188C to 888: Can Historical COVID Overseas Days Count as Australian Residence?
Some existing 188C holders can count qualifying time outside Australia during the statutory concession period as time in Australia for subclass 888 Significant Investor residence calculations. This is not available to every holder. Clause 888.242 requires the relevant original Significant Investor subclass 188 grant to have occurred before 1 July 2019, together with the specified visa and overseas-period conditions.
Cancelled flights or general travel restrictions do not by themselves establish eligibility. The concession concerns historical periods; it does not generate new concession days for travel now. The BIIP has also closed to new applications.
Check the original grant, not another milestone
For the applicant's calculation under clause 888.242(2A), the Significant Investor subclass 188 must have been granted before 1 July 2019. An invitation, application or investment date is not a substitute. A grant on 1 July 2019 is not a grant before that date.
The person must also have held a subclass 188 Significant Investor or Significant Investor Extension visa during the relevant overseas period. An early original grant alone does not prove that every later overseas day qualifies. Put the original and extension notices alongside the travel history and check the periods of visa holding.
Use the statutory start and end dates
Regulation 1.15N starts the initial concession period on 1 February 2020. Instrument LIN 23/063 sets its end at 25 November 2023. The official explanatory statement confirms that this includes 25 November, ending at the end of that day.
Compare the statutory period with the actual overseas dates and the qualifying visa periods. Identify the overlap that satisfies all applicable conditions. Time overseas before the concession began, or travel after it ended, should not be added merely because a person also experienced pandemic-related difficulties.
A partner must meet the partner provision
Clause 888.242(4) addresses the spouse or de facto partner calculation. During the relevant overseas period, the partner must have held the specified subclass 188 granted on the basis of the applicant's Significant Investor or Significant Investor Extension holding. The applicant's Significant Investor subclass 188 must have been granted before 1 July 2019.
A partner's unrelated Australian visa is not automatically sufficient. Confirm the category, basis of grant and period of validity from the notices. The applicant and partner are separate residence routes; their actual and deemed days cannot simply be pooled into a household total.
Keep actual presence and deemed presence separate
Use one column for actual time in Australia and another for overseas time proposed to count under the concession. Link each period to movement records, the visa held and the provision relied upon. Do not count an actual Australian day again as an overseas concession day. Mark missing records or uncertain visa transitions for investigation before calculating a total.
Then apply the relevant applicant or partner residence formula, including the effect of any extension history. A reference to 40 or 180 days alone does not resolve the whole calculation. Investment, nomination and the remaining visa criteria still need their own review.
Before contacting 卓越移民 Premiervisa Group, gather the original grant, extensions and separate travel summaries for both partners. That allows the discussion to identify which historical periods have documentary and legal support. Keep the true dates, even where the resulting total is less convenient than expected.
Policy checked: 24 October 2026
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