28 September 2026 is only days away. If you already hold approval in principle under the Active Investor Plus visa, or you are close to it, Amendment Circular 2026-26 is worth reading for one very practical reason: it writes down the transfer-of-funds route more clearly.

Bottom line up front: this circular is mainly a clarification, not a brand-new policy direction. Most people will not see a different outcome because of it. But if your money has been approved in principle, the route it takes into New Zealand matters, and the circular now spells out which accounts it can come from, whose control it must stay under, and when it actually counts as transferred.

The date is the point

Amendment Circular 2026-26 is dated 16 September 2026, and all changes take effect on 28 September 2026 (Immigration New Zealand, Amendment Circular 2026-26).

That is soon.

The circular amends instructions for the Active Investor Plus category, the Parent Retirement category, the Temporary Retirement category, and Appendix 15, which deals with criteria for managed funds and direct investments.

If you are still at the “can I qualify?” stage, this may feel technical. If you already have approval in principle, it is not technical at all. It is the part where the approved money has to move in the right way.

This is where things can go wrong.

Eligibility gets all the attention. Source of funds gets attention too. But the transfer itself is often treated as admin, when in practice it is part of the immigration pathway.

What actually changed

The circular says minor changes have been made to immigration instructions to clarify transfer-of-funds requirements under the Active Investor Plus, Parent Retirement and Temporary Retirement visa categories.

That word “clarify” matters.

I would not read this as a broad new doorway opening or closing. I would read it as Immigration New Zealand making the route more explicit, especially for people who have nominated funds or nominated assets and now need to move money into New Zealand.

For Active Investor Plus readers, this sits alongside the visa’s broader settings on Immigration New Zealand’s product page (Immigration New Zealand, Active Investor Plus visa). I am not repeating investment amounts, timeframes, fees, or processing figures here, because this notice is about the mechanics in the circular.

The practical question is: where can the money come from, who can hold it on the way, and when does Immigration New Zealand treat it as transferred?

Which money must be transferred

Under the amended BN8.10 wording, the principal applicant must transfer the nominated funds, or the funds from the sale of nominated assets, to New Zealand and make the required investments (Immigration New Zealand, Amendment Circular 2026-26).

The circular is specific about the character of the money.

It must be one of these:

  1. the original funds that were nominated
  2. the original funds received from the sale of the nominated assets
  3. funds secured against the assets nominated in the resident visa application

That is the part I would highlight in yellow if this were sitting on my desk.

It is not just “the same amount of money”. It is not just “money from somewhere clean”. It is the original nominated funds, the original sale proceeds, or funds secured against the nominated assets.

If you have approval in principle, do not treat the transfer as an opportunity to simplify, swap accounts, tidy up ownership, or route money through a helpful relative. That may feel harmless commercially. It may not be harmless for immigration.

The accounts the money may come from

The circular now sets out the permitted starting points.

The funds must be transferred through the banking system, including via a foreign exchange company or money transfer business, directly to New Zealand from one of the listed account types.

Those account types are:

  1. the principal applicant’s bank account or accounts
  2. a joint bank account in the name of the principal applicant and their partner, and/or a dependent child included in the application
  3. a solicitor trust account, where the solicitor is acting for the principal applicant in the transaction of the nominated funds or assets
  4. a pension scheme in the name of the principal applicant
  5. an investment portfolio account in the name of the principal applicant

That list is the point of this circular for many families.

It gives you a cleaner checklist before the money moves. It also gives you something to test against your bank, foreign exchange company, solicitor, pension scheme, portfolio platform, and adviser before anyone presses send.

In plain English: if the money is leaving from somewhere else, pause and get advice before you move it.

Who must keep control of it

The funds must remain in the possession of the principal applicant, or of the listed third party, and the principal applicant must retain control until the funds are placed in on-call and/or acceptable investments.

That is a small sentence with a lot inside it.

It means the transfer route is not only about the name on the original account. It is also about control during the journey.

For example, where a solicitor trust account is used, the solicitor must be acting for the principal applicant in the relevant transaction. Where a foreign exchange company or money transfer business is used, the transfer still needs to be directly to New Zealand and through the banking system.

