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INZ says your job is not skilled - ANZSCO, skill levels and the substantial match test

When Immigration New Zealand says a job is not skilled, it is almost never judging the work: it is applying a classification. Every AEWV job check and every Skilled Migrant residence application is coded against ANZSCO, and the decision that matters is the substantial match test: whether the tasks you actually do comprise most of the occupation description for the code claimed. Disputed matches are the single biggest fight in the residence appeals the tribunal publishes, hitting retail managers, restaurant managers and chefs hardest. A losing code is rarely the end of the road, but the response has to engage the test INZ is actually applying.

Updated 29 September 2026

ANZSCO and skill levels at a glance

ANZSCO skill levels
1 to 5
SMC wage threshold from 9 March 2026
$35.00
SMC residence appeal deadline
42 days
What the skill level changes
SettingSkill level 1 to 3Skill level 4 to 5
AEWV advertising before the job checkAt least 14 days21 days, plus engagement with Work and Income
AEWV English requirementSkill level 3 roles from 1 June 2026; not levels 1 and 2Required
AEWV maximum continuous stayFive yearsThree years
SMC Points-based pathwayPaid the SMC wage threshold ($35.00 an hour)Paid 1.5 times the threshold ($52.50 an hour)
SMC Skilled Work Experience and Trades and Technician pathwaysAvailable (Trades and Technician for listed occupations only)Not available

Rates from 9 March 2026. The detail and the exceptions are in the sections below.

Find the parts of this guide that match your situation

Choose the answer that matches where the skill level question has come up, and the finder points you to the sections of this guide that deal with it. It does not assess your job or say what will happen.
Where has the skill level question come up?

For educational and illustrative purposes only. This is not immigration advice, and no warranty is given as to its appropriateness or accuracy. If in doubt, talk to an immigration adviser or an immigration lawyer about your specific circumstances.

What ANZSCO is and which version INZ uses

ANZSCO is the Australian and New Zealand Standard Classification of Occupations, a joint statistical classification that assigns every occupation a six-digit code and a skill level from 1 (most skilled) to 5, based on the qualification and experience the occupation commensurately requires. The statisticians have already moved on: Stats NZ released its replacement National Occupation List (NOL) in November 2024 and Australia released its own successor. INZ has not:

The classification INZ assesses against
WhereClassification
General ruleANZSCO version 1.2
Skilled Migrant Category applicationsANZSCO version 1.3
AEWV, for listed occupations onlyNOL occupations expressly listed in Appendix 20 of the operational manual

INZ says it will keep using ANZSCO until a full transition, with no confirmed date. NOL codes are not yet recognised for residence.

The substantial match test

The machinery is the same at both decision points: WA3.16.1 for the AEWV job check, SR2.1.1 for Skilled Migrant residence. The employment must be substantially consistent with the six-digit occupation description and with the tasks listed at the four-digit unit-group level, excluding tasks not relevant to the occupation, and:

“To be considered a substantial match to an occupation, the tasks relevant to the ANZSCO occupation description must comprise most of the applicant's role.”

INZ operational manual SR2.1.1 (effective 24 August 2026), read on immigration.govt.nz on 28 September 2026

Officers may also weigh:

  • The scope and scale of the employer's operation: the size of the business, the number of staff and managers, and whether management functions are centralised at a head office
  • The qualifications and experience required for the role
  • The pay offered

The scope-and-scale factor is where franchise and small-format retail managers lose: a store manager whose pricing, purchasing and staffing decisions sit with the franchisor or head office can be found not to be managing in the ANZSCO sense, however demanding the job.

What skill level changes on the AEWV

Since 10 March 2025 there is no median wage threshold for the AEWV: pay must be at or above the adult minimum wage and not less than the market rate for the occupation. What skill level still controls is almost everything else:

