How long do you have to respond to a PPI letter?

There is no fixed statutory timeframe for responding to an INZ PPI letter: the response date is set by the immigration officer in the letter itself. Around two weeks is common in practice. Miss it and INZ may decide the application on the information it already holds.

There is no universal number to memorise, which is exactly what makes the question dangerous. The only reliable source of truth is the letter in front of you, read on the day it arrives.

Key facts

What is a PPI letter and why does INZ send one?

A PPI letter tells the applicant that the immigration officer holds information which may count against the application, and invites comment before a decision is made. It exists because of fairness and natural justice, not because of a specific section of the Immigration Act 2009. Every current PPI instruction opens with the same sentence.

The definitions differ by category and by where the applicant is. Under E7.15, for a temporary entry class visa applicant outside New Zealand, PPI is factual information or material that was not obtained from the applicant or their agent, is not publicly available or that the applicant is not necessarily aware of, will or may adversely affect the outcome, and that the applicant has not previously had an opportunity to comment on. For an applicant in New Zealand the test is much wider: information that will or may adversely affect the outcome, full stop. E7.15 also spells out that an “agent” includes licensed immigration advisers and lawyers, which matters twice: information you supplied is not PPI for an offshore applicant, and the letter comes to you.

How long do you actually get to respond?

However long the letter says. Immigration instructions set no number. A1.5 Fairness frames it as whether “the applicant is given a reasonable opportunity to respond to harmful information”, and adds that how much fairness is owed “depends on the circumstances of the application, and the consequences of the decision for the applicant”.

INZ’s guidance to officers says the same thing operationally. VisaPak 201 (6 March 2015) instructs officers to identify which part of the instructions they consider has not been met, how it has not been met, and what the outcome may be, to supply a copy of the relevant instruction, and to give “a reasonable timeframe” that is “appropriate to the applicant’s circumstances”. VisaPak 604 (1 November 2024) reminds officers to “use standard timeframes in the first instance when setting a response date”, but those standard timeframes are internal and are not published in the manual.

Around two weeks is the common experience. In TQ v Gibson the letter issued on 26 February 2021 with a response date of 12 March 2021, a fortnight, and Auckland immigration lawyer Paul Janssen writes that “generally INZ will issue a two week time-line to reply”. Shorter dates appear where INZ considers the document should already have been supplied. Treat two weeks as a planning assumption, never as the deadline.

Worth keeping the distinction between an RFI and a PPI in mind. Janssen notes that missing an RFI date “is not a reason for them to decline the application (they would have to send you a PPI as per below first)”, whereas on a PPI, “if you do not respond or at least request a deadline extension, INZ can decide the application based on what they have”.

What happens if you miss the response date?

INZ decides on what it has. That is not a theoretical risk. In TQ v Gibson, the adviser overlooked the letter. On 17 March 2021, five days after the response date, INZ emailed to say there had been no response and that “the residence application would be assessed based on the information on the file”. The adviser replied that day saying the letter had been missed and asked for more time. The extension was declined at 1.39pm, although the officer said she would accept further information that day. Nothing came, and the application was declined on 19 March 2021. The client learned of it on 12 April by ringing INZ himself, and asked to be allowed to send the documents requested on 26 February. INZ replied that the decision was final.

There is a second, subtler failure mode. In XX v Xu [2023] NZIACDT 12 the adviser did respond, but the letter of 24 March 2022 raised two concerns with a student visa application, a medical issue and whether the applicant was a genuine student. The adviser addressed only the medical issue. The application was declined and the client became unlawful. The Tribunal recorded the adviser’s own admission of a lack of diligence and due care, and upheld a breach of clause 1. Answering on time is not enough. You must answer every concern raised.

How do you ask INZ for an extension, and will you get one?

Ask early, ask in writing, and give a reason with evidence behind it. VisaPak 604 tells officers that a request “should be considered on its merits”, that they “must be satisfied that there is a genuine reason for the request”, and that where appropriate the applicant “should include supporting evidence to show the steps taken to gather information to respond, the reason for delays, or evidence to show that they have requested the documents”.

