The New CIES: Hong Kong Investment Residency from HK$30 Million — Thresholds, Permissible Assets, Obligations and the Route to Permanent Residence

The New Capital Investment Entrant Scheme is Hong Kong’s investor entry route, open for applications since 1 March 2024. The threshold is HK$30 million: at least HK$27 million in permissible assets and a mandatory HK$3 million into the CIES Investment Portfolio managed by the Hong Kong Investment Corporation. The scheme does not confer permanent residence on entry — it grants a limited period of stay, and the right of abode arises no earlier than seven years later.

Three things most coverage gets wrong.

One: the increase in the aggregate real estate cap from HK$10 million to HK$15 million does not reach residential property. NOTE (8) to the Scheme Rules says so outright: the aggregate cap is raised to HK$15 million, “among which the cap on residential real estate remains at HK$10 million”, and the price floor for a single residential transaction falls from HK$50 million to HK$30 million. Paragraph 102 of the Chief Executive’s 2025 Policy Address adds a material detail the Rules omit: the increase was made “for the purchase of non-residential properties with no transaction price threshold”. The change took effect on 17 September 2025 and applies by reference to the date of completion of the purchase. The reason commentary gets this wrong is not that the rule is buried — it is stated twice in the Rules — but that the Policy Address highlights page mentions only the cut in the price floor from HK$50 million to HK$30 million.

Two: the accountant’s report under this scheme is not an audit and not an assurance engagement. The HKICPA circular classifies the work expressly as an agreed-upon procedures engagement under HKSRS 4400 (Revised), and states: “An agreed-upon procedures engagement is not an audit, review or other assurance engagement.” The practitioner reports factual findings; no opinion is expressed.

Three: the mandatory HK$3 million in the CIES Investment Portfolio is locked for seven years, and no operational exit process has been published. The clock runs from the start date of the annual capital batch rather than from the date of your own payment: 1 January 2025 for the 2024 batch and 1 January 2026 for the 2025 batch. A right of exit does exist in the Rules, but it is a qualified one: paragraph 5.3 provides that “after expiry of the applicable lock-up period, and subject to paragraph 5.3.1 below, the invested amount may be withdrawn by or distributed to the Applicant/Entrant subject to the terms of the CIES IP”, and warns that the timing “may depend on market liquidity and strategy of fund managers”. Paragraph 5.3.1 is the qualification that matters: “Capital preservation and dividends are not guaranteed, and distribution may be made on a discretionary basis at appropriate junctures.” The Hong Kong Investment Corporation publishes neither fee terms, nor a valuation methodology, nor a redemption procedure, and the earliest possible redemption is 1 January 2032, so no track record of getting the money back exists.

The Legal Framework: an Administrative Scheme, Not a Statute

The New CIES is not a statutory scheme: it is constituted by neither an ordinance nor subsidiary legislation. Entry is effected under the Director of Immigration’s general powers in the Immigration Ordinance (Cap. 115), and the Scheme Rules are an administrative document issued by InvestHK and the Immigration Department.

The scheme was announced in paragraph 57(iv) of the 2023 Policy Address, its parameters were published by the Government on 19 December 2023, and applications opened on 1 March 2024. None of those steps involved publication of an instrument in the Gazette. The Scheme Rules cite no enabling provision and describe themselves as a document to be given a “fair, large and liberal interpretation” so as to attain the objects of the scheme. That is the language of policy, not of legislation. The practical consequence is that the Rules change by administrative decision, without a legislative process and without a transitional period — and the changes reach applications already lodged, a point the notes to the Rules make expressly with the formula “also applicable to applications submitted preceding this date unless specified otherwise”.

Layer	Instrument	What it governs
1. Statutory	Immigration Ordinance (Cap. 115)	The general powers to grant visas, permission to stay, extensions and the right of abode
2. Statutory, fees	Immigration Regulations — the New CIES is listed among the “specified schemes”	Application and visa issue fees
3. Admi­nistra­tive, principal	Rules for the New Capital Investment Entrant Scheme, as amended to 1 March 2026	Thresholds, permissible assets, the net asset requirement, procedure, portfolio maintenance obligations
4. Admi­nistra­tive, reporting	HKICPA circular on reporting under Rules 4.2, 4.4, 4.6 and 6.2, version as at 8 May 2026	What the practising accountant must do and what the supporting documents must contain
5. Operational	Hong Kong Investment Corporation Limitedannouncements on the annual capital batches of the CIES Investment Portfolio	Managers, lock-up periods, batch sizes

The division of labour between the four bodies is strict, and they must not be conflated.

•          The New CIES Office within InvestHK assesses the Net Asset Requirement, the Investment Requirements and the continuing Portfolio Maintenance Requirements, and issues the certifying proofs.

•          The Immigration Department (Director of Immigration) grants Approval-in-Principle, Formal Approval, visas and entry permits, extensions of stay and unconditional stay.

•          The Financial Services and the Treasury Bureau is the policy bureau; the 2026-27 Estimates describe InvestHK’s task as to “continue to implement FSTB’s New Capital Investment Entrant Scheme jointly with the Immigration Department”.

•          The Hong Kong Investment Corporation Limited sets up and oversees the CIES Investment Portfolio.

The scheme’s amendment chronology runs to eleven links, the last dated 1 March 2026.