  • Advertising and MSD engagement. Jobs at ANZSCO (or listed NOL) skill level 1 to 3 need at least 14 days' advertising before the job check; level 4 to 5 jobs need 21 days plus engagement with Work and Income. Roles paying at least twice the median wage ($70.00 an hour from 9 March 2026) or on the Green List are exempt from advertising.
  • English. Applicants for level 4 to 5 roles must meet an English standard (IELTS 4.0 or equivalent), and from 1 June 2026 that requirement extends to skill level 3 roles, with a transitional exemption for existing AEWV holders whose visa expires on or before 1 December 2026 applying to use the balance of their stay.
  • Maximum stay and stand-down. Skill level 1 to 3 (including listed NOL occupations, Green List roles, and any role paid at least 1.5 times the median, $52.50 an hour) allows up to five years' continuous stay; level 4 to 5 allows three. At the end of the maximum stay the holder must spend 12 consecutive months outside New Zealand before a fresh AEWV.
  • The applicant threshold. Since 10 March 2025, two years' relevant experience (evidenced beyond your own CV) or a relevant Level 4+ qualification, waived for Green List roles or pay at twice the median.
  • Appendix 7 upgrades. Cooks, fitness instructors, scaffolders and slaughterers are treated as skill level 3 despite their ANZSCO level, and several plant-operator roles can be, where the employer sets level-3-equivalent requirements.

Skilled employment for residence since 24 August 2026

Since 24 August 2026 the Skilled Migrant Category has had three pathways. Under each sits a skilled employment requirement, and this is where the code bites:

Skilled employment and core requirements by pathway
PathwaySkilled employment must beOther core requirements
Points-basedANZSCO skill level 1 to 3 and paid the SMC wage threshold ($35.00 an hour from 9 March 2026), or skill level 4 to 5 or not in ANZSCO and paid 1.5 times it ($52.50)6 points from income, qualification or New Zealand registration, or one of those topped up by points for New Zealand skilled work experience
Skilled Work ExperienceANZSCO skill level 1 to 3 and paid 1.1 times the threshold ($38.50), or 1.2 times ($42.00) for Amber List occupationsAt least 5 years of directly relevant work experience, including 2 years of skilled work experience in New Zealand at the required pay
Trades and TechnicianANZSCO skill level 1 to 3, in an occupation on the Trades and Technician list (Appendix 23), and paid the thresholdA relevant level 4 or higher qualification and at least 4 years of directly relevant experience after it, including 18 months in New Zealand

Occupations on the Red List (Appendix 22) can use the Points-based pathway only. The pay rates in brackets are the 9 March 2026 figures from SR3.10.5.

On every pathway the job must also be full-time, genuine, permanent or at least a 12-month fixed term, and with an accredited employer. Officers apply the substantial match test against ANZSCO version 1.3, and may separately assess whether you are suitably qualified for the occupation: holding the qualification the code indicates, or the experience ANZSCO accepts in substitution (five years for a skill level 1 occupation, three for levels 2 and 3).

The occupations that get fought over

Disputed skill assessments are the single biggest theme in the residence appeals the Immigration and Protection Tribunal publishes: the tribunal's own index records "position not skilled" against nearly 1,500 decisions, with retail managers, store managers, restaurant managers and chefs the most-named occupations. Across 3,640 decided Skilled Migrant appeals in the published record, 48% were allowed, and the full appeal-rate analysis shows how sharply outcomes differ with representation.

Skilled migrant residence appeals, by who appeared for the appellant
Who appeared for the appellantSucceededDismissed or declinedDecided appealsSuccess share
A representative named in the decision1,3741,3992,77350%
The appellant represented themselves32545377842%

A correlation, not a measure of what representation does: professionals also turn weak cases away.

Computed by this site from the published decisions of the Immigration and Protection Tribunal and its predecessor boards in skilled migrant residence appeals. A decision counts as represented where it names a representative for the appellant, and as self-represented where it records that the appellant represented themselves; decisions that show neither are left out, as are withdrawn appeals and procedural rulings. The appeal success rates guide explains the method. Figures as at 20 September 2026, the date of the most recent decision file in the data.

