The inner workings of post-accreditation checks, suspension, and revocation

• Post-accreditation checks are routine, not investigations. INZ checks around 15% of accredited employers each year, and roughly 90% close out with no further action required.
• End-to-end check timelines run up to ~2 months, depending on where in the process the employer is contacted and which external agencies INZ is coordinating with.
• Revocation is a consequence, not a punishment. Liquidation drives most revocations, but ~23% relate to employer non-compliance and ~8% to the Immigration Infringement Stand-Down List.
• Highest-risk sectors for non-compliance are hospitality and accommodation (24%), construction (18%), and agriculture (9%).
• Migrant exploitation indicators include cash wages, cashback schemes, premium payments to obtain or keep a job, underpayment of leave, excessive hours (often 60+ when paid for 30 to 40), passport confiscation, and visa-related threats.
• Exploitation risk profile tends towards small and medium businesses, employers hiring workers of their own nationality or shared language/religion, and the construction, horticulture, retail, hospitality, cleaning, and transport industries.
• Infringement offences have scaled up rapidly, with over 300 issued since April 2024 and prosecutions before the courts up from around 6 a few years ago to about 40 today.
• Suspension is not a PPI process. Employers are notified via their portal once an immigration manager approves the suspension, but they are not necessarily invited to comment beforehand.
• Role inflation and deflation both attract scrutiny. Job-checking an electrician but using the migrant as a labourer (or vice versa) can trigger revocation or infringement action.
• Multi-region roles are acceptable provided the multi-locational nature is articulated clearly at the job check stage. MSD checks focus on the predominant region.
• Employers must notify INZ within 10 working days when an AEWV holder leaves employment. A one-off missed notification is low-level non-compliance, but patterns escalate it.
• Practitioners should expect closing communication from verification officers when a check clears. The panel acknowledged this is not happening consistently and committed to addressing it.

Immigration New Zealand recently joined our members for a roundtable webinar covering the full compliance lifecycle for accredited employers, from post-accreditation checks through to suspension, revocation, infringements, and prosecution. The panel brought together senior INZ leaders from Risk and Verification, Revocations, Immigration Investigations, and Visa Operations.

Below is a structured summary of the discussion and the practical takeaways for advisers and employers operating in the AEWV space.

1. The compliance cycle, why most employers never notice it

INZ frames accredited employer compliance as a continuous cycle, from initial accreditation, through job check, post-decision checks, and re-accreditation. The deliberate design choice is to keep upfront information requests light, trust that most employers are doing the right thing, and rely on evidence employers already generate in the ordinary course of business (IRD filings, employment records, etc.).

• Around 15% of accredited employers are subject to a post-accreditation check each year.
• Approximately 90% of those checks close with no further action.
• Many checks happen entirely behind the scenes. INZ doesn’t always need to contact the employer, drawing instead on internal records and inter-agency data.

A critical distinction the panel drew is that post-accreditation checks are not investigations. They are carried out by verification officers as a routine integrity measure, not by criminal investigators, and being checked does not imply INZ has concerns.

2. How long does a post-accreditation check take

The Risk and Verification lead provided a ballpark figure of up to two months end-to-end, with significant variability depending on the following.

• Where in the check the employer is being contacted (early-stage with little to go on, versus late-stage to fill gaps).
• Which external agencies INZ is coordinating with, including councils, regulators, and IRD.
• The industry and role types involved.

A common practitioner frustration raised on the call was the absence of closing communication when a check clears. The panel acknowledged this should be standard practice and committed to looking into why it isn’t happening consistently across teams.

3. Suspension, what triggers it and how it works

Suspension is used when INZ needs more time to verify or investigate and is not confident the employer should continue recruiting migrant workers in the interim. Key procedural points include the following.

• Suspension is not a PPI process. Once approved by an immigration manager, it can be actioned without first inviting employer comment.
• The employer is notified via their employer portal when the status changes.
• Suspension is not punitive. It is a holding measure to manage risk while verification continues.

4. Revocation, what the numbers show

The Revocations team lead broke down what they see in revocation cases.

• Liquidation drives the largest share of revocations.
• 23% of cases relate to general employer non-compliance.
• 8% of cases relate to the Immigration Infringement Stand-Down List.

Non-compliance typically involves migrants being paid less than visa conditions stipulate, working in unauthorised locations, or performing duties they aren’t permitted to do. Industry concentration is striking.

• Hospitality and accommodation, 24% of non-compliance cases.
• Construction, 18%.
• Agriculture, 9%.

An emerging trend is that employers declare on their application that they will meet a particular obligation (for example, MSD good-faith engagement), only for post-decision checks to find that the commitment wasn’t followed through. This pattern alone has resulted in revocations.

The Revocations lead stressed that revocation is “not a punitive or penal measure” but a consequence of failing to meet accreditation requirements, and that PPI responses with sufficient information do regularly result in INZ stepping back from revocation.

5. Migrant exploitation, what INZ looks for

The Investigations practice leader walked through the indicators his team prioritises. Exploitation is 34% of Immigration Investigations’ current caseload, by far the largest category.

Wage and hour indicators

• Cash wages and cashback schemes.
• Migrants paying to obtain or keep a job.
• Promised pay not being received.
• Leave and public holiday underpayment.
• Migrants being paid for 30 to 40 hours while working 60+ per week.
• Work outside visa conditions, including prostitution and drug manufacturing.

Control and coercion indicators

• Passport confiscation.
• Visa-status leverage.
• Threats and violence.

