Immigration New Zealand has updated its rules for managed funds and direct investments under the Active Investor Plus (AIP) visa programme. The changes take effect immediately and directly affect managed funds and direct investments in the Growth category, introducing new deployment plan requirements, strengthening oversight, and further clarifying the distinction between Growth and Balanced category investments.

Separately, from December 2026, Build to Rent investments will also become available as a Growth category option through approved managed funds.

The updated AIP Guidance Note for managed funds is available here.

Who needs to read it? Why?

These changes matter if you manage, advise on, or invest through an AIP-approved managed fund. Existing approved funds should review their investment strategy and deployment plans to ensure they are aligned with the new requirements. New fund manager applicants can expect a more rigorous assessment process. The consequences of falling short can be significant. Invest NZ may suspend an acceptable investment immediately and without prior notice or consultation, and a six-month freeze on reapplying applies from the date the decline or revocation is communicated. Understanding where you stand now is essential.

What does it cover?

Invest NZ published updated guidance for managed funds on 28 September 2026. There are four material changes to know about.

A new test for growth

Acceptable managed funds must invest predominantly in “Growth Assets”.

A Growth Asset is defined as: 

“an asset that carries higher risk and targets higher rates of return than assets that are typically held for capital preservation or income-generation (including but not limited to bonds and term deposits). The classification of an asset as a growth asset shall be made having regard to the nature and risk profile of the asset and its expected returns relative to income assets or assets held for capital preservation and whether it is an asset that is of a nature that is commonly referred to in the financial markets as a growth asset”.

In practice, managed funds with more conservative mandates, for example those weighted towards capital preservation, income generation, or lower-risk strategies, could be at real risk of not qualifying under the Growth category. Invest NZ’s guidance does not set a numerical threshold for what counts as “predominantly” invested in Growth Assets. We understand that Invest NZ will assess each managed fund on a principles basis, looking at the nature and risk profile of the underlying assets and their expected returns relative to income or capital preservation assets. The existing 70% New Zealand entity threshold is a minimum, not a cap – it does not automatically translate into a "30% permitted in non-Growth Assets" allowance.

New deployment plan requirements

Managed funds must now have a deployment plan consistent with their Statement of Investment Policy and Objectives (SIPO) and the AIP investment requirements. Plans can be updated by notifying Invest NZ. Critically, if a managed fund’s net committed capital has not been deployed substantially in accordance with its plan within 12 months of listing as an acceptable fund, and there is no justifiable reason for the delay, Invest NZ may suspend the fund's acceptable investment status. Existing approved funds should review their deployment plans and SIPOs against the new requirements without delay. 

New expanded powers to suspend and revoke acceptable investment status

Invest NZ's ability to intervene has been significantly broadened. Suspension may take effect immediately and without prior notice or consultation if Invest NZ considers this necessary or appropriate, having regard to the nature of the concern, the integrity or reputation of the AIP programme, or its objective. Suspension may apply for up to three months at a time. Invest NZ is not required to provide reasons for any suspension or revocation at the time of notification.

A six-month stand-down period also applies. A fund that is declined or has its status revoked cannot reapply for six months from the date the decline or revocation is communicated, and Invest NZ is not required to give reasons.

Build to Rent to be added as a Growth investment from December 2026

From December 2026, approved managed funds will be able to offer Build to Rent as an acceptable Growth category investment option, giving Growth category applicants access to purpose-built rental housing developments through investment structures that meet AIP requirements.

Funds wishing to offer this option will need to meet additional requirements relating to capability, governance and delivery. Further detail on eligibility requirements, investment structures and implementation timeframes is expected before the change takes effect. We understand this may include a requirement that participating managed funds be sponsored by a company with a demonstrable track record of at least five years in residential property development at scale.

Our view

Prospective fund manager applicants should be prepared for a more rigorous assessment when they apply, and existing acceptable managed funds are likely to see closer engagement from Invest NZ around how their fund is marketed and how it is actually performing against its stated strategy.

Where a fund's approach leans towards income generation, capital preservation, or lower-risk lending, that positioning is more likely to attract questions about whether the underlying assets satisfy the Growth Asset test.

Managers who are thinking about opening a Build to Rent option should consider how they would demonstrate the relevant capability, governance and delivery, so that they are ready to move once the detailed requirements are released ahead of December 2026.

If you would like to discuss what these changes mean for your fund, your business or your wider AIP strategy, our team is happy to help.

This article was co-authored by Darlene Hu a Solicitor in our Financial Services team.