Employer accreditation and AEWV

staying compliant and audit-ready

If you hire migrants, employer accreditation is basically your licence to operate – and Immigration New Zealand (INZ) is checking who deserves to keep that licence.

As at 30 September 2025, there are around 25,800 accredited employers and more than 82,000 AEWV holders. INZ aims to run post-accreditation checks on about 16% of accredited employers each year, and more than 1,000 employers have already had their accreditation revoked, with another 570 suspended. In other words, this is not a theoretical risk.

This article is about how to stay on the “boringly compliant” list.

1. What AEWV accreditation actually commits you to

Under the AEWV scheme there are three steps – employer accreditation, a Job Check, and then the migrant’s visa application. You must be accredited before supporting an AEWV, and you must pass a Job Check before the worker can apply.

You choose a level of accreditation based on your model and headcount –

• Standard – up to 5 migrants.
• High-volume – 6 or more.
• Triangular – you’re the legal employer but you place migrants with third parties.

Initial accreditation is usually 12 months; you then renew, again for 12-month periods.

Accreditation is not “set and forget”. You’re signing up to ongoing checks on your business viability, how you treat migrants, and whether your key people are fit and proper.

2. What INZ looks for in post-accreditation checks

INZ can run a desk-based review or a site visit at any time while you’re accredited. You might be chosen randomly, targeted as part of a risk sample, checked because you use triangular models, or reviewed after a complaint.

They’ll usually focus on five big questions.

a) Are you a viable, genuinely operating business?

You may be asked for –

• GST or PAYE records showing your IRD number.
• Financial statements demonstrating you are viable – e.g. no loss over two years, or positive cashflow over six months, or evidence of capital/funding, or a credible two-year plan.

If your business is on life support, your accreditation is too.

b) Do you have the right accreditation, and is it current?

INZ checks that –

• Your accreditation type (standard, high-volume, triangular) matches your actual hiring pattern.
• You’ve renewed on time, and not quietly drifted into using more migrants than your level really suits.

If you change your model – for example, you start placing staff with third parties – you’re expected to change accreditation type, not just carry on and hope no one notices.

c) Are your key people “clean”?

INZ can ask for evidence that your directors, owners and HR/immigration decision-makers –

• Aren’t on immigration or employment stand-down lists.
• Have no relevant breaches or outstanding cases.
• Have consented to information being shared.

You must also tell INZ within 10 working days if key people change.

d) Are you a responsible employer?

This is where a lot of audits are won or lost. INZ may ask for –

• Visa status checks and a record of how you track visa expiries and remind staff.
• Proof you’re honouring visa conditions, including minimum/maximum hours and any sector rules.
• Employment agreements, wage, PAYE, hours and leave records.
• Health & safety training records, risk and accident registers.
• Complaints records and how you resolved them.

From 7 April 2024, new AEWVs come with a condition that migrants must be offered at least 30 hours’ work a week, and INZ can revoke accreditation if employers don’t deliver that. So your rostering and payroll data need to line up.

e) Are you helping migrants settle?

You’re required to give AEWV workers settlement information within their first month – for example about rights, services and support – and INZ can ask to see what you provided.

If you’re a triangular employer or franchisee, there are extra expectations – monitoring work conditions at third-party sites, keeping detailed placement records, and in some cases ensuring that at least 15% of staff are New Zealanders working 30+ hours.

3. The Worker Protection Act – why record-keeping suddenly got a lot more serious

From January 2024, the Worker Protection (Migrant and Other Employees) Act tightened both employment and immigration law. Key points –

• If a Labour Inspector requires records, and you can’t produce them immediately, you must supply them within 10 working days. Failing to do so is now an infringement offence with $1,000 per offence, up to $20,000 in three months.
• The Immigration Act now includes infringement offences for – letting someone work when they’re not entitled to, employing them outside their visa conditions, and failing to supply documents within 10 working days.
• MBIE can publish the names of non-compliant employers on a stand-down list, making you ineligible to support further visas for a period.

In my view, the direction of travel is clear – “I’ll get those records together when someone asks” is no longer acceptable. You need to be able to hit print (or export) almost on demand.

4. Being audit-ready in practice

Think of accreditation compliance like a WOF – you don’t just tidy the car on the way to the testing station; you maintain it so there are no surprises.

Here’s a simple, pragmatic setup.

Step 1 – Build a live AEWV register

Maintain a single source of truth (spreadsheet or HR system) that captures, for every migrant –

• Full name, role, location, visa type and number.
• Visa start and expiry dates; hours and key conditions.
• Accreditation type and Job Check reference for their role.

Link that register to VisaView checks and set up automated reminders 6, 3 and 1 month before each visa expiry. INZ explicitly looks for evidence that you monitor visas and remind workers.

Step 2 – Standardise onboarding and settlement support

For all AEWV hires, use a consistent onboarding pack that includes –

• Template employment agreement and job description aligned with what you put in the Job Check.
• A settlement information sheet covering rights, services, and complaint channels.
• An induction checklist including health & safety, hours, pay cycle and who to ask for help.

Save a PDF copy of whatever you give each worker – it’s ideal audit evidence.

Make sure your onboarding explains any AEWV-specific conditions – including the 30-hour minimum and any sector or wage settings that apply to that role.

Step 3 – Create an “AEWV file” for each worker

Whether physical or digital, each file should hold at least –

• Copy of the visa and passport ID page.
• Signed employment agreement and job description.
• Evidence of pay and hours that matches the visa conditions (and sector agreement rates where relevant).
• Records of leave and public holidays.
• Any complaints or performance processes and how they were handled.

That file means you can respond to both INZ post-accreditation checks and any Worker Protection Act request without a scramble.

Step 4 – Run an internal “mock audit” once a year

At least annually –

• Pick a sample of migrant workers and walk through their files as if you were an INZ officer.
• Confirm your business-viability evidence is up to date (financials, tax records).
• Check your register against reality – anyone left? Any role changes that need a Job Change application?
• For triangular or franchise models, confirm you’ve got third-party site visit notes, complaint logs and proof of NZ staff ratios where required.

Given INZ is checking thousands of employers and has already revoked or suspended hundreds, assuming “we’ll never be picked” is, in my opinion, optimistic.

Step 5 – Give AEWV a home in your governance

Finally, make AEWV compliance visible –

• Nominate an AEWV lead (could be HR, finance or operations) and back them with time and budget.
• Add a short AEWV status line to quarterly board/owner reports – accreditation dates, upcoming renewals, and any INZ contact.
• Keep an eye on policy tweaks – median wage removal, experience thresholds, and the new National Occupation List from November 2025 all affect how you design roles.

Handled well, accreditation becomes more than a box-ticking exercise. It’s a way to prove – to INZ, to your workforce and to the market – that you run a viable business, treat people properly, and take your obligations seriously. And that’s the kind of reputation you actually want turning up in a Google search.

The Last Word Remember, Immigration Law is as simple or as complex as Employment Law. However you view it, the best advice is always to have a very well qualified support system to keep you out of trouble, keep your valuable workers exactly where you want and need them and new recruits arriving without drama. Neazor Brady have been providing such sure-footed support for decades now and are willing and able to support all your immigration needs.