The recurring patterns:

  • A franchise or small-store manager whose autonomy sits with head office (the scope-and-scale factor)
  • A café or restaurant manager in a quick-service format that INZ reads as a lower-skilled retail occupation
  • The chef-versus-cook boundary, where seniority and menu responsibility decide which side of the line the role falls, a fight the NOL's chef split now partly defuses for AEWV purposes
Where the disputed occupations sit on the lists in force from 24 August 2026
Occupation (ANZSCO 1.3)ListEffect for the Skilled Migrant Category
Retail Manager (General)Red List (Appendix 22)Points-based pathway only
Hospitality, Retail and Service Manager necRed List (Appendix 22)Points-based pathway only
Café or Restaurant ManagerAmber List (Appendix 21)Additional requirements on the Skilled Work Experience pathway
ChefAmber List (Appendix 21)Additional requirements on the Skilled Work Experience pathway

Both lists name other occupations too, such as hotel or motel managers on the Amber List and hairdressers on the Red List. INZ says the lists will be reviewed regularly.

AI-generated image of a chef's knife and freshly chopped vegetables on a wooden board on a stainless steel kitchen bench

What to do when INZ disagrees with your code

  1. PPI letterBefore INZ decides on the concern

    If INZ doubts the match mid-application, it must put the concern to you before deciding on it, in a PPI letter.

  2. Your response

    The response is where the case is won or lost: it has to answer the actual test, with evidence.

  3. Decision

    The routes after a decline depend on what was declined.

A disputed code, from concern to decision
  1. PPI letter
  2. Your response
  3. Decision
    If a Skilled Migrant residence application is declinedAppeal to the tribunal within 42 days

A response that engages the test usually includes:

  • A detailed statement of duties mapped against the unit-group tasks
  • An organisation chart showing what you control
  • An employer letter addressing scale and autonomy
  • Rosters or timesheets showing where the hours go
  • Evidence of the qualifications, experience and pay the role carries
The routes after a decline
What was declinedRouteTime limit
An AEWV job checkNo appeal. The employer can seek reconsideration, decided by a different officer for a fee, with no obligation to consider new information, so a fresh, better-evidenced job check is often the cleaner path14 calendar days for reconsideration
A temporary visaNo appeal to the tribunalNo appeal right
A Skilled Migrant residence applicationA full appeal to the Immigration and Protection Tribunal, on the grounds that the decision was wrong under the instructions or that your circumstances warrant an exception42 days

Check your understanding

These questions check what this guide says. They say nothing about your own case.

  1. 1. Which ANZSCO version does INZ use for Skilled Migrant Category applications?
  2. 2. What decides whether a job is a substantial match to an ANZSCO occupation?
  3. 3. Under the Points-based pathway, what must a skill level 4 or 5 job pay for Skilled Migrant residence?
  4. 4. Since 24 August 2026, which list is Retail Manager (General) on?
  5. 5. Can a declined AEWV job check be appealed to the tribunal?

For educational and illustrative purposes only. This is not immigration advice, and no warranty is given as to its appropriateness or accuracy. If in doubt, talk to an immigration adviser or an immigration lawyer about your specific circumstances.

Frequently asked questions

Version 1.2 as the general rule, version 1.3 for Skilled Migrant Category assessments, and the National Occupation List only for the occupations expressly listed in Appendix 20 of the operational manual, which are recognised for the AEWV only. INZ has said it will keep using ANZSCO until a full transition to the NOL, with no confirmed date.

No appeal right exists. The employer can request reconsideration within 14 calendar days of the decision, decided by a different officer for a fee, with no obligation to consider new information, or lodge a fresh job check with better evidence, which is often the cleaner route.

Not under the Skilled Migrant Category's Points-based pathway, which accepts employment in a skill level 4 or 5 occupation, or one not in ANZSCO at all, when it pays at least 1.5 times the SMC wage threshold, $52.50 an hour from 9 March 2026, against $35.00 for level 1 to 3 occupations. The Skilled Work Experience and Trades and Technician pathways added on 24 August 2026 need a skill level 1 to 3 role.

No. The median wage threshold was removed from the AEWV on 10 March 2025: pay must be at or above the adult minimum wage and not less than the market rate for the occupation. The median wage ($35.00 an hour from 9 March 2026) still drives other settings: the Green List rates, the $70.00 advertising exemption and the $52.50 five-year-stay and SMC thresholds.

INZ's test of whether your employment genuinely is the occupation claimed: the role must be substantially consistent with the six-digit ANZSCO description and the four-digit unit-group task list, with the relevant tasks comprising most of the role. Officers may weigh the employer's size and structure, the qualifications and experience required, and the pay. Job title alone counts for nothing.

Sources

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