Date	What happened	In force from
2023-24 Budget (February 2023)	A new scheme announced	—
2023 Policy Address, para 57(iv)	HK$30 million threshold, real estate excluded	—
19 December 2023	The Government publishes the scheme parameters	—
1 March 2024	The scheme opens for appli­catio­ns	1 March 2024
16 September 2024	Online application platform launched	16 September 2024
16 October 2024— 2024 Policy Address	Residential property admitted for the first time: a single transaction of HK$50 million or more, aggregate real estate cap HK$10 million	16 October 2024, by date of completion
2024 Policy Address	The private holding company route introduced — NOTE (7) attributes this measure to the Policy Address, not to the January 2025 press release	1 March 2025
11 November 2024	The Hong Kong Investment Corporation announces the operational details of the CIES Investment Portfolio; NOTE (7) incorporates them into the Rules without stating a commencement date	—
7 January 2025	Net asset holding period cut from two years to six months; jointly held family assets count	1 March 2025
17 September 2025 — 2025 Policy Address, para 102	Aggregate real estate cap raised to HK$15 million for no­n-reside­ntial property with no price threshold; residential remains capped at HK$10 million, with the price floor cut from HK$50 million to HK$30 million	17 September 2025, by date of completion
1 March 2026	The conditions for a private holding company updated: in the wording of the Government’s family office portal, an applicant may use a company “which has been set up in less than six months … without a minimum incorporation period”	1 March 2026

The HK$30 million headline threshold has never changed since launch. What has changed is the composition of permissible assets, the net asset test and the real estate rules. Author’s assessment: holding the entry price steady through four rounds of loosening at the edges is a deliberate signal — the government is widening access without discounting the ticket.

A note on source access. The primary text here is the Scheme Rules together with NOTES (1) to (9) appended to them: it is the notes that record which change belongs to which date and which announcement introduced it. The legco.gov.hk portal is closed to automated retrieval because of a broken TLS certificate chain, so no Legislative Council panel papers were used; every material fact here is confirmed from the full text of the Policy Address, the Scheme Rules, the newcies.gov.hk and immd.gov.hk pages, and press releases on info.gov.hk. Where no official source exists, this analysis says so.

Who May Apply, and Who May Not

The scheme is open to four categories: foreign nationals; Chinese nationals who have obtained permanent resident status in a foreign country; residents of the Macao Special Administrative Region; and Chinese residents of Taiwan. Mainland-resident PRC nationals cannot use it.

Paragraph 2.1(b) of the Scheme Rules lists the categories verbatim: “(i) foreign nationals; (ii) Chinese nationals who have obtained permanent resident status in a foreign country; (iii) Macao Special Administrative Region residents; and (iv) Chinese residents of Taiwan”.

This is the scheme’s most under-appreciated restriction. A PRC national without permanent residence abroad falls outside it, whatever the size of the capital. Author’s assessment: it is precisely why official commentary describes the applicant map as “Europe, the United States, Singapore, and other regions” rather than as a flow from the Mainland. Hong Kong permanent residents are outside the scheme by definition — they need no residency.

Three countries are excluded expressly. The footnote to “foreign nationals” in the Scheme Rules: “Nationals of Afghanistan, Cuba, and Democratic People’s Republic of Korea are excluded. The list of excluded countries/regions will be reviewed by the Security Bureau/ImmD from time to time. Stateless persons who have obtained permanent resident status in a foreign country with proven re-entry facilities will be eligible under the Scheme.”

The exclusion list is not permanently closed — the Scheme Rules expressly contemplate its review by the Security Bureau and the Immigration Department. The Rules contain no other provision on nationals of states Hong Kong does not recognise.

Personal requirements.

Requirement	Wording
Age	“an Applicant is aged 18 or above at the time of applying for Net Asset Assessment”
Immigration history	“no adverse immigration record and meets normal immigration and security requirements”
Financial self-su­fficie­ncy	able to support and accommodate himself and his dependants “without relying on any return on the Permissible investment assets, employment, self-e­mploy­ment, office, business or public assistance in or carried on in Hong Kong as the case may be”

There is no separate clear-criminal-record criterion in the admission tests. Paragraph 2.1(e) contains a single composite formula — “no adverse immigration record and meets normal immigration and security requirements” — and that is what is assessed. The “clear criminal record” wording familiar from the General Employment Policy, the Top Talent Pass Scheme and other Immigration Department schemes does not appear in the New CIES Rules. That is no relaxation in practice, since security vetting applies here too — but quoting another scheme’s criterion as though it belonged to this one is wrong.

The self-sufficiency requirement is read carelessly, it is demanding, and its boundary is precise. The applicant must show that he supports himself and his family without drawing on the returns from the scheme investment, and without employment, self-employment, office, business or public assistance — with paragraph 2.1(f) confining that list to Hong Kong in the words “in or carried on in Hong Kong as the case may be” before going on to add that “the entry of dependants will be subject to any other policy applicable to such entry at the time”. The practical consequence: the scheme assumes an independent source of funds outside Hong Kong over and above the HK$30 million locked into the portfolio. A “move over and live off the yield on the invested sum” model contradicts the Rules on their face. On the natural distributive reading of “in or carried on in Hong Kong as the case may be”, income from a business carried on in another jurisdiction does not offend the criterion — though no official source states that expressly, and this reading is the author’s construction of the wording.

The scheme does not prohibit working in Hong Kong, but it is not a work visa either. Permission to stay is granted “on time limitation only” — that is, without conditions restricting employment. The ability to work does not, however, displace the requirement to demonstrate financial self-sufficiency at the point of application without reliance on Hong Kong earnings — and there is no contradiction between the two precisely because the criterion is confined to Hong Kong sources.

