New Zealand Golden Visa: Donations can now count toward Active Investor Plus (AIP) “Growth” investment requirements

Starting June 1, applicants under the Active Investor Plus (AIP) visa in the Growth track will be able to count charitable donations toward the required investment amount. The change was announced by Immigration Minister Erica Stanford on May 25, and Immigration New Zealand followed up the next day by publishing updated operational guidance.

The update is especially significant for people who view AIP as New Zealand’s “golden visa.” Previously, donations could only be credited in the Balanced category. Now they are also permitted in Growth—the stream that accounts for the overwhelming majority of applications.

How much can be directed to charity under Growth

Under the new rules, Growth applicants may allocate up to 20% of the minimum investment of NZ$5 million (about US$2.9 million) to charitable purposes. The remaining 80% must be invested in higher-yield assets, such as:

managed funds and direct equity in a business.

Before this change, donations were treated as allowable investment only within Balanced, where the minimum requirement is NZ$10 million (around US$5.9 million) invested over five years. The option has now been extended to the Growth category.

Why the minister called the change a response to investor feedback

According to Stanford, over the past year she has been speaking with investors and prospective applicants, and she has also received messages from charitable organizations. Many asked for the ability to contribute to social, environmental, conservation, or cultural initiatives in New Zealand as part of the AIP pathway.

The minister noted that Balanced already offered this option, but it was missing from Growth—the category that attracts most applicants.

Compliance requirements: what the circular clarified

Although the announcement sounded like simplification, the practical rules turned out to be more detailed. The updates are set out in Amendment Circular 2026-13, published by the Ministry of Business, Innovation and Employment (MBIE).

Key conditions for charity contributions to be credited under AIP include:

1) The charity must file at least five years of annual reports that meet the required standards.

2) The organization must have an up-to-date Inland Revenue donee status (the tax-recognition category for donation purposes).

3) The charity must report to Charities Services (Ngā Rātonga Kaupapa Atawhai) under Tier 1, 2 or 3.

Donations must also be used exclusively for domestic initiatives in New Zealand. This is supported by a written agreement between the applicant and the recipient organization.

The guidance further specifies that initiatives connected to the Department of Conservation (DOC) may qualify if they appear on DOC’s published approved list.

James Hall, Director at ANZ Migrate, said these conditions will narrow the set of charities that can be used: “You can’t simply pick any organization. You need years of compliant reporting, an active donee status, and a formal written agreement confirming that funds are directed solely to New Zealand-based purposes. If it’s conservation-related, the initiative must be on the approved DOC list.”

Expanded conflict-of-interest disclosure rules

The circular also introduces disclosure obligations that may be stricter than those found in many other RBI (Residence by Investment) programs.

Applicants must declare any pre-existing relationships—including ties between the applicant (and anyone included in the application) and family members—on one side, and the charity receiving the donation on the other.

“Family members” in the instructions include, among others: partners, parents, children, grandparents, grandchildren, aunts/uncles, nieces/nephews, and adult siblings.

“Pre-existing affiliations” can include, for example, membership in an incorporated society or serving as a trustee within a charitable trust.

Immigration New Zealand may refuse an application if such a connection exists and the donation has caused or could cause a “direct private benefit.” This concept covers not only financial advantages, but also non-financial benefits and in-kind services.

Hall described the rules as broader than many expect: the disclosure duty can extend beyond the applicant and into an expanded family circle.

NZ$1 million isn’t a hard cap—what matters is the percentage

In the media, NZ$1 million has often been cited. That figure corresponds to 20% of the minimum NZ$5 million threshold. However, the circular clarifies that the deciding factor is the percentage, not a fixed dollar amount.

For instance, if an applicant invests NZ$10 million in the Growth category, they could direct NZ$2 million to charity.

“The percentage is fixed, and the dollar amount scales,” Hall explained. He called the change a “real and positive addition” to AIP, but emphasized that applicants will still need thorough due diligence—checking the charity, the family links involved, and the donation structure.

Stanford also framed the move in economic terms: it “adds flexibility” while keeping the Growth category focused on strong economic outcomes.

Misha Mannix-Oppy, Director of Client Experience at Greener Pastures New Zealand, described the update as a “balanced evolution” of Active Investor Plus. In her view, the charitable component gives investors another way to “strengthen their connection to New Zealand” while continuing to support the country’s longer-term growth.

Current AIP application figures

According to Immigration New Zealand, as of May 20 the program had received 730 applications covering 2,390 people. This could correspond to minimum investments of roughly NZ$4.26 billion (about US$2.5 billion).

By category:

608 are for Growth,

122 are for Balanced.

The figures are up from the data reported for February (when the program had only been running for 10 months): at that time there were 573 applications and NZ$3.39 billion. Approximately one-third of applicants are US citizens.

How Active Investor Plus works—and what alternatives exist

In its current form, the AIP visa launched in April 2025, replacing the earlier single-threshold model of NZ$15 million. The program now has two categories:

Growth: NZ$5 million invested over three years, plus a minimum 21 days of physical presence in New Zealand.

Balanced: NZ$10 million invested over five years, plus 105 days of stay.

Separately, in November 2025 New Zealand introduced a standalone Business Investor Visa for people willing to buy and manage existing businesses, with an entry threshold starting from NZ$1 million.

Expert note: While the charitable-donation option may sound straightforward, practitioners often treat “Golden Visa” charity planning as a documentation-heavy exercise rather than a simple add-on. In New Zealand, charities operate within a regulated reporting ecosystem, so investors typically need to align (1) the charity’s compliance history, (2) the tax-recognized donee status, and (3) the project’s domestic scope—before the investment package is finalized. A lesser-known practical point is that donation timing and the wording of the written agreement can matter: immigration decision-makers look for evidence that the funds are earmarked for qualifying outcomes from the outset, not just “intended” later.

If you’re considering a New Zealand Golden Visa via Active Investor Plus, the updated approach—allowing charitable donations to count within the Growth category—may make your investment strategy more flexible. Digital Nomad can help you structure your capital across eligible assets and permitted contributions, improving alignment with the program requirements and reducing avoidable mistakes. Learn more: https://digital-nomad.gr/en/goldenvisa

Our Telegram channel about various types of Greek residence permits, digital nomad programs, and the Greek Golden Visa: @digitalnomadgr