Immigration New Zealand (INZ) has introduced a temporary manual process for situations where a business is sold or restructured and Accredited Employer Work Visa (AEWV) holders need to transfer to the new employer. This change primarily affects employers, who must now complete a manual Job Check application for each AEWV worker. INZ has confirmed that no Job Check fee will be charged, and employers will not be required to re-advertise the role as part of this temporary process. However, the new process may cause businesses significant disruption in the way it will operate.

AEWV holders are also impacted, as their visa records will not update correctly unless employers follow this process - something that could affect their work rights or future visa applications.

Why INZ introduced the temporary manual process

In October 2025, INZ announced an interim change to the way AEWV holders are transitioned between employers following a business sale or restructure.

The change addresses a system limitation that affects how AEWV holders are linked to employers in INZ’s system. Until a permanent fix is implemented, affected employers will need to follow a temporary manual process to ensure records remain accurate and compliant.

When INZ introduced the updated AEWV framework in November 2024, visa holders could apply for a Job Change if they remained in the same role and location during a business sale or restructure. In those cases, the new employer did not need to complete a Job Check.

However, INZ has identified a technical limitation preventing its system from automatically creating or updating “job tokens” - the digital record that connects an AEWV holder to their accredited employer. Without this connection, it is difficult to maintain accurate visa and employment data in the Immigration Online platform.

The changes

To address this issue, INZ has introduced a temporary manual process to manage transitions during sales or restructures.

Under this temporary arrangement:

• Employers (or their immigration lawyer) must submit a new Job Check application for each AEWV holder transferring to them.
  
• INZ will waive the Job Check fee, and employers do not need to advertise the role.
  
• INZ will contact affected employers directly and provide detailed guidance on how to complete the process.

 This process ensures that:

• AEWV holders are properly linked to their new employer in the Immigration Online system, with a valid Job Check associated to their role;
• Employers’ records remain accurate for accreditation purposes; and
• Visa holders can continue to apply for the remaining balance of their maximum continuous stay.

 INZ has confirmed that a long-term system fix is under development and expected to be rolled out in 2026. Once implemented, this should remove the need for manual Job Check applications in these scenarios.

What employers need to know

Employers involved in a business sale or restructure that includes AEWV holders should be aware that this process is entirely employer-driven. INZ will not provide directions or prompt employers, as it has no visibility of upcoming sales, transfers, or restructures. The responsibility to identify affected AEWV holders and begin the manual Job Check process rests entirely with the new employer and their lawyers.

Key Actions for Employers:

• Identify all AEWV holders early in the sale or restructuring process and assess how many Job Checks will be required.
• Prepare to submit manual Job Check applications immediately once the transfer legally occurs. INZ has stated that applications should not be submitted in advance — a requirement that may create practical delays.
• Work closely with your immigration lawyer, as timing and sequencing will be critical to avoid unintended gaps in work rights.
• Review commercial and operational contingencies, including potential staffing shortages.

Commercial risks and staffing impact

One of the most significant issues with this interim process, and one that employers must plan for, is that AEWV workers will be unable to work while the Job Check and Variation of Condition processes take place.

Because INZ requires the transfer to be completed before a Job Check is lodged, and the Job Check to be lodged before the Variation of Change is lodged, and given current processing timeframes:

• AEWV holders will be unable to legally work during the gap. Until the Variation of Conditions is granted, their visa will bind them to the former employer, who is no longer operating the business;
• businesses losing key staff at a crucial time in the transition;
• operational disruption, particularly in sectors reliant on migrant labour;
• increased costs from having to temporarily reallocate staff or reduce services.

This is widely viewed as an oversight in INZ’s interim design, as it creates unnecessary downtime for both employers and employees during what is often a commercially sensitive period.

A heavier burden on businesses

It is also important to note that this process replaces a previous temporary workaround, but shifts more administrative burden onto employers.

While the fee waiver and removal of advertising requirements offer some relief, the reality is that this change:

• reduces INZ’s workload;
• increases administrative time and compliance effort for employers;
• introduces uncertain processing timeframes at a moment when continuity of employment is essential; and
• adds cost and complexity during an already demanding restructuring or acquisition process.

This temporary approach does allow employers to maintain compliance, but it comes with significant commercial and immigration implications. Employers should begin planning early, identify risks well ahead of the transfer date, and ensure their immigration and commercial lawyers are aligned so that delays, gaps in work rights, and operational disruption are minimised.

If you would like tailored advice on how this change may affect your business or your AEWV workers, please contact our Immigration or Employment law team to discuss your specific situation further.

‍