AIP in New Zealand: NZ$1.4 billion pledged, but only NZ$19.6 million has gone directly into business

In the first year of the Active Investor Plus (AIP) visa programme, the New Zealand government reported striking results: the total committed and in-progress investments amounted to NZ$3.9 billion (about US$2.3 billion). Of this, NZ$1.49 billion has already been deployed in practice, while NZ$2.415 billion remains in the pipeline under 609 applications from 1,988 participants.

Immigration Minister Erica Stanford said the figures confirm reforms launched in April 2025: minimum investment thresholds for eligibility were lowered from NZ$15 million to NZ$5 million. It was also noted that private credit alone attracted nearly NZ$900 million, with funding going, among other things, to projects in aged care and dental technology.

However, an investigation by New Zealand Herald pointed to a systemic issue: a significant portion of the money entering AIP appears to be staying in cash longer than the government expected—meaning the pace at which funds “flow” into real business assets is slower than anticipated.

According to the publication, in the first year only NZ$19.6 million (about US$11.6 million) went into direct business investments—a mere 1.4% of the overall NZ$1.4 billion.

Where AIP money actually ends up

The AIP programme offers two investment categories.

To qualify under “growth,” an investor must put NZ$5 million (about US$2.95 million) over three years into higher-risk instruments. Direct business investments and managed funds are allowed, but final decisions depend on approval by Invest NZ.

The “balanced” category requires NZ$10 million (about US$5.9 million) over a five-year horizon and permits more conservative structures—for example, listed shares and bonds.

In the actual allocation of funds, the growth pathway dominates—accounting for about two-thirds of all investments. Across both categories:

NZ$1.228 billion went to managed funds (about NZ$900 million of that into private credit), NZ$389 million into corporate and government bonds, and NZ$65.2 million into listed shares.

Against this backdrop, NZ$19.6 million in direct investments looks particularly small. Stanford said the “direct investment story” is still unfolding: further investments by visa holders are expected, and some may have already started. Authorities also said they were gathering supporting data and examples.

The “vulnerability” of DIMS: money may have sat in cash for too long

One channel that drew particular concern was discretionary investment management services (DIMS). In the eight months leading up to December 2025, NZ$172 million (about US$101 million) passed through DIMS accounts offered by management firms (including Craigs Investment Partners and Forsyth Barr)—over 32% of growth-category investments.

The key point: DIMS is a service, not a ready-made investment product. In practice, the investor’s capital can be held at the manager’s discretion entirely in cash if no suitable timing or instruments are found.

According to the Herald, Forsyth Barr, in particular, often invested only about 25% of funds shortly after receiving AIP money, keeping the rest in cash without waiting for the entire amount to be fully deployed—even by the 12-month mark. In addition, some providers may have pooled investors’ capital rather than deploying it individually.

Stanford said authorities issued warnings before tougher measures were introduced. When behaviour did not change, the DIMS channel was closed in December 2025 as an approved AIP investment mechanism.

Why closing DIMS didn’t fully solve the problem

Removing DIMS didn’t address the underlying issue: managed funds can also hold money uninvested while waiting for a “call” to deploy capital.

Once a visa holder allocates money to a fund, it can remain in reserve for months or even years before the fund begins investing. During that period, the investor may hold up to 25% in cash or term deposits, with the remainder in more liquid instruments, including listed shares and bonds.

The problem is that for the growth category, visa rules are designed to encourage investment into growth—not to allow long-term “parking” of capital. Yet “waiting to deploy” is treated as part of the investment timeline within the three-year window.

On top of that, fund managers can keep cash inside the funds themselves even after AIP capital arrives. Simona Robbers, acting AIP investment director at Invest NZ, told the media that the agency does not impose strict deployment deadlines, but it can pause or remove funds from the approved list if capital deployment drags on. She did not name the specific funds affected.

One of the largest “warehouses” for AIP money mentioned in coverage is the open-ended NZ Debt Fund run by Private Capital Group (PCG): in a year it received around NZ$350 million (about US$207 million) through the visa.

Co-founder Paul Carmen said the fund holds roughly 20% in cash—he argued this is needed for unit redemptions and for investment opportunities in the pipeline. He denied that authorities had raised concerns about the fund’s cash level.

At the same time, Carmen acknowledged AIP’s transformative impact: the fund surpassed NZ$500 million (about US$295 million), with AIP capital being the main source. Invest NZ also tightened reporting requirements for managed funds: from mid-2025, quarterly disclosures became required on the inflow and deployment of AIP funds. According to Carmen, funds that failed to meet reporting requirements were removed from the approved list.

Greener Pastures spokesperson Misha Mannix-Oppy, whose company manages two Invest NZ-approved funds, responded cautiously to the criticism: “We understand the intent behind the visa settings and are focused on creating long-term value for New Zealand through productive investment… Our job is to build real assets, support regional growth and deliver sustainable economic benefits.”

Liquidity vs growth: why investor preferences may diverge from visa goals

The issue isn’t only technical. As consultants working with AIP holders noted, many investors—based on their financial habits—tend to prioritise capital preservation and liquidity rather than the riskier strategies the programme is meant to encourage.

Senior lawyer Sarah Wells of Dentons, who has advised golden visa clients in New Zealand for around a decade, told the Herald that 95% of investors either invested or kept funds in New Zealand after the mandatory holding period ended.

Wells also stressed that exiting strictly after three years is not always realistic: private equity and venture capital funds often “lock up” capital for longer periods. Even for private credit, redemption timelines can shift.

Enda Stankard from MA Financial Group made a similar point. He compared AIP with Australia’s Business Innovation and Investment Program, where there is a formal cap on cash in approved managed funds—20%. In New Zealand, there is no comparable hard limit; the emphasis is on oversight and Invest NZ discretion.

Programme review continues: further tightening is possible

Stanford confirmed that a planned review of AIP is already underway. She declined to confirm specific changes and rejected rumours that the growth category would require a minimum allocation of NZ$1 million to private equity. In her view, such a rule could structurally restrict liquidity: after placement in PE, capital typically remains invested for years.

Financial services lawyer Tim Williams of Chapman Tripp urged the government to reach a “steady state” sooner. Any further rule changes increase compliance costs for applicants and complicate approval processes for companies that need investment. In his assessment, the programme is working overall, but “moving the goalposts” reduces trust.

Wells echoed a similar logic: any adjustments are likely to be targeted refinements to a system that, since its restart in April 2025, has already gone through multiple rounds of changes.

Big headline numbers don’t always mean fast deployment: expectations vs reality

By application volume and headline capital, AIP does look like a success story. The previous version attracted only 116 applications and roughly NZ$70 million over more than two and a half years. In the first 12 months under the updated model, there were 609 applications and NZ$3.9 billion in committed and in-progress investment.

But growth in “numbers” does not always translate into growth in “speed.” While the programme is designed to channel foreign capital into productive New Zealand businesses, at this stage it is more often sending money into managed funds and private credit instruments, where part of the capital may remain on standby.

At the same time, the government is signalling it is willing to act: the DIMS channel has been removed, quarterly reporting has been introduced, and a formal review is ongoing. The question is whether the next set of adjustments can accelerate real investment without deterring the capital that made the programme prominent and “successful” in public statistics.

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