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The Active Investor Plus (AIP) visa pathway continues to develop, with significant changes taking effect on 28 September 2026.
These changes will directly affect managed funds and direct investments under the Growth category of acceptable investments, introducing new requirements for deployment plans, strengthening oversight of acceptable investments, and further clarifying the distinction between Growth and Balanced category investments.
Separately, from December 2026, Build to Rent investments will be added to the Growth category of acceptable investments through approved managed funds.
Incoming changes to AIP rules
Immigration New Zealand has recently published amendments to the AIP immigration instructions aimed at improving the quality and oversight of managed funds and direct investments. There are three key changes that may affect both applications for approval and the ongoing status of these investments as “acceptable” investments.
1. New deployment plan requirements for managed funds
Managed funds will now be required to have a deployment plan in order to obtain and retain status as an acceptable investment. That deployment plan must be consistent with both the fund’s statement of investment policy and objectives (SIPO) and the investment requirements under the AIP rules.
Deployment plans may be updated by notifying Invest NZ. Existing acceptable managed funds should review their current deployment plans and SIPOs to ensure they are aligned with the new requirements.
2. Expanded powers for Invest NZ to suspend or revoke acceptable investment status
Invest NZ will now have broader powers in relation to managed funds and direct investments that have been approved as acceptable investments.
In addition to its existing power to revoke acceptable investment status, Invest NZ will also be able to suspend that status in certain circumstances. These include where:
- the relevant acceptability criteria are no longer met, or there is a material risk that they will no longer be met
- without justifiable reason, a managed fund’s Net Committed Capital has not been deployed in a manner substantially consistent with its deployment plan within 12 months of being listed as an acceptable managed fund, or
- Invest NZ considers suspension necessary or appropriate (in which case it may impose a suspension with immediate effect and without prior notice or consultation).
The amendments also allow Invest NZ to revoke acceptable investment status where there is a material risk that the relevant acceptability criteria will no longer be met.
A new stand-down period has also been introduced. If a Managed Investment Scheme or Investee Entity is declined or has its acceptable investment status revoked, it must wait six months before reapplying.
3. New definition of “Growth Asset”
A new definition of “Growth Asset” has been introduced into the AIP rules. Acceptable managed funds must now invest predominantly in Growth Assets, and any acceptable direct investment must itself be a Growth Asset.
A Growth Asset is defined as an asset that carries higher risk and targets higher rates of return than assets typically held for capital preservation or income generation, such as bonds and term deposits. Whether an asset is classified as a Growth Asset will depend on its nature, risk profile, expected returns, and whether it is commonly regarded in financial markets as a growth asset.
The amendments also include minor changes to clarify the transfer of funds requirements under the AIP visa.
Build to Rent to be added as a Growth category investment option
From December 2026, Invest NZ-approved managed funds will be able to offer investments in Build to Rent developments as an acceptable Growth category investment option. Funds offering Build to Rent investments will need to meet additional requirements relating to capability, governance and delivery. Further detail on those requirements is expected before the change takes effect.
This is a targeted expansion of the Growth category. Under the current rules, investments in pure property assets or projects, other than infrastructure, do not satisfy the principles for acceptable Growth category investments. The new Build to Rent exception will allow approved managed funds to invest in purpose-built rental housing through the Growth category, while maintaining the programme’s focus on productive investment.
Investor migrants and their family members will not be permitted to live in any Build to Rent development in which they are invested. Direct investments in Build to Rent developments will not be permitted.
What this means for fund managers and investors
If you operate a qualifying managed fund, or are considering establishing one, now is a good time to review your deployment plans and SIPOs to ensure they are consistent with the new requirements. You should also consider whether your fund’s investment mandate aligns with the new Growth Asset definition.
Fund managers interested in offering Build to Rent as an investment option should begin considering the governance, capability and delivery requirements that will apply from December 2026, once those requirements are published.
Please contact one of our experts if you would like to discuss how these changes may affect your fund, your business, or your investment strategy under the AIP visa programme.
