Golden Visa Comparison 2026: How New Zealand's Active Investor Plus Stacks Up Globally

Three years ago, a wealthy investor shopping for a second residency had a buffet of options. Australia, the UK, Spain, Portugal, Greece, the Caribbean — the golden visa market was crowded, competitive, and relatively easy to enter. That world no longer exists. Since 2022, three of the most established programmes have shut down entirely, several others have been gutted, and the field has narrowed to a handful of credible options.

For anyone evaluating New Zealand residency by investment through the Active Investor Plus visa, the question is no longer "should I consider NZ?" — it's "what's actually left to compare it against?"

Here's the honest answer, programme by programme.

The Full Golden Visa Comparison Table: 2026

Programme	Investment Required	Presence Requirement	Investment Term	Path to Citizenship	Status
NZ Active Investor Plus (Growth)	NZ$5M (~US$3M) in VC/PE/direct	21 days / 3 years	3 years	~5-8 years total	Open
NZ Active Investor Plus (Balanced)	NZ$10M (~US$6M) mixed portfolio	105 days / 5 years	5 years	~6-10 years total	Open
Australia Significant Investor Visa	AUD$5M complying investments	40 days/year	4 years	~8-10 years total	Closed (July 2024)
UK Tier 1 Investor	GBP 2M in UK securities	185 days/year	5 years	~6 years (ILR + citizenship)	Closed (Feb 2022)
US EB-5	US$800K (TEA) / US$1.05M	Must reside in US	~2 years (conditional)	~7-12 years (backlogs)	Open
Portugal Golden Visa	EUR 250K-500K (funds/research/culture)	7 days/year average	5 years	5 years to citizenship	Open (no real estate)
Spain Golden Visa	EUR 500K property	Minimal	Renewable	10 years to citizenship	Closed (April 2025)
Hungary Guest Investor	EUR 250K fund / EUR 500K property / EUR 1M donation	Minimal	5 years (fund)	8 years to citizenship	Open (since 2024)

Let's break down what each remaining programme actually offers — and where New Zealand's NZ golden visa holds a genuine edge.

The Closed Programmes: What Happened and Why

Australia — Significant Investor Visa (Closed 31 July 2024)

Australia's SIV was the programme most similar to New Zealand's AIP: a substantial investment in complying funds, moderate presence requirements, pathway to permanent residency. It was enormously popular with Chinese investors, processing hundreds of applications annually. The Albanese government's decision to close it on 31 July 2024 — citing limited economic benefit and programme integrity concerns — sent thousands of prospective applicants scrambling for alternatives.

Many landed on New Zealand. And for good reason: once AIP holders progress to NZ citizenship (approximately 5–8 years from investment), they gain the right to live and work in Australia indefinitely under the Trans-Tasman Travel Arrangement — making the NZ Active Investor Plus visa effectively a pathway into the Australian market. We've had multiple clients tell us they initially wanted Australia and only discovered the Trans-Tasman route after the SIV closure.

United Kingdom — Tier 1 Investor (Closed February 2022)

The UK programme required GBP 2 million in listed securities and demanded 185 days per year of physical presence — heavy by any standard. It was closed amid concerns about Russian oligarch money and broader anti-money-laundering failures. A Transparency International report had described it as a "welcome mat for dirty money." The closure was politically inevitable.

Spain — Golden Visa (Closed April 2025)

Spain's EUR 500K property-based programme was among Europe's most popular, attracting buyers primarily from China, Russia, and the Middle East. Barcelona and Madrid's overheated housing markets made the programme politically toxic. Prime Minister Sanchez's decision to close it was framed explicitly as a housing affordability measure. Sound familiar? New Zealand faced the same tension — and resolved it with the NZ$5M luxury property threshold rather than a blanket closure.

The Remaining Programmes: Programme-by-Programme Analysis

US EB-5: Powerful but Painful

The EB-5 is the oldest investment immigration programme of its kind, and on paper it's the cheapest: US$800,000 in a Targeted Employment Area or US$1.05 million elsewhere. It also requires the creation of 10 permanent jobs.

So why isn't everyone doing EB-5? Processing backlogs. Chinese nationals face wait times of 10-15+ years due to per-country visa caps. Indian nationals are now hitting similar backlogs. The programme also requires physical residence in the United States and subjects green card holders to worldwide taxation on all global income. For a wealthy international investor who wants optionality rather than relocation, the EB-5 is a poor fit.