If the objective is employment or running an operating business rather than deploying capital, this is almost certainly the wrong instrument. Hong Kong maintains separate routes: the General Employment Policy, the Top Talent Pass Scheme, the Quality Migrant Admission Scheme and the entrepreneur route. Their thresholds and comparison are set out in Work Visas and Immigration to Hong Kong for Entrepreneurs 2026, and the residence and permanent-residence requirements in Hong Kong Work and Relocation Visas 2026.

What the HK$30 Million Threshold Is Made Of

The threshold has two mandatory components: at least HK$27 million in permissible financial assets and/or real estate, and exactly HK$3 million into the CIES Investment Portfolio. The second is not optional and cannot be substituted by the first.

The Scheme Rules put it in terms: “An Applicant must make investment of a minimum of HK$30 million Net (or equivalent in foreign currencies) in the Permissible investment assets.” Paragraph 5.1 then reads: “The Applicant/Entrant must invest a minimum of HK$27 million in any of the following Permissible financial assets and/or real estate.” And paragraph 5.3: “each Applicant/Entrant under the Scheme is required to place HK$3 million into the CIES IP.”

Component	Amount	Flexibility
Permissible financial assets and/or real estate	at least HK$30,000,000 − HK$3,000,000 = HK$27,000,000	Composition chosen by the applicant, within the list and the sub-caps
CIES Investment Portfolio	exactly HK$3,000,000	Mandatory; composition not chosen; managed by the Hong Kong Investment Corporation
Of which real estate	no more than HK$15,000,000 in aggregate	Of which residential no more than HK$10,000,000
Of which certificates of deposit	no more than HK$3,000,000	A 10 per cent sub-cap on the threshold
Of which private OFCs and private LPFs combined	no more than HK$10,000,000	A single sub-cap across two classes

The word “Net” in the threshold is a technical term and is defined in the Scheme Rules: “the figure in Hong Kong dollars after deducting the amount of any and every charge, lien or encumbrance which may be secured on or attached to that asset, property or equity”. The practical consequence: a charged asset counts only to the extent it is unencumbered.

Acquisition costs do not count towards the threshold. The official guidance is unqualified: “All fees, charges, commissions, stamp duties, taxes, levies and all other expenses incurred during the process of acquiring, disposing or realising the Permissible investment assets shall not be counted as committed investment.” The consequence for the budget: stamp duty on share and property purchases, brokerage commissions and legal costs are paid on top of the HK$30 million, not out of it. The rates and mechanics of stamp duty on share transfers are set out in Stamp Duty on Share Transfers in Hong Kong 2026.

Investments count only from the scheme’s launch date. Anything acquired before 1 March 2024 falls outside the scheme in all circumstances.

Paragraph 2.1(d) of the Scheme Rules offers three alternative windows for making the investment, and the choice between them drives the whole transaction logistics. The paragraph opens with a proviso — “Subject to paragraph 5.1(c) on investment in certificates of deposits” — which matters and is dealt with immediately below the table:

Option	Window opens	Window closes
(i) Investment already made	the scheme launch date or the 180th day before the net asset assessment application, whichever is later	the day the net asset assessment application is lodged
(ii) Mixed	the same start	the 180th day after Approva­l-in-Pri­nciple is granted
(iii) Investment after approval	the day Approva­l-in-Pri­nciple is granted	the 180th day thereafter

Certificates of deposit are carved out of the choice altogether. Paragraph 2.1(d) closes with an express exception: “if the Applicant/Entrant chooses to invest in them for the purpose of qualifying under the Scheme, he must do so within the period beginning on the day when Approval-in-Principle has been granted by DoI and ending on the 180th day thereafter, and thereafter be absolutely beneficially entitled to them throughout the term of the invested certificates of deposits”. Practical consequence: the carve-out is about when a deposit may be bought, not about which option the rest of the portfolio uses. It defeats option (i) entirely, because that window closes before Approval-in-Principle is granted. It defeats only the earlier part of option (ii), whose window also runs to the 180th day after Approval-in-Principle. Deposits bought before Approval-in-Principle count for nothing — and once bought they must be held to maturity.

Option (iii) is the only one that avoids putting capital at risk before Approval-in-Principle, and in most cases it is the rational choice. Option (i) requires the assets to sit in a compliant configuration before the application is even lodged — market risk taken with no assurance of approval. Author’s assessment: a “buy first, apply later” sequence is defensible only where the compliant portfolio already exists for independent reasons rather than being assembled for the scheme.

Ring-fencing: the investment that secured entry is set apart within the scheme. Paragraph 7.2 of the Scheme Rules says that, apart from the redemption of a mortgage, Surplus Equity and cash dividend, interest and rental income, “the Applicant/Entrant is not allowed to withdraw or remove any appreciation from his Permissible investment assets under the Scheme even if the subsequent Market value of those assets rises above the requisite minimum level of HK$30 million Net” — in other words the qualifying investment “will be ring-fenced within the Scheme”. The rule is about what may leave the portfolio, not about what else the assets may be used for: the Rules say nothing about whether the same assets could support an application under some other programme.

Which Financial Assets Are Permissible

The list of permissible financial assets is closed: it operates by exhaustive inclusion. An asset not named in paragraph 5.1 of the Scheme Rules falls outside the scheme — the Rules contain no list of prohibited assets at all.

