New Zealand will allow Active Investor Plus (AIP) visa applicants in the Growth category to count philanthropic donations toward their investment requirement from June 1. Immigration Minister Erica Stanford announced the change on May 25, and Immigration New Zealand published the amended operational instructions the following day.
Under the new settings, Growth category applicants can direct up to 20% of their minimum NZ$5 million (approximately US$2.9 million) investment toward philanthropic gifts. The remaining 80% must stay in higher-growth assets such as managed funds and direct business stakes.
Philanthropy was already an eligible investment class in the Balanced category, which requires NZ$10 million (approximately US$5.9 million) over five years. Until now, however, it was absent from Growth, the category that draws the vast majority of applications.
“Over the last year I have met a number of investors, potential investors, and heard from charities, asking for investors to be able to contribute directly to social, environmental, conservation, or cultural good in New Zealand through a philanthropic gift as part of their AIP Visa,” Stanford said. “While that option is currently available in the Balanced category, it is not available in Growth which attracts the majority of applications.”
Compliance Requirements Are Detailed
Amendment Circular 2026-13, published by the Ministry of Business, Innovation and Employment (MBIE), sets out operational rules tighter than the ministerial announcement suggested. Charities receiving philanthropic gifts through the AIP visa must have filed at least five years of compliant annual returns, hold current Inland Revenue donee status, and report to Charities Services (Ngā Rātonga Kaupapa Atawhai) under Tier 1, 2, or 3.
Donations must also be “exclusively directed to domestic causes within New Zealand,” evidenced by a written agreement between the applicant and the receiving charity. Specified Department of Conservation (DOC) initiatives qualify as well, provided they appear on the DOC’s published approved list.
James Hall, Director of ANZ Migrate, said the compliance requirements will narrow the field of eligible charities. “You can’t just pick a charity you like,” he said. “The organisation needs five years of compliant annual returns, current Inland Revenue donee status, and the investor has to get a formal written agreement confirming the funds go exclusively to domestic causes inside New Zealand. If it’s conservation, the initiative has to be on the Department of Conservation’s published approved list.”
Broad Conflict-of-Interest Rules
The circular also introduces disclosure requirements that go further than most residence by investment (RBI) programs demand. Applicants must declare any pre-existing affiliation between themselves, anyone included in their application, or any family member and the receiving charity.
“Family members” under the instructions extends to partners, parents, children, grandparents, grandchildren, uncles, aunts, nephews, nieces, and adult siblings. Pre-existing affiliations include membership of an incorporated society or trusteeship of a charitable trust.
Immigration New Zealand can decline an application where such an affiliation exists and the donation has resulted or may result in “direct private benefit,” defined to include non-financial advantages and services received in kind. Hall called these rules “broader than most people would expect,” noting that the disclosure obligation covers the applicant’s extended family, not just the applicant himself.
The NZ$1 Million Figure Is Not a Hard Cap
Most media coverage has pegged the philanthropic allowance at NZ$1 million, which reflects the 20% cap applied to the NZ$5 million minimum. The circular clarifies that the percentage, not the dollar figure, is the operative limit. An applicant investing NZ$10 million under the Growth category could allocate NZ$2 million to philanthropy.
“The percentage is fixed, the dollar amount scales,” Hall said. He described the expansion as “a genuine and welcome addition to the program” but one that “will require serious due diligence on the charity, the family connections, and the donation structure.”
Stanford’s announcement echoed the economic framing, calling the capped option a way to add “flexibility, while keeping the category’s focus on strong economic outcomes.”
Mischa Mannix-Opie, Client Experience Director at Greener Pastures New Zealand, called the change “a thoughtful evolution of the Active Investor Plus program,” adding that the philanthropic component “gives investors another meaningful way to build a connection with New Zealand while still contributing to the country’s long term growth.”
Updated Application Data
According to Immigration New Zealand, the program had received 730 applications covering 2,390 people as of May 20, representing a potential minimum investment of NZ$4.26 billion (approximately US$2.5 billion). Of those, 608 sit in the Growth category and 122 in Balanced.
Those figures mark a jump from the 573 applications and NZ$3.39 billion reported in February, when the AIP visa had been operating for ten months. Roughly one third of applicants are from the United States.
Program Structure
Launched in its current form in April 2025, the AIP visa replaced a single-tier structure built around a NZ$15 million nominal requirement with two categories. Growth requires NZ$5 million over three years and a minimum of 21 days spent in New Zealand; Balanced requires NZ$10 million over five years and 105 days of physical presence.
New Zealand also introduced a separate Business Investor Visa in November 2025, targeting investors willing to acquire and operate existing businesses at a NZ$1 million entry point.
