New Zealand’s Active Investor Plus (AIP) programme is entering a new phase of momentum. Investor demand is strengthening, the investment landscape is widening, and recent policy adjustments are reshaping what qualifies as acceptable investment. These themes framed our session at the Parent Boost Visa & Golden Visa Intensive, held on 14 November 2025 (NZT) via Zoom. Chaired by Marcus Beveridge of Queen City Law and presented by Bradley So (Active Investor Plus / “Golden Visa”), the session explored how the programme is evolving, from the shift beyond private equity into infrastructure and operating businesses, to the raised threshold for Direct Investment.

Against this backdrop, we combined the practical insights from the session with fresh data and policy updates released in Invest New Zealand’s November Advisor update. What follows is a concise wrap of the key developments and what they mean for advisers working with high-net-worth investors.

New Zealand’s Active Investor Plus (AIP) programme is in high gear, and its centre of gravity is shifting. The latest settings broaden “acceptable investment” beyond private equity to include infrastructure projects and operating businesses, while lifting the bar for direct deals to those with genuine investor interest.

Below is a concise wrap of my session, combined with fresh numbers and policy notes from Invest New Zealand’s November Advisor update. You can also access the AIP Presentation Power Point here.

The numbers: a deeper pipeline, real conversions

• 307 applicants in the Growth category → NZ$1.5b of growth capital signalled.
• $300m+ already committed to Growth-category products.
• International events may be converting more interest:

- US (NY/LA/SF): 296 attendees → 9 new AIP applications worth $45m since 18 Sept (with more imminent).

- Singapore: 80 attendees (notably higher than 2024).

- Germany (Berlin/Munich): 66 attendees across the EU, strong engagement.

• What’s next: managed funds and DIMS are being re-certified on capital commitments (refreshed allocation data to follow).

Takeaway for advisers: demand is expanding, and investors are explicitly asking where they can invest.

What changed — and why it matters

Direct Investment = market-validated only

Invest New Zealand will only consider Direct Investment applications when there’s genuine investor interest already in place, evidenced by at least one of:

• prior capital received, or
• interest from an approved managed fund/DIMS, or
• a principal applicant committing capital.

There is a short pause on new Direct Investment applications while forms and guidance are updated; existing acceptability letters remain valid, with extensions aligned to the revised criteria. Direct Investments are being removed from Live Deals.

Broader “acceptable investment”: infrastructure now in scope

Infrastructure developed for lease or for sale can be Growth-eligible where it forms part of an operating business or project delivering public/sector value (e.g., transport, digital, health/education, public infrastructure). “Pure property” appreciation/vanilla leasing remains out for Growth.

Direct Investment is no longer the Live Deals platform only approved managed funds.

What we covered in the session (and how to apply it)

Practical hurdles that make or break files

• Nominated funds & ownership: a company is a separate legal person — clients nominate shares, not the company’s bank account. For trusts, the trustee should be the principal applicant, so ownership/control are crystal clear.
• Source of funds: combine direct evidence (SPAs, audited financials, tax returns, bank statements) with circumstantial evidence (board minutes, registers, counterparty confirmations) to bridge sensible gaps — the standard is balance of probabilities.
• Transfers from China/Hong Kong: separate lawful earnings from transfer mechanics. However, the new policy states that in assessing lawful earning INZ will look into the currency exchange which makes it more difficult for Chinese applicants. Therefore, it is important to be strategic in nominating the asset for investment.

Direct vs Managed — which path fits your client? (see comparison slide)

• Direct (Growth): equity/convertible notes; pre-approval from Invest NZ before any deployment; focus on feasibility, financials, and market validation; funds land with the company.

• Managed (Growth): equity and debt at the fund level; product assessed and reviewed periodically; cash can sit on-call pending capital calls; governance/track record is the key lens.

Property vs Infrastructure — draw the line early

Ask: Is property the investment, or the platform enabling an operating business/infrastructure?

If value comes from operations, jobs, productivity, IP, sector impact, you may be in Growth; if it’s yield/appreciation, you’re not.

The test is if the main source of income is derived from a lease through ownership of the property. If this is the structure, then it would be a pure property play.

Property per se is under review and we would expect a widening of acceptable investment classes to be announced in the next quarter so watch this space.

How QCL can we help

At Queen City Law, we sit at the intersection of policy detail and deal execution. We help investors and NZ businesses:

• Map proposals to Growth vs Balanced and the new infrastructure settings,
• Evidence genuine interest and manage Invest NZ confirmation,
• Structure ownership/nomination, source-of-funds (including China/HK pathways), and deployment sequencing,
• Keep files moving with templates, checklists and pre-screen memos that answer the right questions the first time.

Queen City Law is one of the most experienced law firms in New Zealand in this space with literally decades of experience navigating the business immigration space. The applicants we represent have the very best chance of success and we can add a lot of wrap-around services if required and always focus on bottom line value.