Asset class	Requirements	Sub-cap
(a) Equities	Shares of companies listed on the Stock Exchange of Hong Kong and traded in Hong Kong dollars or renminbi	none
(b) Debt securities	Debt securities listed on the SEHK and traded in HKD or RMB; or denominated in HKD or RMB and issued or fully guaranteed by the Government, the Exchange Fund, specified government and statutory bodies, or listed companies	none
(c) Certificates of deposit	Denominated in HKD or RMB, issued by authorised insti­tutio­ns, with a remaining term to maturity of not less than 12 months at acquisition; may be bought only in the “Appro­val-in-Pri­nciple plus 180 days” window and must be held for their whole term	HK$3,000,000— 10 per cent of the threshold
(d) Subordinated debt	Denominated in HKD or RMB, issued by authorised institutions, complying with Schedules 4B and 4C to the Banking (Capital) Rules	none
(e) Collective investment schemes	Four sub-classes — see below	none for the public ones
(f) Interests in LPFs	Ownership interests in limited partnership funds registered under the Limited Partnership Fund Ordinance (Cap. 637)	HK$10,000,000jointly with private OFCs under (e)(iv)

Sub-paragraph (e) — collective investment schemes — breaks into four items, each tied to a specific regulatory status:

•          (i) funds authorised by the SFC, managed by corporations licensed by or institutions registered with the SFC for Type 9 regulated activity;

•          (ii) REITs authorised by the SFC and managed by the same persons;

•          (iii) Investment-Linked Assurance Schemes authorised by the SFC and issued by insurers permitted to carry on Class C business under Part 2 of Schedule 1 to the Insurance Ordinance (Cap. 41);

•          (iv) open-ended fund companies registered under the Securities and Futures Ordinance (Cap. 571) and managed by Type 9 licensees.

Exactly one kind of insurance product qualifies — an SFC-authorised ILAS. Conventional whole-of-life, endowment and universal life policies are not permissible assets. The practical test for any insurance product marketed as “CIES-eligible” is a single question: is it an authorised ILAS issued by an insurer permitted to carry on Class C business?

Currency and venue are the second most common ground of rejection. Equities and debt securities must be listed on the Stock Exchange of Hong Kong and traded in HKD or RMB. Securities listed in New York or London, and USD-denominated instruments generally, fall outside sub-paragraphs (a) and (b). Author’s assessment: this is not a technicality but the design objective — the capital is meant to work inside the Hong Kong market, not merely to be owned by the person receiving the visa.

What is absent from the list — and this follows from omission, not from prohibition. Foreign equities, USD-denominated instruments, overseas real estate, bare land, art, commodities and crypto assets fall outside the scheme because they are not named, not because they are expressly barred. This analysis does not assert an express prohibition: the Rules are drafted as an exhaustive list of what is allowed.

OFCs and LPFs are precisely the two Hong Kong fund regimes through which private capital enters the scheme.Their structure, manager requirements and comparison are analysed in Hong Kong Fund Structures in 2026: the OFC and the LPF.

The combined HK$10 million sub-cap on private OFCs and private LPFs is the key constraint for anyone planning to enter through their own structures. Paragraph 5.1(f) states it directly: “The total investment amount of ownership interest in private LPFs in this paragraph and private OFCs in paragraph 5.1(e)(iv) above is subject to an aggregate cap of HK$10 million.” The consequence: the threshold cannot be filled with private fund structures alone — at least HK$17 million must sit in public instruments, real estate or other permissible classes.

Financial assets must be held in a designated account with a financial intermediary. The requirement sits in the opening limb of paragraph 6.1(a) of the Scheme Rules and in sub-item (i), which stipulates that the account must be in the applicant’s name or that of a Holding Company; sub-item (ii) is not the requirement itself but the list of eligible intermediary categories. The mechanics are analysed below; the requirement does not extend to real estate or to the CIES Investment Portfolio.

Real Estate: How Much Counts, and What Changed on 17 September 2025

Real estate counts towards the threshold up to an aggregate of HK$15 million, of which residential property accounts for no more than HK$10 million. Residential property counts only where a single property is purchased for HK$30 million or more.

Paragraph 5.2 of the Scheme Rules states the rule verbatim: “The total investment amount in real estate in paragraph 5.2(a) AND (b) below which is counted towards the fulfillment of minimum investment threshold is subject to an aggregate cap of HK$15 million, of which the investment in residential real estate is capped at HK$10 million.”

Type	What counts	Cap	Single­-transa­ction price floor
No­n-reside­ntial — commercial and/or industrial, including pre­-comple­tion properties: offices, commercial and retail premises, factories. Land and multi-purpose property partly for residential use are excluded	Within the aggregate	Within the aggregate HK$15,000,000	none
Re­side­ntial — including pre­-comple­tion property and multi-purpose property partly for residential use	One property only	HK$10,000,000	HK$30,000,000and above

Here lies the error that runs through almost all coverage: the increase from HK$10 million to HK$15 million applies to non-residential property, not to real estate generally. Paragraph 102 of the 2025 Policy Address: “raising the maximum amount of investment to be counted from $10 million to $15 million for the purchase of non-residential properties with no transaction price threshold; as for the purchase of residential properties, the investment to be counted will continue to be capped at $10 million, but the transaction price threshold will be lowered from $50 million to $30 million.” The practical consequence: an investor buying a residential property for HK$40 million counts HK$10 million towards the threshold, not HK$15 million — the additional HK$5 million is available only through non-residential property.

