The Active Investor Plus visa was built on a simple promise: foreign capital would flow into New Zealand businesses, creating real economic activity. For a time, that promise was being quietly broken — not through fraud or bad intent, but through inaction.

In December 2025, Immigration Minister Erica Stanford drew a line. The government approved the removal of Discretionary Investment Management Services (DIMS) from the AIP approved investment list. Out went Alvarium, Craigs Investment Partners, Forsyth Barr, and Shaw and Partners. The reason, as officials put it, was blunt: investor capital was sitting in bank accounts rather than being put to work. B2B News

DIMS accounted for over 32% of growth category visa investment in the prior period, and for at least one major provider it was ordinary practice to invest just a fraction of AIP funds quickly — holding the remainder in cash at their discretion, with full deployment not always anticipated even at the 12-month mark. NZ Herald

Minister Stanford didn't mince words: "The intent of this visa is that the money gets deployed… we gave multiple warnings and behaviour didn't change."

The lesson no one wants to say out loud

The DIMS removal made headlines. But the deeper issue — one that applies directly to private credit funds still on the approved list — is the same: size does not equal deployment, and deployment is everything.

Some fund managers assumed that building a large, well-branded fund would naturally attract borrowers. That raising capital was the hard part. It isn't. Originating quality loans consistently, across different products and borrower types, is the hard part. A fund sitting on $100 million waiting for the right deal to come to it isn't investing — it's hoping.

Invest New Zealand has made clear that open-ended funds, particularly in private credit strategies, are expected to be closely monitored to ensure capital is being deployed and that investors are taking real economic exposure, rather than retaining liquidity without meaningful investment risk. Nzte

This isn't just a regulatory concern. It's a visa timeline concern. Your three-year investment clock doesn't pause while a fund waits for its phone to ring.

What to look for — and what to look out for

Choosing a private credit fund for your AIP investment isn't just about picking something on the approved list. The approved list tells you a fund has cleared a compliance threshold. It tells you nothing about whether that fund will actually put your money to work.

Here's what separates genuine deployment capability from a well-dressed waiting room:

Origination diversity. A fund that only writes large, medium-term commercial loans to a narrow borrower type is exposed. When that market tightens, deal flow dries up. Funds with multiple origination channels — different loan products, different cheque sizes, different borrower relationships — keep capital moving across market conditions.

Cheque size flexibility. New Zealand's private credit universe isn't deep enough to sustain a large fund writing only large tickets. Managers who can operate across a range of deal sizes — from smaller SME facilities to larger property transactions — have a material advantage in keeping capital deployed.

Track record, not ambition. A deployment plan is not a track record. Ask the fund manager to show you their actual loan book history: how quickly they deployed prior capital, what their average time-to-deployment looks like, and what percentage of committed capital is in active loans right now.

Active origination relationships. Quality loan origination comes from relationships — brokers, accountants, developers, business owners. Funds with established referral networks don't wait for borrowers to find them. They have a pipeline.

Regulatory standing. To remain on the acceptable managed fund list, funds must complete Invest New Zealand's annual recertification and adhere to disclosure requirements — failure to do so can result in removal from the list. Ask when the fund last recertified and whether there are any open compliance matters. CTF Assets

The bottom line

The removal of DIMS from the AIP programme was a signal, not an isolated event. The government has made clear that capital parking — in any form — is not what this visa was designed for. As one commentator noted, for New Zealand startups and growth businesses waiting for capital that was promised but never arrived, the distinction between committed and deployed is everything. B2B News

For investors, the same logic applies. A fund that can't deploy doesn't just create a compliance risk — it creates a visa risk.

The right private credit manager isn't the biggest name on the list. It's the one that has been writing loans since day one, across a range of products and relationships, and can show you the numbers to prove it.

If you'd like an introduction to active, well-deployed private credit options approved under the AIP programme, get in touch.