The same VisaPak lists what officers weigh against you: whether the document was mandatory at lodgement or is genuinely new, whether INZ has already said publicly that it should be provided up front, whether sufficient time has already been given in the form of a PPI, whether RFI letters have already sought the same information, and whether the information is readily and easily obtainable.

On length, “up to five additional working days is generally considered to be a reasonable extension timeframe in most circumstances”. Anything longer “may be considered and granted on a case-by-case basis for compelling and relevant circumstances”, with the officer recommended to discuss it with a technical adviser or immigration manager. The document is explicit that “the discretion to grant an extension to a response date lies with the immigration officer and an approval may not be guaranteed”. Where one is granted, a fresh PPI letter with the new response date should be issued.

One trap worth knowing. VisaPak 201 addresses the tactic of filing a Privacy Act or Official Information Act request and asking for the PPI date to be pushed out to match it. INZ’s position is that it “is not expected that immigration officers will grant extensions” on that basis, “as the applicant is required to provide comment only on the issues raised in the PPI letter”. Your PPI date will not wait for the 20 working days INZ has to answer the access request.

What should a PPI response actually contain?

The substance of any PPI response is immigration advice, and that is a matter for the licensed adviser or lawyer with carriage of the file. What follows is structure, not advice on what to argue.

What do you do when the client is overseas or slow to respond?

Start the clock on your side the day the letter lands, not the day the client replies. The gap between the two is where files are lost.

Send the letter to the client the same day, with the response date in the subject line. TQ v Gibson is a clause 26(b) case as much as a clause 1 case: the client never saw the PPI letter, and the Tribunal found separate breaches for the failure to make timely updates.

Set your internal date before the INZ date. If INZ has given you until the 12th, your file should be complete by the 8th. Time zones, courier delays and a translator’s turnaround eat the buffer, not the deadline.

Ask for the extension before the date passes, not after. Gibson’s request came five days late and was refused the same afternoon. A request lodged inside the window, with evidence of the steps already taken to gather the documents, is the situation VisaPak 604 describes.

If the client cannot be reached, document the attempts and take instructions on whether to file a partial response. A partial response addressing what can be evidenced is a decision you have made with the client; silence is a decision INZ makes without you.

Is a missed PPI window a Code of Conduct problem as well as a client problem?

Yes. Clause 1 of the Code of Conduct 2014 requires an adviser to “be honest, professional, diligent and respectful and conduct themselves with due care and in a timely manner”. In TQ v Gibson the Tribunal put it plainly: “The failure to reply to the PPI letter shows a lack of professionalism, diligence and due care.” The adviser had bought the business weeks earlier and was the only person in it. The Tribunal accepted the workload as “a plausible reason” but not “a justification for her failure to attend to the complainant’s matter”, adding: “As a professional, she is responsible for regulating her workflow so all work can be attended to with diligence and due care.”

The published outcome, in TQ v Gibson (Sanctions) [2022] NZIACDT 23, was a caution, $1,000 to the Registrar and $2,000 to the complainant, on top of a refund the adviser had already made. In XX v Xu (Sanctions) [2023] NZIACDT 18 it was a caution, $1,000 to the Registrar and $4,893 to the complainant. Both decisions sit on justice.govt.nz with the adviser named, permanently.

Neither adviser was dishonest. Both were busy, and in Xu’s case the Tribunal was told she was “an experienced and generally conscientious adviser”. That is the uncomfortable point: this is a workflow failure, and workflow failures are the ones a system of record can help you see coming. Clerq is built around that idea, with every matter carrying dated deadlines and a named owner, and PPI responses drafted and versioned on the matter itself (what it does). It will not draft your argument or make the call for you, and no software prevents a complaint. It does mean an unanswered PPI date is visible to somebody before INZ has to point it out.