The transitional rule attaches to the date of completion of the purchase, not to the date of the contract, and it is split across two footnotes. Footnote 13 to the Scheme Rules governs the aggregate cap: for real estate — non-residential and residential alike — completed before 17 September 2025, the aggregate cap remains HK$10 million. Footnote 15 governs the residential price: where completion falls before 17 September 2025, the investment must still be made in one single property with a transaction price of HK$50 million or above. The completion date is the sole trigger; there is no separate commencement instrument, and the day the Policy Address was delivered serves as the effective date.

Residential property was not admissible at all before 16 October 2024. The requirement survives in the current text: “The date of completion of the purchase of the residential property should be on or after 16 October 2024.” A property bought earlier counts for nothing — even if it is in Hong Kong and even if it cost more than HK$30 million.

What does not constitute real estate for the scheme. Paragraph 5.2 excludes expressly: “illegal or unlawful use or occupation of land, and boats, houseboats, trailers, caravans, illegal structures and cocklofts whether or not rated, connected to mains water or power supplies, or on permanent or fixed moorings or foundations”.

Holding and valuation mechanics.

•          The property is held in the applicant’s own name, through a sole proprietorship in his name, or through a company of which he is the sole shareholder, including a Holding Company.

•          No financial intermediary is required for real estate — the designated account requirement applies to financial assets only.

•          Evidence comprises Land Registry records, bank statements and, where required, a written valuation from a valuer registered with the Hong Kong Institute of Surveyors.

•          A mortgage is permitted, but only the equity counts: “An Applicant/Entrant/Holding Company may take out a mortgage loan with a bank or financial institution licensed in Hong Kong in respect of the real estate but only the amount of equity is counted.”

•          Rental income stays with the investor: “Rental income from the real estate can be paid and retained by the Applicant/Entrant/Holding Company.”

The concept of Surplus Equity allows the excess over the counted amount to be extracted. The Scheme Rules define it as “the excess or surplus over the Net equity which is attributable to Applicant’s/Entrant’s equity in the real estate at the date of purchase that will be available to the Applicant/Entrant to make use of thereafter as he wishes without loss of entitlement under the Scheme”. The practical consequence: appreciation above the equity fixed at the purchase date is not locked — unlike appreciation on financial assets.

Whether the investor may live in the property he buys is not addressed by the Scheme Rules. There is neither permission nor prohibition. This analysis does not resolve the point and recommends confirming it with the New CIES Office on the specific transaction.

> The official statistics show that the real estate concessions are barely being used. As at the end of February 2025 the government stated expressly that no applicant had invested in residential real estate under the scheme. In the breakdown of verified investment as at 28 February 2026, real estate is not itemised: five lines are financial assets and the CIES Investment Portfolio, and the sixth is a residual “Other” at 3.2 per cent. A year earlier the breakdown was finer and non-residential real estate did appear in it — the Government’s reply of 26 March 2025 shows it at HK$18 million, against HK$5,171 million in collective investment schemes and HK$3,570 million in equities. Author’s assessment: two rounds of loosening — October 2024 and September 2025 — have produced close to no response on the published data, and the most plausible explanation is that the HK$10 million residential cap is too small relative to the price of a property that qualifies for it.

The CIES Investment Portfolio: the Mandatory HK$3 Million We Know Least About

The CIES Investment Portfolio is a mandatory HK$3 million component of the threshold, set up and overseen by the Hong Kong Investment Corporation Limited. The money is locked for seven years, capital preservation and distributions are not guaranteed, and no exit process has been published.

Paragraph 5.3 of the Scheme Rules sets out the mandate: the portfolio exists to “make investments bringing contribution to the long-term development of Hong Kong’s economy and society by accelerating the exploration and strategic planning of cutting-edge growth drivers”.

Paragraph 5.3.1 is equally direct in removing any expectation of return: “Capital preservation and dividends are not guaranteed, and distribution may be made on a discretionary basis at appropriate junctures subject to factors such as the pace and mix of the construction and realisation of the CIES IP.”

The portfolio is assembled in annual capital batches, and the lock-up attaches to the batch, not to the date any individual investor pays in.

Batch	Announced	Portfolio life	Managers	Expected size
2024 batch	11 November 2024; managers on 30 December 2024	seven years from 1 January 2025	four: Betatron Venture Group, Inno Angel Fund, MindWorks Capital, Radiant Tech Ventures	at least HK$300 million by end-2024; minimum HK$50 million per fund; venture capital focus
2025 batch	31 October 2025; managers on 2 December 2025	seven years from 1 January 2026	ten: Abax Global Capital, Beyond Ventures, CMC Capital, FirstLight Capital, Hidden Hill Capital, M Capital, Polymer Capital, Primavera Capital, Trustar Capital / CITIC Capital with Vision Capital Investment Management, Value Partners	at least HK$2 billion as announced; minimum HK$200 million per mandate; public markets and private equity
2026 batch	not announcedas at 24 August 2026	—	—	—

The requirements on these managers are the same ones that govern the rest of Hong Kong’s collective investment industry: an SFC licence and a fund vehicle constituted under local law — the mechanics of the OFC and the LPF through which such funds are formed are set out in Hong Kong Fund Structures in 2026: the OFC and the LPF.

