The investment criterion is often the first of the seven settlement criteria founders think they have covered. Many Innovator Founder businesses raise money or put in their own savings early on. But the wording asks for more than having money. It asks for at least £50,000 invested and actively spent furthering the business, and it does not reward larger sums with extra credit.
This article looks at criterion (i) from the settlement section of the Home Office caseworker guidance "Innovator Founder" version 11.0 (4 August 2026). It covers the two parts of the test, why the "counts once" rule matters, how the team rule may apply, and how to keep records that make the figure easy for your endorsing body to confirm.
The two parts of the test
| Part | What it means in practice |
|---|---|
| Invested | At least £50,000 has gone into the business |
| Actively spent furthering the business | That money has been used on the business, not left idle or used for unrelated purposes |
The guidance does not, as summarised here, list approved categories of spending. The phrase "furthering the business" points to spending connected to building the business you were endorsed for. Spending that clearly advances the plan your endorsing body assessed is the easiest to explain.
Invested is not the same as spent
Consider two hypothetical founders.
- Founder A raised £60,000 in year one and has spent £55,000 of it on product development, marketing and staff costs by the time of the settlement assessment.
- Founder B raised £150,000 in year three, and most of it is still in the business account when the settlement letter is requested.
Founder A's position is easier to present under criterion (i), because the money has been both invested and spent. Founder B has the larger raise but may be able to show less actually spent. Unspent funds are not wasted, though: they may support the separate confirmation that the business is sustainable for at least the next 12 months. See the 12-month sustainability test.
Why £100,000 still counts once
The guidance is direct: the same criterion cannot be counted twice, and £100,000 invested is one criterion. Raising more does not substitute for a second criterion.
That matters for planning. A founder who expects to rely on investment should decide early which other criterion will sit alongside it:
| Second criterion | Why it may fit with investment |
|---|---|
| (ii) Customers doubled and above comparable UK mean | Spending on sales and marketing may drive customer growth |
| (iii) Significant R&D and UK IP application | Spending on research is common in technical businesses |
| (iv) or (v) Revenue thresholds | If spending has produced revenue at the required level |
| (vi) or (vii) Jobs for settled workers | If spending has gone on qualifying roles |
Each has its own detailed article: customers, R&D and IP, revenue and exports, and jobs.
Teams: the same money, two applicants
The guidance says team members applying for settlement cannot share the same means. Its worked example uses jobs: two applicants relying on the 10-jobs criterion need 20 jobs. If you and a co-founder are both on the route and both expect to rely on investment, raise this with your endorsing body early. Do not assume one £50,000 round can carry two settlement applications. See Innovator Founder teams and individual endorsements.
Records that make the figure checkable
The endorsing body must be satisfied before it confirms the criterion in your settlement letter. Records that typically make that easier:
- Bank statements showing the money arriving in the business
- Share issue or loan documents, where relevant
- Management accounts or a spending summary showing what the money was used for
- A short note linking the spending to milestones in your business plan
Where the money came from also matters at other stages. For first endorsements after 13 April 2023, the endorsement letter must confirm there are no concerns over the legitimacy of the sources of funds invested or how they were transferred. Clean records from the start help at every stage. See source of funds checks.
Common planning mistakes
A few patterns make criterion (i) harder than it needs to be:
- Counting the raise, not the spend. The figure that matters is what has been invested and actively spent, not the size of the round announced.
- Mixing personal and business money. If founder funds pass through personal accounts or are spent on mixed purposes, it becomes harder to show the money furthered the business.
- Leaving the second criterion to chance. Because investment counts once however large, a founder who raises well but has no second criterion in sight still has a gap.
- Spending everything. Spending heavily to clear £50,000 can leave the business short for the separate 12-month sustainability confirmation. Model both together.
The rest of the settlement letter
Meeting criterion (i) is one part of the settlement case. The letter must also confirm significant achievements against the business plan in your previous endorsement, Companies House registration with you as a director or member, active trading, sustainability for at least the next 12 months, and your active key role in day-to-day management. Use the full settlement checklist to make sure nothing is missing, and note that the letter must be no more than three months old when you apply.
Sources and further reading
- GOV.UK — Innovator Founder caseworker guidance
- GOV.UK — Indefinite leave to remain: Innovator Founder visa
- GOV.UK — Immigration Rules Appendix Innovator Founder
Key takeaways
- Criterion (i) needs at least £50,000 invested and actively spent furthering the business.
- Unspent money is not the test, though it may support the separate sustainability confirmation.
- £100,000 invested is still one criterion; plan a second, different criterion.
- Co-founders cannot share the same means, so check how your endorsing body treats shared investment.
- Keep spending records tagged from day one so the figure is easy to evidence three years later.
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