New Zealand’s Active Investor Plus (AIP) visa has pulled in NZ$3.9 billion (approximately US$2.3 billion) in committed and pipeline investment in its first year, the government announced on April 22.
Of that, NZ$1.49 billion (approximately US$879 million) has already landed, with NZ$2.415 billion (approximately US$1.4 billion) in the pipeline across 609 applications covering 1,988 people.
Immigration Minister Erica Stanford framed the results as vindication of the April 2025 overhaul that slashed minimum thresholds from NZ$15 million to NZ$5 million. Private credit alone has attracted nearly NZ$900 million (approximately US$531 million), and sectors ranging from aged care to dental technology have received funding.
Beneath those top-line figures, however, an investigation by the New Zealand Herald has exposed a persistent structural problem: Much of the money that enters the AIP system sits in cash far longer than the government intended.
In the program’s first year, just NZ$19.6 million (approximately US$11.6 million), or 1.4% of the NZ$1.4 billion total, went directly into business investments.
Where the Money Actually Went
The AIP visa offers two categories. Growth requires NZ$5 million (approximately US$2.95 million) over three years in higher-risk assets: Direct business investments and managed funds, both subject to approval by Invest NZ. Balanced demands NZ$10 million (approximately US$5.9 million) over five years and permits more conservative holdings such as listed equities and bonds.
By a wide margin, growth is the dominant pathway, accounting for roughly two-thirds of all AIP investment. Across both categories, NZ$1.228 billion flowed into managed funds (with approximately NZ$900 million of that going to private credit), NZ$389 million into corporate and government bonds, and NZ$65.2 million into listed equities.
That leaves the NZ$19.6 million in direct investments looking conspicuously thin. Stanford told the Herald that the direct investment story is still unfolding; follow-on investments from AIP holders are expected, and some have already materialized. Collection of supporting data and anecdotes is underway, she said.
The DIMS Loophole
A more immediate concern was the discretionary investment management services (DIMS) channel. In the eight months to December 2025, NZ$172 million (approximately US$101 million) of growth-category investment, over 32% of the total, flowed through DIMS accounts offered by asset managers including Craigs Investment Partners, Forsyth Barr, and others.
DIMS is a service, not a fund product. At the manager’s discretion, investor capital can sit entirely in cash if the manager has not identified suitable deployment opportunities.
According to the Herald, Forsyth Barr routinely invested only around 25% of AIP funds on receipt, holding the remainder in cash with no expectation that the balance would be fully deployed even at the 12-month mark. Several providers were also pooling AIP investor capital rather than deploying it individually.
Stanford said the government gave multiple warnings before acting. When behavior did not change, she ordered DIMS closed as an approved AIP investment channel in December 2025.
Managed Funds and the Cash Question
Closing DIMS did not resolve the broader issue. Managed funds, the overwhelmingly preferred vehicle for growth-category investors, can also hold undeployed cash.
Once a visa holder commits capital to a managed fund, the money may wait months or years before the fund calls it for investment. During this period, investors are permitted to hold up to 25% in cash or term deposits, with the remainder in listed equities and bonds.
Growth-category visa holders would not otherwise be allowed to park money in such conservative assets, yet the waiting period counts toward their three-year investment clock.
Fund managers can also retain cash within their funds after receiving AIP capital. Invest NZ’s acting director of AIP Investments, Simone Robbers, told local media that officials do not mandate deployment timelines but can remove or suspend funds from the approved list if deployment is lagging. She declined to identify specific funds affected.
Private Capital Group’s (PCG) open-ended NZ Debt Fund appears to be the single largest repository of AIP capital, having received roughly NZ$350 million (approximately US$207 million) in visa money over the past year.
According to co-founder Paul Carmen, the fund holds roughly 20% in cash at any given time, a proportion he characterized as necessary for redemptions and pipeline opportunities. Carmen denied that officials have raised concerns about his fund’s cash position.
He acknowledged that the AIP influx has been transformative: The fund now exceeds NZ$500 million (approximately US$295 million), with visa capital constituting the overwhelming majority. Invest NZ tightened reporting requirements for managed funds in mid-2025, requiring quarterly disclosures on AIP inflows and deployment. Several funds that failed to meet reporting requirements were removed from the approved list, he added.
Mischa Mannix-Opie of Greener Pastures, whose firm operates two Invest NZ-approved funds, offered a measured response to the scrutiny. “We understand the intent behind the visa settings, and our focus is on delivering long-term value to New Zealand through productive investment,” she said. “While commentary will always vary, our attention remains on creating real assets, supporting regional growth, and generating enduring economic benefit.”
Investor Preferences and the Liquidity Tension
The cash problem is not purely structural. Advisors working with AIP investors describe a clientele whose instincts run toward capital preservation and liquidity, not the growth-oriented risk the visa is designed to incentivize.
Sarah Wells, senior associate at Dentons, who has worked with golden visa investors across successive iterations of the New Zealand program for roughly a decade, offered a longer view. She told the Herald that 95% of golden visa clients invested more or retained their New Zealand investments after the required holding period expired.
Wells also noted that exit at the three-year mark is not always possible; private equity (PE) and venture capital funds typically lock capital for much longer, and even private credit redemption windows can shift.
Enda Stankard of MA Financial Group drew a comparison with Australia’s now-defunct Business Innovation and Investment Program, which capped approved managed funds at 20% cash. New Zealand has no equivalent formal cap, relying instead on Invest NZ’s supervisory discretion.
Review Underway, Rumors of Further Tightening
Stanford confirmed she has brought forward a planned review of the AIP program. She declined to confirm specific changes but dismissed as rumors the speculation, circulating among industry practitioners, that the government will mandate a minimum NZ$1 million private equity allocation within the growth category. Such a requirement would structurally limit liquidity; once deployed into PE, capital tends to stay deployed for years.
Tim Williams, a financial services lawyer and partner at Chapman Tripp, urged the government to reach a steady state as quickly as possible. Every rule change adds costs for applicants and delays for businesses seeking Invest NZ approval. Williams characterized the program as broadly working well, but noted that moving goalposts erode confidence.
Wells was similarly pragmatic. She described potential changes as further tweaks to a system that has already undergone several rounds of adjustment since its April 2025 relaunch.
Shattering Expectations
New Zealand’s AIP visa has, by any application-volume or headline-capital metric, outperformed every expectation. Its predecessor drew just 116 applications and NZ$70 million over two and a half years. In 12 months, the revamped program generated 609 applications and NZ$3.9 billion in committed and pipeline capital.
But volume is not the same as velocity of deployment. A program designed to channel foreign capital into productive, growth-oriented New Zealand businesses is, for now, channeling most of it into managed funds and private credit instruments where some portion sits idle.
Wellington has shown it will act: DIMS is gone, quarterly reporting is in place, and a formal review is underway. Whether the next set of adjustments can accelerate deployment without spooking the capital that made the program a headline success is the question Stanford will need to answer.