BOCI-Prudential Trustee Limited is the administrator of both batches. The 2025 manager selection criteria: Hong Kong headquarters, key leadership and the majority of staff in Hong Kong, an SFC Type 9 licence, at least two years of operating history and at least HK$200 million of assets under management; capital to be deployed within two years of the fund’s establishment.

The lock-up attaches to the batch, and that creates an inequality between investors. An applicant who paid HK$3 million in mid-2025 falls into a batch whose life begins on 1 January 2026 — his money is locked longer than that of someone who paid in December 2024. The Hong Kong Investment Corporation does not publish the rule by which investors are assigned to batches.

What is not disclosed at all — and this should be said plainly.

Item	Disclosure status
Fees	Not published. The 2025 invitation for proposals asks managers to state the management fee, admi­nistra­tive and partnership expenses, carried interest, hurdle rate and performance fee — so fee terms exist and are negotiated with each manager, but the investor is never told what they are
Valuation methodology and NAV	Not published. The only commitment is that managers “compile consolidated reports regarding the progress on a regular basis”; the frequency is undefined
Redemption mechanism	Stated in principle, unspecified in practice. Paragraph 5.3 provides that after the lock-up expires the sum “may be withdrawn by or distributed to” the investor, and warns that timing “may depend on market liquidity and strategy of fund managers”; no procedure, no notice period, no secondary transfer provision and no extension language have been published
Loss allocation	Not addressed
The rule assigning an investor to a batch	Not published

There is no redemption track record by construction: the earliest date is 1 January 2032. As at August 2026 no participant has yet exited the CIES Investment Portfolio, and no experience of getting the money back exists. Author’s assessment: the mandatory HK$3 million should be modelled as a contribution whose return is contractually contemplated but operationally unspecified, not as an investment with a known liquidity profile. It is 10 per cent of the threshold — material but not decisive — and that is precisely why the statistics show that nobody puts in more than the minimum.

The official breakdown corroborates this indirectly. As at 28 February 2026 verified investment under the scheme was HK$55,636 million, of which the CIES Investment Portfolio accounted for HK$5,511 million — 9.9 per cent. The mandatory ratio of HK$3 million to HK$30 million is exactly 10.0 per cent. What can and cannot be inferred from that. Writing the portfolio line as 3N + x and the other classes as 27N + y, where x and y are the amounts contributed above each minimum, a share below 10 per cent means simply that y exceeds nine times x. So the figures show that excess investment in the other classes outweighs any excess in the portfolio by a wide margin; they do not prove that nobody contributes more than HK$3 million to the portfolio. **Two further cautions: the Government footnotes the portfolio line “*Including capital pending deployment”, and HK$5,511 million divided by HK$3 million gives 1,837 against 1,762 approvals, so the two columns are not counting an identical population.**

The 2025 batch began deploying in the first quarter of 2026 — officially, more than HK$3 billion has gone into artificial intelligence applications, sustainable technologies, materials science and biotechnology. Note the distinction: HK$2 billion is the batch size the Hong Kong Investment Corporation announced in October 2025, while the HK$3 billion is the amount deployed in the first quarter of 2026 as reported on 2 March 2026. The two figures are often conflated.

The Net Asset Test and the Role of the Practising Accountant

The applicant must show beneficial entitlement to net assets of at least HK$30 million continuously throughout the six months preceding the application. The confirmation is prepared by a Certified Public Accountant (Practising) at the applicant’s cost — and it is not an audit.

The wording on the official eligibility page: “Net assets or Net equity … to which he is absolutely beneficially entitledwith a Market value of not less than HK$30 million Net (or equivalent in foreign currencies) … throughout the six months preceding the date he lodged his application.”

The anchor date is the same in every official source, and it is worth fixing precisely because it is easy to assume otherwise. Paragraph 2.1(c) of the Scheme Rules, the definition in paragraph 1.16, the eligibility page and the Guide on Preparation of Fulfillment Documents all use the same formula: “throughout the six months preceding the date he lodged his application for Net Asset Assessment”. The date the Fulfillment document is issued is not the anchor — it appears in the Rules only in the separate 14-day rule. Practical consequence: the six-month window closes on the day of filing, so an accountant’s engagement completed a fortnight earlier still has to speak to a period ending on the filing date.

The holding period has been more than halved. Until 1 March 2025 the requirement was two years. The change was announced on 7 January 2025 and took effect on 1 March 2025. The same change introduced credit for jointly held family assets — “for the respective portion which is absolutely beneficially entitled to the applicant”.

Who prepares the confirmation. Paragraphs 4.2 and 6.2 of the Scheme Rules require a Certified Public Accountant (Practising) within the meaning of the Accounting and Financial Reporting Council Ordinance, engaged at the applicant’s own cost. The output is the Fulfillment document.

The nature of that engagement is the most under-appreciated detail in the whole procedure.

The HKICPA circular on reporting under Rules 4.2, 4.4, 4.6 and 6.2 classifies the work as an agreed-upon procedures engagement and warns expressly: “An agreed-upon procedures engagement is not an audit, review or other assurance engagement”, and that such an engagement does not involve obtaining evidence for the purpose of expressing an opinion or assurance. The standard applied is Hong Kong Standard on Related Services 4400 (Revised), Agreed-upon Procedures Engagements.

