In February, I wrote about the Government’s proposed overhaul of the Active Investor Plus (AIP) Visa—a much-needed reset designed to address low uptake and reignite investor confidence. As of 1 April 2025, those changes are now in force, and we have clarity on how the updated policy will operate in practice.
This follow-up outlines the finalised visa settings, the legal and strategic implications for applicants (including those already in the system), and why these changes matter.
A Simpler Framework with Two Defined Investment Pathways
The previous weighting system—widely criticised for its complexity and opaqueness—has been replaced with two clear investor categories:
Growth Category
- Minimum investment: NZD $5 million
- Investment term: 3 years
- Eligible investments: Direct investments or managed funds approved by NZTE
- Time in NZ: Minimum 21 days over the 3-year term
Balanced Category
- Minimum investment: NZD $10 million
- Investment term: 5 years
- Eligible investments: Listed equities, bonds (including government and corporate), property developments, philanthropy, and investments from the Growth category
- Time in NZ: 105 days over 5 years, reduced for additional capital investment: $11M = 91 days $12M = 77 days $13M = 63 days
Both categories include mandatory “investment activity questionnaires” at compliance checkpoints (24 and 36 or 60 months).
Key Changes from Previous Policy
Several other material adjustments have also taken effect:
- English language requirements removed: This is a welcome removal of a barrier that had little relevance to economic contribution.
- QDII and QDLP schemes now excluded: Funds must be transferred via acceptable channels; these schemes are no longer recognised under AIP, though they remain permitted under some legacy categories.
- Investment must be completed within 6 months of approval in principle (extendable once by 6 months on request with evidence).
- On-call investment mechanism introduced: Funds awaiting deployment into managed investments may be held in short-term instruments like listed equities or term deposits (up to 6 months).
- Flexibility to change category once: Applicants may switch between Balanced and Growth once during the process.
- Caps on investment types removed: Investors now have discretion in allocating their capital across eligible assets.
What This Means for Existing and New Applicants
Transitioning Applicants (pre-1 April 2025):
Those who applied under the old AIP settings can opt into the new regime by 31 May 2025 without paying a new fee. This offers a meaningful opportunity to reassess the chosen category, particularly if the investment strategy has changed or been delayed.
Investor 1 and 2 Applicants (legacy categories):
Applicants still awaiting a decision under the closed Investor 1 or 2 categories must submit a new AIP application. While existing funds may be reused, applicants must meet the new thresholds and timeframes, and the investment period will restart on approval.
Resident Visa Holders Seeking to Reapply:
Those already holding residence under AIP or the prior investor categories may submit a second AIP application under the new settings. However, they must comply with the existing visa conditions until the second application is decided, or risk liability for deportation if non-compliant investments are made in the interim.
This reset has clear intent to recover from a failed policy experiment and restore New Zealand’s reputation as a viable destination for foreign direct investment. As Ministers Nicola Willis and Erica Stanford have acknowledged, the previous iteration of the AIP visa discouraged investor participation—with just $70 million committed under it, compared to $2.2 billion under its predecessors.
By simplifying the rules, broadening investment types, and removing unnecessary barriers, the Government is aligning immigration policy with its economic growth ambitions. At the same time, the return of property and bond investments under the Balanced category provides the security many investors are seeking, without abandoning the Government’s goal of stimulating business activity and job creation.
Next Steps for Clients
If you:
- Have an existing AIP application;
- Are considering whether to transition;
- Need to reassess investment structure; or
- Wish to make a fresh application under the new rules
I recommend reviewing your strategic position well before the 31 May 2025 transition deadline. Given the nuances of these changes, and the compliance expectations under section 49 conditions, sound immigration and investment advice is critical.
If you would like to learn more about the process or have any questions, please don’t hesitate to contact us on +64 3 441 2743 or [email protected].
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