with Australia’s vision of a progressive, inclusive society.
By endorsing this change, the migration system can promote age equity, address critical skills shortages, and ensure that talented immigrants are recognised and valued, rather than being denied the opportunity to apply due to age.
Thus, we invite you to co-sign this initiative and help bring about meaningful change that recognises the value of skilled migrants, regardless of their age. Your expertise and support are essential in driving this important shift. Moreover, raising the age limit for the 186 ENS to 55 will promote fairness for older migrants with relevant qualifications, strengthen Australian industries, and address critical workforce shortages with their skills.
Ultimately, Australia cannot afford to let arbitrary age restrictions prevent it from harnessing the talent, innovation, and dedication of skilled workers who are eager to contribute. Progress cannot be capped, Australia’s future demands nothing less.
BIBLIOGRAPHY
A Articles/Books/Reports
Australian Human Rights Commission, Willing to Work: National Inquiry into Employment Discrimination Against Older Australians and Australians with Disability (Report, May 2016)
Australian Law Reform Commission, Access All Ages—Older Workers and Commonwealth Laws (Final Report, 21 March 2013)
Australian Law Reform Commission, Grey Areas: Age Barriers to Work in Commonwealth Laws, ALRC Discussion Paper No 78 (2012)
Australian Law Reform Commission, Grey Areas—Age Barriers to Work in Commonwealth Laws (IP41) (Report, April 2012)
Blackham, Alysia, Exceptions to Age Discrimination Law (Melbourne Law School Legal Studies Research Paper No 4, 2016)
Cebulla, Andreas and George Tan, ‘When what you have is not enough—Acquiring Australian qualifications to overcome non-recognition of overseas skills’ (2022) 61(3) International Migration 175
Grattan Institute, Migrants in the Australian workforce: A guidebook for policy makers, (Report, May 2022)
Parr, Nick and Ross Guest, ‘Migrant Age Profiles and Long‐Run Living Standards in Australia’ (2020) 53(2) Australian Economic Review 265
Warnes, Antony M., et al., ‘The diversity and welfare of older migrants in Europe’ (2004) 24(3) Ageing and Society 307
B Cases
ABCC v CoreStaff WA Pty Ltd [2020] FCA 893
Gutierrez v MUR Shipping Australia Pty Ltd (No 2) [2023] FCA 567
Qantas Airways Ltd v Christie [1998] HCA 18; (1998) 193 CLR 280
C Legislation
Age Discrimination Act 2004 (Cth)
Migration Act 1958 (Cth)
Migration Regulations 1994 (Cth)
