Invest NZ has published anticipated guidance updates designed to assist managed fund and direct investment applicants under the Active Investor Plus (AIP) visa programme. The updates are designed to help applicants interpret recent changes to the AIP settings which took effect on 28 September 2026.
Major changes to the AIP settings introduced by Immigration New Zealand have now come into effect, as of 28 September 2026. A summary of these changes (which we examined in detail here) is:
- acceptable managed funds must invest predominantly into a clarified definition of “growth assets”, and direct investments must themselves be “growth assets”;
- managed funds must now develop, provide and comply with a deployment plan detailing how they intend to deploy capital into the New Zealand economy;
- Invest NZ now has expanded powers to suspend or revoke approved investments; and
- declined AIP applications or revoked investment offerings now have a stand-down period of six months before they can re-apply for approval.
On the same day these changes took effect, Invest NZ updated its guidance to help managers of existing and prospective managed funds and direct investments interpret the new settings.
Meaning of Growth Assets
During the initial application process or when recertifying existing acceptable managed funds or direct investments, applicants will be prompted to provide an overview of how their investment structure satisfies the test.
Overall, it needs to be clearly established that the investment is an asset that:
“…carries higher risk and targets higher rates of return than assets that are typically held for capital preservation or income-generation, including but not limited to bonds and term deposits.”
Applicants can do this by assessing the new definition against:
- the nature of the assets in which the fund invests or intends to invest (or for direct investments, the nature of the proposed investment);
- their expected risk and return characteristics; and
- any other information supporting their classification as growth assets.
Outside of this guidance, it will be up to the applicant to determine how best to demonstrate alignment to the new growth asset definition.
Comparing the investment structure and its nature, risk and return to traditional conservative or balanced asset classes such as bonds and term deposits could be a practical starting point, but a far more detailed and well thought-through analysis will be required.
Importantly, existing fund managers who already hold approval under the AIP programme will also be required to explain to Invest NZ how their investment mandates “fit” within the new growth asset definition. This explanation, together with any updated investment policies and offer documents, are expected to be included in the upcoming re-certification response. This is due to be filed by approved funds in November 2026. This presents risk to existing managed funds, as we do not expect the recertification process will be straight forward.
Fund managers of approved AIP funds should act now to assess their investment mandate against the new criteria and prepare their response ahead of the next re-certification deadline. Fund managers should consider whether changes to their investment approach should be made to reflect the new AIP settings, and update their documentation where necessary, well in advance.
Requirements of a deployment plan
The 28 September updates to the AIP settings introduced a requirement for a deployment plan to accompany managed fund applications under the AIP programme.
Deployment plans are expected to be prepared consistently with a fund’s investment mandate and should demonstrate how the fund intends to deploy capital into the New Zealand economy within a reasonable timeframe. A deployment plan should be prepared with a timeline of at least 12 months in mind, and should include:
- the amount of capital expected to be deployed;
- the anticipated timing and pace of deployment;
- the investment pipeline or opportunities identified to date;
- the key assumptions underpinning the plan; and
- any factors that may materially affect deployment.
Invest NZ will take into consideration the particular nature of different types of funds when assessing a deployment plan – acknowledging that the approach to capital deployment can typically differ across investment strategies.
Failing to deploy capital in a manner substantially consistent with the deployment plan within 12 months of AIP approval can present grounds for a fund to have its acceptable managed fund status revoked.
The requirement for a deployment plan also applies to funds that are already approved under the AIP programme. Existing managed funds are expected to create their own deployment plans and ensure these are ready for Invest NZ during the November 2026 re-certification.
Managers of existing AIP funds should act quickly to develop and finalise their deployment plans in time for the recertification deadline.
The ‘70% / 30%’ split
While unrelated to the 28 September changes, the new Guidance note clarifies the existing requirement that at least 70% of an approved managed fund’s committed capital must be allocated to New Zealand entities.
An allocation of up to 30% may be invested by approved funds into assets that are not New Zealand entities. The Guidance note clarifies for the avoidance of all doubt that:
- the permitted allocation of up to 30% may still only be invested in assets that meet the AIP Objective and Principles – it is not an allocation that may be applied to asset classes that do not comply with the AIP Growth category (e.g. assets under the AIP Balanced category); and
- the allocation may be applied towards investments in offshore assets (i.e. investment that are not in New Zealand entities), but only if those offshore investments are otherwise compliant.
The “70% / 30%” split effectively represents the permitted allocations between onshore and offshore assets under the AIP settings, but either way, the investment must always be compliant with the AIP Growth criteria.
Looking ahead
Prospective applicants now have further information to help them progress their investment structures, with a better understanding of the major changes to the settings.
However, fund managers of existing acceptable managed funds have just a short window of time to ensure their offerings are aligned with the new settings, and that they are ready for the upcoming November 2026 recertification deadline.
If you would like to discuss how these changes may affect your managed fund or direct investment, including assistance with the re-certification process, contact our team. We are already assisting fund managers to navigate the new requirements and prepare for implementation of the new settings in November.
Source: Invest NZ Guidance