Risk profile

• Small and medium-sized businesses (rarely large business).
• Employers hiring workers of the same nationality, language, or religious affiliation.
• High-risk industries are construction, horticulture, retail, hospitality, cleaning, and transport.

How complaints reach INZ

• Employment Services Exploitation Line (phone or web form).
• INZ’s online web form.
• Crime Stoppers.
• Direct contact with an INZ staff member.

Complaints are triaged by Employment Services, which determines whether the migrant needs a Migrant Exploitation Protection Visa support letter and routes the substantive complaint to the right team, usually the Labour Inspectorate or Immigration Investigations.

6. Infringements and prosecutions, the sharper end

Since infringement offences were introduced in April 2024, INZ has issued over 300 infringements. The Investigations lead described infringements as a particularly useful tool for employers who are starting to break the rules at a small scale but where more serious offending can’t yet be proven. The stand-down list consequences alone create meaningful deterrence.

On prosecutions, a few years ago INZ had around 6 prosecutions in train. That figure now sits at roughly 40 before or about to be before the courts. INZ is deliberately publicising successful prosecutions to encourage further complainants and victims to come forward.

A bill currently before Parliament proposes adding two further infringement offences and amending the timeframes for issuing infringements.

7. Job check consistency and employment agreements

The Director of Visa addressed practitioner concerns about inconsistent treatment of employment agreements at the work visa stage. Following last year’s job check redesign, individual employment agreements are no longer assessed at job check. They are examined at the work visa decision, with the focus on consistency between the agreement and the job check terms (salary, conditions, hours).

He acknowledged that with a large operation, some inconsistency is inevitable, but emphasised the following.

• Immigration officers exercise discretion based on individual circumstances, and are encouraged to do so.
• If practitioners are seeing inconsistent outcomes for the same employment agreement across multiple job tokens, this should be fed back through engagement channels.
• INZ sometimes gets pulled into checking employment-law compliance of agreements, which can drive requests for amendments where legislation has moved on.

8. Role substitution, what crosses the line

Whether a worker is doing the job described in the job check is now a standard focus of post-decision checks. The panel distinguished between the following.

• Role inflation, for example job-checking an electrician but using the migrant as a labourer. This often signals an attempt to evade the test for available New Zealanders or secure a longer visa, and can trigger revocation or infringement.
• Role deflation, bringing a migrant in on a lower-paid advertised role while actually using them for higher-skilled (and higher-paying) work. Also a significant concern.
• Genuine variability within a role, for example movement between similar labourer-type duties, which generally falls below the threshold for action.

The Investigations lead added that in construction specifically, the more common issues are migrants working in the wrong location, working for the wrong employer, or being placed in triangular employment arrangements their visa doesn’t permit.

9. Multi-region roles

For genuinely multi-locational roles (Visa Pack 591 territory), the key is articulating the multi-regional nature clearly at the job check stage.

• If the job check makes the multi-region requirement clear, that becomes the benchmark for the work visa assessment.
• MSD checks focus on the predominant region from which the role is based.
• If short-term project work in another region evolves into a long-term commitment, employers should return to the job check process to re-test New Zealand availability for that location.

10. Employer notification obligations

Employers must notify INZ within 10 working days when an AEWV holder leaves employment. Notifications flow to a central team and are routed depending on whether the migrant remains in New Zealand.

• If the migrant has left New Zealand, visa cancellation follows.
• If the migrant is still onshore, INZ follows up to confirm new employment, a variation application, or compliance with visa conditions.

A one-off missed notification (“we thought you’d know”) is treated as low-level non-compliance, usually a reminder rather than an enforcement event. But where it sits alongside a broader pattern of non-compliance, it can contribute to escalating action.

For non-AEWV visa types (e.g. SPVs, partnership work visas), notifications aren’t a legal obligation but INZ does still consume the information to understand worker movement.

11. The dairy sector “live on farm” issue

A specific question covered the recent change preventing job adverts from requiring migrants to live on-farm, on the basis that such a requirement excludes nearby New Zealand candidates. The Director of Visa’s response covered the following.

• Employers cannot make on-farm residence a compulsory condition of the role.
• The legitimate underlying need (ready access to the worker at various times) can still be reflected in the job description.
• Accommodation deductions only become relevant if the employee actually takes up on-farm accommodation. They are not deducted from the outset.

Practical action points for practitioners and employers

• Treat post-accreditation checks as routine. Respond promptly and completely, but don’t assume INZ has concerns.
• If you provide information for a check and hear nothing back, follow up. Closing confirmation should happen, even if it currently isn’t consistent.
• Document multi-regional work requirements clearly at job check, including the predominant region.
• Make sure the work the migrant actually performs aligns with the job-checked role. Role inflation and deflation both attract scrutiny.
• Build in a process to meet the 10-working-day notification requirement for AEWV departures.
• Where you see inconsistent decisions on the same employment agreement across job tokens, feed it back through the established engagement channels.
• Watch for sector-specific risk concentration, particularly hospitality, construction, and agriculture, and tighten internal compliance where you operate in these areas.

Closing thought

The consistent thread across the session was INZ’s graduated and proportionate philosophy. Most employers are doing the right thing, most checks close uneventfully, and education comes before enforcement for low-level non-compliance. But where significant concerns emerge, particularly around migrant exploitation or deliberate misrepresentation of roles, the toolkit (suspension, revocation, infringement, prosecution) is being used more actively than ever, with prosecutions now sitting around 40 cases and infringements past 300.