Immigration New Zealand announced on 16 September that changes to managed funds and direct investment offerings under the Active Investor Plus Visa take effect on 28 September 2026. This is the second set of AIP changes in six weeks, following the evidentiary updates that came into force on 12 August. The settings are still moving.

Four changes:

• Deployment plans for managed funds. Approved funds will have to provide a plan setting out how they intend to invest capital into New Zealand, and maintain it over time. It is aimed at the gap between capital raised and capital actually working.
• A six-month stand-down for declined funds and direct investments. A manager whose offering is declined cannot immediately refile a tidied-up version. It is aimed at application quality and churn on the Invest New Zealand side.
• Enhanced powers for Invest New Zealand to suspend or revoke eligibility. Approval is no longer a one-off gate. An offering that stops meeting programme requirements can lose its status while investors are in it. It is aimed at ongoing compliance rather than entry.
• Clearer guidance on the Growth and Balanced categories. New guidance will describe what features make an investment a Growth category investment. It is aimed at the boundary between the two categories, which is where the threshold and investment period differences sit.

None of them change what an applicant has to do. All of them change how an applicant should choose where to put the money.

Nothing here touches the investor requirements

Thresholds are unchanged. Investment periods are unchanged. Time in New Zealand is unchanged. On the face of it this is fund manager housekeeping. The practical effect reaches further.

Deployment plans tell you what the problem was

Managed funds will have to provide and maintain investment deployment plans.

This one is not hard to read. Invest New Zealand data obtained by Queen City Law under the Official Information Act earlier this year showed $663 million in uncalled capital and $360 million held in cash, against $777 million actually invested. Invest NZ also confirmed it does not monitor downstream deployment of managed fund capital into the underlying businesses and projects at all.

A deployment plan requirement is the obvious answer to both. It gives Invest New Zealand a document to hold a manager against. It gives investors something concrete to test a manager on — what have they deployed, into what, and how quickly.

Revocation is the change with teeth

Invest New Zealand will have enhanced powers to suspend or revoke the eligibility of managed funds and direct investments that no longer meet programme requirements.

The announcement does not say what happens to an investor already committed to a fund that loses eligibility mid-term. That silence is the thing to watch. An AIP pathway depends on holding an acceptable investment for the full investment period. If the vehicle ceases to be acceptable through no fault of the investor, the question is whether there is transitional protection, a grace period to reinvest, or nothing at all.

Nobody can answer that until the instructions publish.

It is also worth noting what this does to Invest New Zealand's role. We have said before that its dual position as promoter and gatekeeper of the programme sits awkwardly. These changes expand the gatekeeper function without addressing that tension.

There is also a resourcing question. Monitoring deployment plans and testing ongoing eligibility across the approved market is continuous work, and Invest New Zealand is a small team. New powers are one thing. The capacity to use them consistently is another.

Growth category guidance may not leave every fund where it sits now

Growth carries the lower capital threshold and the shorter investment period. It is the reason most applicants look at the category at all.

New guidance will clarify the features of a Growth category investment. Clarification of that kind usually narrows rather than widens, and the Growth boundary has already been tested hard — the inclusion of "Project" within the Growth settings has admitted a wider range of asset-backed structures than the market expected a year ago. Some offerings currently presented as Growth may not sit comfortably within a clarified description.

The direction of travel is clear. Private credit accounts for roughly 73% of AIP capital committed, and the Government wants Growth capital reaching a wider range of productive investment. The Minister appears receptive on this point. Clarifying what counts as a Growth investment is one of the levers available to shift that concentration.

If you have selected a fund on the strength of the Growth threshold, confirm its position after 28 September. Not before.

The stand-down disciplines the supply side

Declined funds and direct investments wait six months before reapplying. That ends speculative applications by managers.

There are currently more than 70 approved managed funds, competing for an estimated 300-plus AIP investors still looking for a qualifying home for their capital. That is not a sustainable ratio. Once the cost of marketing to a small pool of families becomes clear, we would expect the field to consolidate hard — plausibly to a fraction of its current size.

The new requirements accelerate that. Approval gets harder for new entrants, and existing funds now face an ongoing test rather than a one-off one. For investors, a shrinking pool of approved vehicles is the thing to watch.

Fund selection is now a due diligence exercise

Three questions worth asking any manager from 28 September. What is your deployment plan, and what is your record against it? What happens to my investment if your eligibility is suspended or revoked? Have you been declined before, and when can you reapply?

What we do not know yet

Further guidance goes on the Invest New Zealand site from 28 September. The announcement is short on detail and anything more specific than the above is guesswork until the instructions publish.

We also expect further movement on build-to-rent. The acceptable investment boundary has been shifting steadily and BTR is the obvious next area. Additional property-based investment would likely be included once the Minister has dipped her toes in the water.

We will look at the instructions when they land.

If you are considering an Active Investor Plus application, or you are already committed to a fund and want to understand your exposure to these changes, get in touch.

Mathew Harrington is a lawyer at Queen City Law. He spent over a decade at Immigration New Zealand across operational, technical and leadership roles, primarily in business and investment migration. He now sits on the other side of the same assessments.