What this means	Consequence
The accountant expresses no opinion	He reports the factual findings of the procedures performed
No assurance is given — neither reasonable nor limited	Respo­nsi­bility for the accuracy of the information stays with the applicant
Independence and ethics obligations still apply	The Code of Ethics for Professional Accountants and HKSQM 1 govern
The scope of procedures is agreed in advance	Departing from the agreed procedures changes what the report says

The practical consequence redistributes risk: the report under this scheme is not a guarantee that the assets meet the requirements. It confirms that specified procedures were performed and produced specified findings. Author’s assessment: an applicant who believes “the auditor has checked and confirmed it” has misunderstood the product he is paying for — which is why the quality of the underlying documentation on the applicant’s side determines the outcome, not the accountant’s signature.

A separate timing trap sits in the current version of the circular. The version dated 8 May 2026 carries its own commencement provision: “This updated Circular will be effective for agreed-upon procedures engagements for which the terms of engagement are agreed on or after 8 May 2027. Early adoption is permitted.” So as at August 2026 an engagement is governed by the previous version of the circular unless the practitioner has early-adopted the new one. The previous version is no longer posted and could not be compared page by page; this analysis does not attempt that comparison.

What the Fulfillment document must contain. It is the agreed-upon procedures report together with the relevant appendix — the Net Assets Statement under Rules 4.2 and 4.4, the Permissible Investment Assets Statement under Rule 4.6, or the Portfolio Maintenance Requirements Anniversary Statement under Rule 6.2 — plus the annexes recording the findings. The accountant signs the report as a whole, appendices included.

The annual statement requirements are set out in detail. The Anniversary Statement must show the permissible investment assets, supported by originals or copies certified true by the applicant, including “the quantity and value of permissible investment assets, the transaction price and amount of mortgage and surplus equity for real estate as at the start and the end dates of the relevant anniversary period as well as the details of all changes/transactions during the anniversary period”.

The deadline attached to the confirmation, and it applies twice. Paragraph 4.2 of the Scheme Rules: “No more than 14 calendar days may elapse between the date of issuance of the Fulfillment document and the date on which the Applicant lodges his application for Net Asset Assessment.” The same 14-day limit applies again at the investment stage: the official Guide on Preparation of Fulfillment Documents states that no more than 14 calendar days may elapse between issue of the Fulfillment document and the date the applicant lodges his application for assessment on investment requirements. Missing either means obtaining a fresh Fulfillment document — and paying the accountant again.

How the Procedure Works and How Long It Takes

The procedure has six stages and runs through two separate bodies: InvestHK assesses assets and investments, the Immigration Department grants approvals and visas. No stage is handled end-to-end by one body.

No.	Stage	Who conducts it	Output
1	Net Asset Assessment — verification of the net asset requirement	New CIES Office (InvestHK)	Certifying proof
2	Appro­val-in-Pri­nciple	Director of Immigration	A visa or entry permit on visitor status for not more than 180 days
3	Making the investment	The applicant	A portfolio of permissible assets
4	Investment Requirements Assessment	New CIES Office (InvestHK)	Certifying proof
5	Formal Approval	Director of Immigration	Permission to stay for not more than 24 months
6	Portfolio Maintenance Requirements Assessment — before each extension	New CIES Office (InvestHK)	Certifying proof for the extension

The deadlines set by the Rules, as distinct from practice.

Period	Provision	What it governs
14 calendar days	para 4.2	Between issue of the Fulfillment document and lodging the net asset assessment application
14 calendar days	Guide on Fulfillment Documents	Between issue of the Fulfillment document and lodging the application for assessment on investment requirements — the same limit applies again at stage four
180 days	para 2.1(d)	The window for making the investment after Approva­l-in-Pri­nciple
180 days	stage 2	The maximum visitor stay on the visa issued after Approva­l-in-Pri­nciple
24 months	stage 5	The initial period of stay after Formal Approval
not earlier than 3 months	para 4.10	Approaching the New CIES Office before the limit of stay expires
14 calendar days	para 4.12	The window to seek review of an unsuccessful assessment

The published processing times are stale and relate to a fundamentally smaller caseload. The only official statement is a Legislative Council reply of 12 June 2024: net asset assessment — “around three weeks”; Approval-in-Principle — “around three weeks”. No official time has ever been published for the Investment Requirements Assessment or for Formal Approval. The Immigration Department’s current page makes no commitment: “The actual processing time is subject to the specific circumstances of individual applications and the number of applications received at the time.” Author’s assessment: the three-week figure describes a period when some 250 applications had been received in total; by 28 February 2026 the cumulative figure was 3,166 — more than twelve times as many — so the 2024 number cannot be used for planning.

It should also be understood that the visitor visa at stage 2 is not a residence visa. It is issued so the applicant can enter and complete the investment; residence status arises only on Formal Approval at stage 5.

Review of an unsuccessful assessment. Paragraph 4.12 of the Scheme Rules allows 14 calendar days from the date of notification to seek a review. This is an administrative process within the scheme, not a judicial appeal.

The sequence of stages creates a structural risk worth keeping in view. Under option (iii) the investment is made after Approval-in-Principle but before Formal Approval. If at stage 4 the New CIES Office finds the portfolio configuration non-compliant, the capital is already deployed and residence status has not yet been granted. The practical response: agree the portfolio configuration with the New CIES Office before executing, not after — the scheme expressly invites contact and runs briefing webinars for prospective applicants and professional advisers.

Current organisational details. The New CIES Office is at 24/F Fairmont House, 8 Cotton Tree Drive, Central; telephone 3904 3001; email newcies@investhk.gov.hk. The online application platform has been live since 16 September 2024.

