Last Friday I had the privilege of presenting at the Finance, Investment & Innovation Delegation Roundtable hosted by the Auckland Business Chamber — a small, focused gathering bringing together senior representatives from Shaanxi Province with a select group of New Zealand businesses.

The delegation was led by senior government and financial figures — including the Deputy Director-General of the Office of the Financial Commission of the CPC Shaanxi Provincial Committee, the Director-General of the Provincial Treasury Payment Center, and the Chairmen of Qin Nong Bank and Yong'an Property Insurance, among others. It was exactly the kind of room where a practical, frank conversation about investment frameworks is most valuable.

I presented alongside Michelle Chen from Moore Markhams and Tammy Crause from Fox Partnerships, with each of us covering our respective areas. My focus was the Overseas Investment Office — the OIO — and the rules governing how overseas investors can acquire property in New Zealand. Given the seniority of the group and their background in finance and institutional investment, I wanted to keep it practical and grounded in real examples.

The Starting Point

If you are not a New Zealand citizen, the OIO rules may apply when you look to acquire property here. The rules vary significantly depending on what type of property you are acquiring — and understanding which category you fall into is the essential first step.

I walked the delegation through three asset classes: residential property, commercial property, and sensitive land. Each has a distinct set of requirements.

Residential Property — A Significant New Pathway

This is where the most important recent change sits. Overseas persons were previously prohibited from acquiring residential land in New Zealand. That restriction now has a meaningful exception: investors who hold a resident visa under the Active Investor Plus (AIP) category — New Zealand's Golden Visa — can purchase residential property here.

The property must be valued at a minimum of NZD 5 million, calculated on land and construction costs — fit-out is excluded from that figure. It is a detail that matters, and one worth getting right from the outset.

For developers, there are two separate exemption pathways: the Build-to-Rent exemption — which requires the developer to hold and rent long-term — and the increased housing supply exemption, which requires the developer to on-sell the completed units. The two are often confused, but the conditions are quite different.

Commercial Property — Largely Open

Below the NZD 100 million threshold, commercial property does not require OIO consent. The market is open. For the vast majority of commercial transactions — hotels, offices, retail, industrial assets — Chinese investors can participate directly and without the OIO process. We have acted on a number of landmark commercial acquisitions in Auckland on exactly this basis.

Sensitive Land — The Benefit Test

Sensitive land — which includes rural land of five hectares or more, farmland, foreshore, and seabed — requires OIO consent and a benefit-to-New Zealand assessment. The OIO applies a counterfactual test: would New Zealand be better off with this investor than without them? It is not a closed door, but it requires a carefully constructed case. Structure and narrative matter enormously.

The Bigger Picture

China has been a core part of our practice at Queen City Law for many years. The investors we work with are serious, long-term participants in the New Zealand economy — and collectively, our AIP clients have invested over one billion dollars into this country. Property has always been central to those conversations.

It was a genuine privilege to be part of this roundtable, and I am grateful to the Auckland Business Chamber — particularly Anna-May Isbey and Hao Hsu — for the invitation and the quality of the event. The delegation asked sharp questions and the dialogue was substantive. I hope it marks the beginning of a longer conversation. If you are a Chinese investor or institution considering New Zealand and would like to understand the investment framework, I would be happy to talk.