Immigration New Zealand has announced significant changes to the requirements for approved managed funds and direct investments under the Active Investor Plus (AIP) visa programme. The changes are designed to improve the quality and oversight of managed funds and direct investments.
The changes introduce new deployment requirements, broaden Invest NZ’s powers to decline, suspend or revoke managed funds and direct investments, and create a new “growth asset” test that will apply across the programme.
The amendments take effect on 28 September 2026. New applications to be recognised under the AIP programme are suspended until that time, to enable Invest NZ to update related policies and guidance.
The changes are separate to the inclusion of a new Build-to-Rent investment category recently announced by the NZ Government, due to take effect in December 2026.
Instead, the 28 September changes focus on clarifying distinctions between “Growth” and “Balanced” asset classes and on bolstering the oversight powers of Invest NZ.
Clarifying the distinction between Growth and Balanced investments
Immigration New Zealand has expanded the criteria that managed funds and direct investments must satisfy before they can be approved for AIP purposes. One of the most significant changes is the introduction of a more clearly defined concept of a “growth asset”.
The new concept is intended to reinforce the distinction between the AIP visa programme’s Growth and Balanced investment categories.
That distinction matters because Growth investors benefit from a significantly lower investment threshold and physical presence requirement. Applicants under the Growth category are required to invest a minimum of NZ $5 million for three years and spend 21 days onshore during that term, whereas applicants under the Balanced category must invest NZ $10 million for five years and spend 105 days onshore during that term. The Growth category is intended for higher-risk, higher-impact investments, while the Balanced category investment can be deployed across a broader range of investment classes that are often described as “passive”.
It is an intended and important distinction. Growth applicants receive the benefit of a smaller investment amount, minimum investment timeframe and physical presence requirement. This is due to the higher investment risk they are taking and the potential to create greater economic impact by virtue of investing in assets that are not considered “passive” in nature.
To better achieve this objective and maintain the integrity of the programme, Immigration New Zealand has added a requirement that under the Growth category, acceptable managed funds must invest predominantly into growth assets, and direct investments must themselves be growth assets.
A growth asset is defined as an asset that:
“…carries higher risk and targets a higher rate of return than assets typically held for capital preservation or income generation, including assets such as bonds and term deposits.”
Invest NZ will need to determine whether an investment is sufficiently growth-oriented. In assessing whether the growth asset test is met, Invest NZ may assess:
- the nature of the asset;
- its risk profile;
- expected returns;
- whether it is aimed at growth capital rather than preservation; and
- whether it would commonly be regarded by financial markets as a growth asset.
Managed funds or direct investments with more conservative strategies, or which are weighted more towards capital preservation than they are towards risk and return, may not qualify as a growth asset under the clarified concept.
It’s important to understand that the introduction of this test overlays the existing AIP requirements rather than replacing them. The policy here is also a clear signal to the existing managed funds and direct investments of expectations in future certifications.
New deployment plan requirements for managed funds
For managed funds, another new requirement is that Invest NZ must also be satisfied that the fund manager has a deployment plan that is consistent with its investment mandate or SIPO.
The intention is to ensure that AIP investor funds move into productive New Zealand investments within a reasonable timeframe. Fund managers will need to be able to demonstrate that capital has been deployed substantially in accordance with the plan submitted as part of the approval process.
This change is designed to enable the policy to achieve its purpose (funding company growth and new employment opportunities). It also aims to prevent managed funds holding cash, or delayed capital calls resulting in on-call investments (cash/bonds/listed equities) being retained longer than is reasonably expected, thereby frustrating or unreasonably delaying the programme’s intended economic benefits.
Expanded powers to suspend or revoke approved investments
In addition to the new criteria, the new AIP rules also substantially strengthen Invest NZ’s ability to intervene where an approved managed fund or direct investment no longer meets programme requirements.
Invest NZ may now suspend a managed fund or direct investment if, in its reasonable opinion:
- the investment no longer satisfies the acceptance criteria; or
- there is a material risk that it will cease to satisfy those criteria.
Notably, a suspension may take place immediately and without prior notice or consultation.
A managed fund may be suspended or revoked where:
- it no longer meets, or is at risk of no longer meeting, the approval criteria;
- information provided to Invest NZ is incomplete, inaccurate or misleading;
- a material change affecting the fund, manager or supervisor has not been disclosed;
- there are concerns regarding regulatory compliance, governance, integrity or reputation;
- continued approval would materially impair the objectives of the AIP programme; or
- the fund’s capital has not been deployed substantially in accordance with its deployment plan and SIPO within the first 12 months, unless Invest NZ considers there are circumstances justifying the delay.
Similar powers also exist in respect of direct investments.
These powers represent a significant shift from the previous framework and place greater ongoing compliance obligations on fund managers and direct investments after approval has been granted. All managed funds and direct investments need to pay careful attention to this.
Stand-down period
The changes to the AIP settings also introduce a new six-month stand down period. Where a managed fund or direct investment application is declined, or where an existing approved fund or direct investment has its approval revoked, a freeze on re-applying for AIP recognition will take effect for a period of six months.
For this reason, any managed fund or direct investment that receives a request for further information (RFI) in any application or certification process should seek professional assistance for any matters that are potentially contentious, to mitigate the potential of being closed out of the system for six months.
What does this mean for managed fund applications?
Fund managers seeking AIP approval should expect a more detailed assessment process and for those already in the system, increased scrutiny of their approach to market and performance.
Applications will need to demonstrate:
- a clear focus on growth assets;
- a credible deployment strategy; and
- ongoing reporting and compliance capability.
Attention should be paid to investment strategies that emphasise lower income generation, capital preservation or lower-risk lending strategies, as these will face increased scrutiny under the growth assessment framework.
What does this mean for direct investment applicants?
Similar changes apply to direct investments.
In practice, many direct investments are already likely to satisfy the growth asset test because they typically involve investment into operating businesses or growth-focused ventures. However, applicants will still need to demonstrate that the investment satisfies the new requirements and contributes to the objectives of the programme.
Looking ahead
The amendments reinforce the Government’s intention that AIP investor capital should be directed toward growth-focused investments that generate meaningful economic benefits for New Zealand.
While the new framework provides greater certainty around Invest NZ’s expectations, it also introduces heightened compliance obligations and broader regulatory intervention powers. Financial advisers and investors should review AIP-related investment structures carefully with these changes in mind. From our perspective, these changes are the first “shot across the bow” for the AIP managed fund and direct investment ecosystem.
If you would like to discuss how these changes may affect your proposed or current managed fund or direct investment from 28 September, contact us.
