Managed Funds & Direct Investments Criteria (Appendix 15)

At a glance

Invest New Zealand (Invest NZ) maintains a list of acceptable managed funds and certifies direct investments for the Active Investor Plus visa. All investments must be legitimate, broadly benefit New Zealand, and not prejudice the country's reputation. Business immigration specialists rely on Invest NZ's list and letters as evidence of acceptable investments [A-appendix-15-criteria-for-managed-funds-and-direct-investment].

Definition

The appendix introduces several key definitions that underpin the acceptability tests [A-appendix-15-criteria-for-managed-funds-and-direct-investment]:

• Debt Security — as defined in the Financial Markets Conduct Act 2013 (FMCA).
• Equity Security — a share in a company or equivalent interest in a body corporate, but not a Debt Security.
• Financial Product — as defined in the FMCA.
• FMCA — the Financial Markets Conduct Act 2013.
• Investment authority — as defined in the FMCA.
• Investee Entity — a body corporate that is a New Zealand Resident Entity and is not listed on any securities or stock exchange.
• Managed Investment Scheme and Managed Investment Product — as defined in the FMCA.
• Net Committed Capital — total funds committed to the scheme, minus anticipated fees, obligations, expenses and liabilities.
• Entity — any company, limited partnership, body corporate or other similar entity wherever formed.
• New Zealand Entity — an entity that, at or immediately after initial investment, has:
  • the majority of its full-time employees and independent contractors in New Zealand or main operations based in New Zealand; and
  • one of:
    • shareholder voting control held by New Zealand tax residents;
    • a majority of the senior leadership team are New Zealand tax residents; or
    • its headquarters in New Zealand.
• New Zealand Resident Entity — as defined in BN7.10.20 of the Active Investor Plus visa instructions.
• Objective — the objective of the Active Investor Plus visa as set out in BN1.
• Principles — investments must:
  1. clearly contribute to the Government’s economic strategy by being invested in businesses or projects that deliver economic and other positive impacts for New Zealand. Acceptable sectors include technology, manufacturing, food and beverage, renewable energy, aged care, primary industries (including post‑harvest infrastructure), and infrastructure (tourism, transport, digital, health, education, public).
  2. be into legitimate Investee Entities or managed funds, with proper verification.
  3. not prejudice New Zealand’s reputation as a responsible world citizen.

  Investments into pure property assets or projects (commercial, residential, industrial real estate) are not acceptable, except for infrastructure. Invest NZ may consider other sectors that add value.

• Wholesale Investor — as defined in the FMCA.

Application in decisions

Managed funds: Invest NZ decides whether a Managed Investment Scheme is acceptable if it is managed by a properly registered manager/general partner that is a New Zealand Resident Entity, holds funds in New Zealand in NZD, and invests wholly or substantially (≥70% of initial net committed capital not allocated to other managed funds) in New Zealand Entities or in managed funds meeting the criteria, and otherwise aligns with the Objective and Principles. Invest NZ publishes a list of acceptable managed funds [A-appendix-15-criteria-for-managed-funds-and-direct-investment].

Direct investments: For listed equities, Invest NZ confirms an investment is acceptable if there is a separate wholesale offer through which the principal applicant invests as a Wholesale Investor, and Invest NZ provides prior written confirmation. For unlisted Investee Entities, Invest NZ must confirm in writing before investment, and must be satisfied that the entity has previously received capital or has genuine investment interest from an acceptable managed fund, a registered third‑party Wholesale Investor, or a principal applicant. In exercising its discretion, Invest NZ considers whether economic and other positive impacts will flow directly, including job creation/saving, productivity, intangible assets, and other economic, social or environmental impacts. For start‑ups or greenfield projects, evidence of market validation, feasibility and diligence is required [A-appendix-15-criteria-for-managed-funds-and-direct-investment].

Business immigration specialists must rely on the managed funds list (as evidence under BN7.10.10) and a letter from Invest NZ for direct investments (as evidence under BN7.10.15).

Interpretation & edge cases

• Revocation: Invest NZ may revoke an investment’s acceptable status if, in its reasonable opinion, the investment no longer meets the criteria in immigration instructions (BN7.10 and this appendix). This ensures ongoing compliance, not just a point‑in‑time assessment.
• “Substantially” test: For managed funds, at least 70% of the initial net committed capital not already allocated to managed funds must be invested in New Zealand Entities. The balance may be invested in other managed funds that themselves meet the criteria.
• Principles over financial health: The verification of legitimacy under the Principles is not a test of the Investee Entity or managed fund’s financial health or growth potential—that risk belongs to the principal applicant.
• Exclusion of pure property: The Principles explicitly exclude passive property investment, even if the business model involves property, unless it qualifies as infrastructure. Invest NZ retains discretion to include businesses in sectors beyond the listed ones if they add value to the New Zealand economy.
• Role of FMCA definitions: Many terms rely on FMCA meanings, creating consistency with New Zealand financial regulation. Advisers should consult the FMCA for precise legal definitions.

Citations

• A-appendix-15-criteria-for-managed-funds-and-direct-investment