The applicant’s control is not a nice extra. It is part of the requirement.

I am asked about transfer steps regularly, especially when families are trying to line up bank cut-offs, exchange rates, investment deadlines, and document requests. My answer is usually boring, but it is the safer one: map the route before the transfer starts.

The moment the transfer counts

The circular also states when the funds are considered to have been transferred through the banking system.

They count as transferred at the point at which they leave the country in which they were legally earned or acquired, and are received in New Zealand (Immigration New Zealand, Amendment Circular 2026-26).

Both sides matter.

Leaving the source country is not enough on its own. Being received in New Zealand is part of the test.

This is why clean records matter. You want a paper trail that shows the nominated funds, the permitted sending point, the transfer through the banking system, and receipt in New Zealand.

Not dramatic. Just tidy.

Parent Retirement and Temporary Retirement

The same practical theme applies to Parent Retirement and Temporary Retirement applicants.

The circular says it clarifies transfer-of-funds requirements under these categories too. If you are in one of those pathways, I would read this as a reminder that the transfer step needs the same care as the eligibility step.

Do not assume that because the money exists, the transfer will automatically be accepted. The route matters.

This is especially important where money is held across different structures, pension schemes, investment accounts, joint accounts, or sale proceeds. Before money moves, check whether the starting account fits the clarified wording and whether the applicant remains in control until the money is placed where it needs to go.

What changed in Appendix 15

Appendix 15 is also amended. The circular says the changes are intended to improve the quality and oversight of managed funds and direct investments under the Active Investor Plus visa by doing three things:

  1. requiring up-front and ongoing deployment plans from managed funds
  2. strengthening processes relating to declines, suspensions, and revocations
  3. clarifying the distinction between Growth and Balanced category investments

That is all I would safely say from the circular itself. I would not read extra detail into it beyond those three points.

If you are following the investment side closely, you may also find my earlier notes on the Active Investor Plus direct investment list becoming public again useful: Active Investor Plus direct investment list is public again.

But a careful line matters here.

I can help you understand the immigration consequences of an investment pathway. I cannot tell you which fund, asset, tax position, or investment choice is right for you. Those decisions belong with a licensed financial adviser and, where needed, a tax adviser.

Why this clarification matters even if your outcome does not change

This circular may not change your final answer.

If your funds are already nominated, your ownership is clear, your sale proceeds are traceable, and the transfer route is clean, this may simply confirm the way you were already planning to move the money.

That is still valuable.

Visa work is often stressful because the dangerous parts look ordinary. A bank account. A currency transfer. A solicitor trust account. A pension payment. A portfolio withdrawal.

None of those sound like immigration decisions, but in this context they can be.

The value of this circular is that the route the money takes is now written down. Which accounts may be used. Who must keep control. When the transfer counts.

For someone holding approval in principle, that is practical.

What I would actually do

If I were sitting with your file this week, I would not start by asking which investment looks attractive.

I would start with the transfer map.

I would list the nominated funds or nominated assets from the visa application. Then I would match each source to the account or structure it will leave from. Then I would check whether that account is one of the permitted starting points in the amended wording.

After that, I would confirm who controls the funds at each step.

Principal applicant. Joint account with included family members. Solicitor trust account where the solicitor is acting for the principal applicant. Pension scheme in the principal applicant’s name. Investment portfolio account in the principal applicant’s name.

Then I would check the evidence trail.

Not because I enjoy paperwork. I do not. But because the transfer is only helpful if you can show what happened later, in plain English, with documents that make sense.

Finally, I would make sure the financial advice is coming from the right place. Immigration advice and investment advice are not the same thing. This article is immigration information only. It is not investment advice, tax advice, or a recommendation to use any particular fund or investment.

For the investment decision, talk to a licensed financial adviser.

For the immigration consequences of the route, talk to a licensed immigration adviser.

Sources

If you are close to transfer stage and want me to look at the immigration side of your route, send me a few details. I will be honest if I cannot help, and tell you who can.

Suzanne