Frequently asked questions

Is there a legal minimum time to respond to a PPI letter? No. Neither the Immigration Act 2009 nor immigration instructions set a number of days. A1.5 Fairness requires that the applicant be given a reasonable opportunity to respond to harmful information, and says how much fairness is owed depends on the circumstances of the application and the consequences of the decision for the applicant. The officer sets the actual date in the letter.

Can you get an extension to a PPI response date? Sometimes. VisaPak 604 of 1 November 2024 tells officers that a request should be considered on its merits, that they must be satisfied there is a genuine reason for the request, and that up to five additional working days is generally considered to be a reasonable extension timeframe in most circumstances. The discretion lies with the immigration officer and an approval may not be guaranteed.

Does asking INZ for the file under the Privacy Act pause the PPI clock? No, and you should not plan on it. VisaPak 201 of 6 March 2015 says it is not expected that immigration officers will grant extensions to the PPI timeframe on the basis that information requested under the Privacy Act or Official Information Act will assist in providing comment, because the applicant is required to provide comment only on the issues raised in the PPI letter.

What happens if nobody replies by the response date? INZ may assess the application on the information already on the file. In TQ v Gibson the response date was 12 March 2021, INZ emailed the adviser on 17 March 2021 to say the application would be assessed on the file, an extension was declined the same day, and the residence application was declined on 19 March 2021.

Is missing a PPI response date a Code of Conduct breach? It can be. In TQ v Gibson [2022] NZIACDT 18 the Tribunal held that the failure to reply to the PPI letter showed a lack of professionalism, diligence and due care and breached clause 1. Workload was accepted as a plausible reason but not a justification: a professional is responsible for regulating her workflow so all work can be attended to with diligence and due care.

Does the PPI letter go to the adviser or to the client? In practice INZ corresponds with the adviser named on the file. In TQ v Gibson the PPI letter was emailed to the adviser on 26 February 2021 and the client did not learn of it until 12 April 2021, after the decline. The Tribunal found breaches of clause 1 and clause 26(b) for the failure to keep the client updated.

Sources

• INZ Operational Manual, A1.5 Fairness, effective 29/05/2025. Checked 10 August 2026.
• INZ Operational Manual, A1.15 Practical steps towards achieving fairness and natural justice in decision-making, effective 29/05/2025. Checked 10 August 2026.
• INZ Operational Manual, E7.15 Potentially prejudicial information, effective 25/09/2023. Checked 10 August 2026.
• INZ Operational Manual, BB3.20 Potentially prejudicial information, effective 23/12/2019. Checked 10 August 2026.
• INZ Operational Manual, BD2.35 Potentially prejudicial information, effective 24/11/2025. Checked 10 August 2026.
• VisaPak 604: Response date extensions for potentially prejudicial information letters and requests for information related to accredited employer processing, 1 November 2024. Checked 10 August 2026.
• VisaPak 201: Privacy Act and Official Information Act requests in response to potentially prejudicial information letters, 6 March 2015. Checked 10 August 2026.
• TQ v Gibson [2022] NZIACDT 18, 25 July 2022. Checked 10 August 2026.
• TQ v Gibson (Sanctions) [2022] NZIACDT 23, 7 September 2022. Checked 10 August 2026.
• XX v Xu [2023] NZIACDT 12, 13 April 2023. Checked 10 August 2026.
• XX v Xu (Sanctions) [2023] NZIACDT 18, 1 June 2023. Checked 10 August 2026.
• Licensed Immigration Advisers Code of Conduct 2014, Immigration Advisers Authority. Checked 10 August 2026.
• INZ, How to appeal a residence class visa decision. Checked 10 August 2026.
• Office of the Privacy Commissioner, Principle 6: Access to personal information. Checked 10 August 2026.
• Turner Hopkins, “RFI’s, PPI’s and Deadlines!”, Paul Janssen (secondary source, used only for the observed two-week norm). Checked 10 August 2026.