Immigration New Zealand (INZ) has rewritten the rules on where Active Investor Plus (AIP) visa applicants may borrow and how they must document gifted capital. The agency published the package on August 13 under the heading of greater certainty for investors.
Borrowed funds must come from the same country or jurisdiction as the assets supporting the application. Applicants also have to show that they earned or acquired the nominated funds lawfully, then moved them through appropriate banking channels.
Gifted capital brings a second test. Proof must establish that the gift was unconditional, and that it complied with the laws of the country where the donor made it.
Investors in managed funds receive the single concession in the package. A legally binding agreement now suffices, and the requirement for a non-revocable agreement has gone.
INZ has not stated a commencement date in the announcement itself. Its guidance pages already carry the amended requirements.
What the borrowing rule requires
Three conditions attach to borrowed funds under the published guidance, and INZ named only one of them in the announcement. The lender must be a bank or commercial lending institution acceptable to a business immigration specialist, and the applicant must secure the loan against the nominated assets.
Those borrowed funds must then sit in the same country or jurisdiction as the assets securing them. An applicant must also show that he borrowed because of a change of circumstances outside his control. Liquidating, transferring, and investing the nominated assets has to be neither economically viable nor practical.
INZ defines a commercial lending institution as a regulated entity providing loans, credit, or other debt financing to individuals on commercial terms. Lending arranged outside a regulated institution does not qualify.
Gifted capital and the source-of-funds test
Money gifted from within New Zealand is off the table. Applicants cannot nominate gifted funds already sitting in the country, nor gifted funds that sat there at any point as part of the nominated investment.
A relative distributing capital from a New Zealand trust or bank account therefore cannot underwrite an application. Documentation expectations run to gifting certificates, bank statements evidencing receipt, and proof of how the donor earned or acquired the money.
INZ moved the other way on the adjacent Business Investor Work Visa in July, when it began accepting lawfully earned gifted capital alongside franchise investments. On the AIP visa, gifts now carry conditions rather than fewer of them.
Why the managed fund concession matters
Growth category capital rarely deploys on arrival. Committed money that a fund manager has not yet called must go into on-call investments, and that placement starts the investment period running.
A non-revocable agreement locked the investor into that structure before a single capital call. Dropping the requirement gives applicants room to contract on ordinary commercial terms with fund managers and nominees.
Children born after approval
INZ can now grant visas as secondary applicants to children born after it approves an investor visa. Eligibility reaches permanent resident visa applications, variations of travel conditions, and second or subsequent resident visa applications.
Three conditions govern eligibility. The child must be a dependent child of an Active Investor Plus, Investor 1, or Investor 2 resident visa holder. He must also hold a Dependent Child Resident Visa based on that relationship, and must have entered New Zealand on it.
One further amendment aligns transfer of funds requirements across the Parent Retirement and Temporary Retirement categories.
Where the program stands
INZ has received 837 applications covering 2,732 people since the April 2025 relaunch, according to data current to July 23. Approvals total 395, with another 285 holding approval in principle and 139 still under assessment.
Committed and pipeline capital together reach NZ$4.845 billion (approximately US$2.85 billion). Approved applicants whose money has landed in New Zealand account for NZ$2.3 billion (approximately US$1.35 billion) of that.
The Growth category, requiring NZ$5 million (approximately US$2.9 million) over three years, accounts for 710 applications. Balanced, at NZ$10 million (approximately US$5.9 million) over five years, takes the remaining 127.
Americans lead with 277 applications covering 838 people, ahead of China on 156 and Hong Kong on 110. Germany, on 56, tops the European source markets. Intake has climbed steadily from the 573 applications INZ counted in February.
Approval takes an average of 36 working days once investment documentation reaches INZ.
Two different first-year totals
INZ puts the first 12 months at 637 applications and around NZ$3.7 billion (approximately US$2.18 billion) in potential investment. Immigration Minister Erica Stanford gave a different account in April, when the government reported NZ$3.9 billion across 609 applications for the same period.
That earlier count matched INZ data current to March 11, three weeks before the year closed. Both figures measure the same window from different vantage points.
A program that keeps moving
Settings have shifted repeatedly since the relaunch. Stanford closed discretionary investment management services (DIMS) as an approved channel in December and opened a philanthropic route for Growth applicants from June 1. She also brought forward a scheduled review of the program in April.
Parliament separately carved AIP holders out of the foreign buyer ban, letting them purchase homes above NZ$5 million from March 6.
INZ’s own breakdown of first-year committed capital puts direct business investment at NZ$20.4 million (approximately US$12 million) out of NZ$1.48 billion, or 1.4%. Tim Williams, a financial services lawyer and partner at Chapman Tripp, argued in April for reaching a steady state quickly. Each rule change adds cost for applicants and delay for businesses awaiting Invest NZ approval, he noted.
INZ made no reference to that review in the August announcement.
Nothing in this package touches the thresholds. What has moved is the standard of proof attached to where an applicant’s money came from and how it traveled.