New Zealand's Growth category requires more capital (NZ$5M / ~US$3M vs US$800K) but delivers residency faster, demands only 21 days of presence, and operates under a territorial tax system with significant exemptions for new residents. The total cost of ownership — factoring in US worldwide taxation — often makes NZ the better financial proposition despite the higher upfront investment.

Portugal Golden Visa: Europe's Survivor

Portugal's programme has been reshaped beyond recognition. The 2023 reforms eliminated real estate as a qualifying investment, killing the programme's most popular pathway. What remains is investment in venture capital funds (EUR 500K), research activities (EUR 500K), or cultural production (EUR 250K).

The presence requirement is minimal — roughly 7 days per year — and the path to EU citizenship takes 5 years, which is genuinely attractive. But the programme now has a reputation for uncertainty. Applicants worry about further restrictions. Processing times have stretched. And Portugal's venture capital ecosystem, while growing, lacks the institutional depth of established markets.

Portugal offers access to the EU and Schengen zone — a major advantage for investors wanting European mobility. But for those who prioritise English-speaking jurisdictions, common law, and an established fund management ecosystem, New Zealand's Active Investor Plus visa has structural advantages Portugal cannot match.

Hungary Guest Investor: The Unknown Quantity

Hungary launched its Guest Investor Visa in 2024 with three pathways: EUR 250K in a government-approved fund, EUR 500K in residential property, or EUR 1M in a donation to a higher education institution. Presence requirements are minimal, and the programme offers Schengen access.

The programme is new and unproven. Hungary's political direction under Orban raises questions about programme stability and EU relations. Henley & Partners and other industry consultancies have flagged concerns about due diligence standards. For risk-conscious investors, Hungary represents a bet on a programme that may or may not mature into something reliable.

Why the Active Investor Plus Visa Stands Apart

Strip away the marketing language and evaluate each programme on the metrics that actually matter to a UHNW investor. New Zealand's NZ golden visa wins on an unusual combination of factors that no single competitor can match:

1. Trans-Tasman Access — The Hidden Multiplier

No other investment migration programme offers a clear pathway to two countries. Once AIP holders obtain NZ citizenship (approximately 5–8 years from investment), they can live and work in Australia indefinitely under the Trans-Tasman Travel Arrangement. With Australia's own programme closed, the NZ AIP is the only investment route that leads to the Australian market. Period. For anyone who wanted Australia — and thousands did — this is the play.

2. English-Speaking Common Law — The Last One Standing

The UK is closed. Australia is closed. The US demands relocation and worldwide taxation. New Zealand is the only significant English-speaking common law country offering a pure investment-for-residency pathway with minimal presence requirements. For investors from Hong Kong, Singapore, the UAE, and indeed the United States, this matters enormously.

3. Programme Maturity and Track Record

635 applications. NZ$3.73 billion (~US$2.2B) committed (as of March 2026). 237 approved. The Active Investor Plus visa is not theoretical — it's processing applications, approving residency, and deploying capital. Prospective applicants can evaluate the programme based on real data, not promises. Compare that to Hungary's untested programme or Portugal's recently gutted one.

4. A 183-Country Passport

New Zealand citizenship, available approximately 5-8 years after AIP approval (including investment term and subsequent residency requirements), provides one of the world's strongest passports. NZ citizens can travel visa-free to 183 countries. For investors from countries with weaker passports — China, India, the Middle East — this is a transformative upgrade in global mobility.

5. Property Rights Restored

Since March 2026, AIP holders can purchase one luxury residential property at NZ$5M or above. This was the last major gap in New Zealand's offering. Portugal doesn't allow real estate investment. The US EB-5 has no property restrictions but demands you actually live there. New Zealand's approach — one prestige property, no occupancy requirement — hits the sweet spot for investors who want a home without being tied to it.

The Strategic Picture for 2026

The global golden visa market has contracted sharply, and that contraction benefits New Zealand disproportionately. When Australia, the UK, and Spain were all open, NZ was one option among many — and not always the most obvious one. Now it stands in a category of its own: the premier English-speaking, common-law investment migration destination with minimal presence requirements and a pathway to dual-country access via NZ citizenship.

Will this last? Perhaps not forever. If application volumes continue at their current pace, MBIE may raise thresholds, introduce caps, or tighten eligibility. History — as we've documented in our analysis of the AIP's policy evolution — shows that this government adjusts settings based on data. And 635 applications in ten months is a lot of data to act on.

For investors evaluating their options today, the comparison is unusually clear. The field has narrowed. The remaining programmes each have significant limitations. And New Zealand's Active Investor Plus visa, through a combination of smart policy design and fortunate timing, has emerged as the most complete offering available. The full visa comparison on our site breaks down the categories in detail.