Active Investor Plus Cash Rules Under Review Amid Idle Funds Concerns

Where Has the NZ$1.4 Billion Gone?

In its first year (April 2025 to March 2026), the Active Investor Plus programme brought NZ$1.4 billion into New Zealand. However, the breakdown of where those funds have been deployed has raised questions about how "active" the investment really is.

The low level of direct investment — just $19.6 million or 1.4% of the total — has prompted questions about how much "hands-on" engagement investors are having with New Zealand businesses. Minister Stanford has emphasised that the real activity in direct investment is expected to come through follow-on investments, and that data to support this is being collected.

DIMS Option Closed in December 2025

In December 2025, the Government closed off the Discretionary Investment Management Services (DIMS) option after concerns that investor funds were sitting in cash for extended periods.

DIMS was offered through asset managers including Craigs Investment Partners, Forsyth Barr, Shaw and Partners, and Alvarium. In the eight months to December 2025, $172 million of Growth category investment (over 32% of the total) went into DIMS accounts.

The Herald reported that for at least one DIMS provider, it was ordinary practice to invest just a fraction of AIP funds quickly (in the order of 25%), with the remainder held in cash at the manager's discretion.

Cash Holdings Within Managed Funds

Beyond DIMS, another area of concern is cash held within managed funds while waiting to be deployed. Under the current rules, money destined for managed funds can sit "on-call" waiting to be invested — and during this period (which can take months or even years), the money may be held in cash or term deposits (up to 25%) and otherwise in listed equities and bonds.

Crucially, during this waiting period, the investment clock is ticking down. Growth category visa holders are not otherwise permitted to keep their money in such conservative investments as listed stocks and bonds — but the on-call exception allows it.

Invest NZ tightened reporting rules for managed funds in mid-2025. Funds now report quarterly on details including how much AIP money they have received and how much they have actually invested. Some funds have reportedly been removed from the approved list for failing to provide this information adequately.

Private Credit Funds: Where Most Money Goes

Private credit funds hold the lion's share of Growth visa investment — approximately $900 million of the $1.228 billion that went into managed funds. The PCG NZ Debt Fund appears to be the single largest repository, having attracted approximately $350 million in AIP funds in the past year alone.

Paul Carmen, one of PCG's founders, told the Herald that the fund holds roughly 20% in cash at any given time — to provide for both redemptions and investment opportunities in the pipeline. He rejected suggestions that officials have had concerns about the fund's cash holdings.

Carmen acknowledged that the influx of AIP money has been a "game-changer" for the fund, accounting for the overwhelming majority of its now $500+ million size.

Possible Further Changes

Minister Stanford has confirmed that she brought forward a planned review of the programme to ensure it is working as intended. Rumours in the market include:

• Further tightening of rules around cash holdings
• A requirement to allocate at least $1 million to private equity (which typically has much more limited liquidity than private credit)

Minister Stanford described these as "just that: rumours" — no changes have been announced.

The Bigger Picture

Despite the concerns about cash holdings, the programme has been a significant improvement on its predecessor. The investor visa iteration that ran from 2022 to 2025 brought in less than $100 million in total. In contrast, the current programme has brought in $1.4 billion in its first year alone, with over $2 billion more in the pipeline.

Sarah Wells, senior associate at law firm Dentons who has worked with golden visa investors for roughly a decade, emphasised the longer-term picture:

She was phlegmatic about the possibility of further "tweaks to the system," noting that investors will not necessarily be able to withdraw their investments at the three-year mark anyway — most private credit funds offer regular redemption windows, but these terms can change, and private equity and venture capital funds typically require much longer-term investments.

What This Means for Potential Applicants