What Applying Costs: the Official Fees

The Immigration Department’s fees under the scheme are HK$600 per application and HK$1,300 for a visa valid for more than 180 days. The fees apply per person — to the principal applicant and to each dependant separately.

The current scale has applied since 11 a.m. on 26 February 2025, and the New CIES is listed among the “specified schemes” in the Immigration Regulations.

Item	Amount	Note
Application fee	HK$600	Per person, dependants included. No­n-refu­ndable in any circu­msta­nces, whatever the outcome
Visa or entry permit issue fee, relevant period over 180 days	HK$1,300	Applies to the 24-month permission
Visa or entry permit issue fee, relevant period 180 days or less	HK$600	Applies where a speci­fie­d-scheme visa is issued for a short period. It does not cover the visitor visa taken up after Approva­l-in-Pri­nciple, which is excluded from the speci­fie­d-scheme scale and charged at the ordinary rate of HK$330
Change of conditions or extension of stay, period over 180 days	HK$1,300	Applies to extensions of up to three years
Change of conditions or extension of stay, period 180 days or less	HK$600

The application fee is new, introduced in 2025, and it is non-refundable. Before 26 February 2025 there was no separate application fee at all, and a single flat visa issue fee was payable. The Government release of 26 February 2025 records the change verbatim: the fee “will be increased, based on the length of the limit of stay, from the original flat rate of $230 to $600 (with a limit of stay of 180 days or below) or $1,300”. The official wording on the current application fee is unambiguous: it is “non-refundable in any circumstances irrespective of the application result”.

Applications for unconditional stay and for a visit visa fall outside this scale — the specified-schemes list says so expressly, marking both New CIES entries “excluding the application for unconditional stay or visit visa”. This is why the 180-day visitor visa at stage three is charged at the ordinary HK$330 rather than at the specified-scheme rate, and why no HK$600 application fee attaches to it.

Costs the scheme creates but does not price.

Cost	Set by	Disclosure
Certified Public Accountant (Practising) fees	The market	Borne by the applicant “at his own cost” at each of three stages and annually after Formal Approval
Financial intermediary charges	The intermediary	Not regulated by the scheme
Stamp duty, brokerage and legal costs	Law and market	Expressly excluded from the threshold by the official guidance — “all fees, charges, commissions, stamp duties, taxes, levies and all other expenses … shall not be counted as committed investment”. The Scheme Rules themselves are silent on transaction costs
CIES Investment Portfolio fees	The Hong Kong Investment Corporation and its managers	Not published

The total cost of entry is driven not by the government fees, which are small, but by three other lines. The first is the annual accountant’s fee, because the agreed-upon procedures engagement repeats after every anniversary of Formal Approval for as long as participation lasts. The second is the transaction cost on HK$27 million, which does not count towards the threshold. The third is the undisclosed fee load inside the mandatory portfolio. Author’s assessment: the government fees are token — HK$5,700 for a family of three on the first cycle, being three application fees of HK$600 and three visa fees of HK$1,300 — and any cost model that stops there understates the real figure several times over.

No InvestHK charge is published on the official pages. No fee is stated for the net asset assessment, the investment requirements assessment or the annual portfolio maintenance assessment. Nor could an affirmative official statement be found that these services are free of charge, so this analysis puts no figure on them.

How Long the Stay Lasts and When Permanent Residence Arises

Formal Approval grants permission to stay for not more than 24 months; each subsequent extension is for not more than three years. The right to apply for permanent residence arises after seven years of ordinary residence in Hong Kong, not on approval.

The pattern is 2 + 3 + 3 and onwards. The Scheme Rules: “Permission to stay will normally be granted to the Applicant/Entrant and his dependants … for not more than 24 months on time limitation only, subject to the condition that the Applicant/Entrant continues to satisfy the requirements of the Scheme throughout this period”; and then “Extension of stay for not more than three years will normally be granted on the same conditions and on the same basis upon subsequent successful applications for extension of stay.”

“On time limitation only” means the permission carries no condition restricting employment. That distinguishes the scheme from a work visa tied to a named employer.

Stage	Duration	Condition for extension
Visitor visa after Approva­l-in-Pri­nciple	not more than 180 days	—
First permission after Formal Approval	not more than 24 months	—
Each subsequent extension	not more than 3 years	Verification of the Portfolio Maintenance Requirements through the New CIES Office
Eligibility to apply for the right of abode	after 7 years of continuous ordinary residence	Ordinary residence under Hong Kong law; for a person not of Chinese nationality, also a declaration that Hong Kong has been taken as the place of permanent residence
Unco­ndi­tional stay — the alternative	after 7 years of continuous compliance with the portfolio requirements	For those who cannot demonstrate ordinary residence

The right of abode, and the second condition that is routinely left out. The Immigration Department puts the first limb this way: “Persons admitted under New CIES who have ordinarily resided in the HKSAR for a continuous period of not less than seven years may apply for the right of abode in the HKSAR in accordance with the law.” The second limb is cumulative: a person who is not a Chinese national must also make a declaration in the form the Director of Immigration stipulates “that he/she has taken Hong Kong as his/her place of permanent residence”. The Immigration Department may call for evidence in support — habitual residence in Hong Kong, the presence of family members, means of income and tax payment history. Practical consequence: seven calendar years of formally uninterrupted presence do not by themselves produce the right of abode; the applicant must also be able to show that Hong Kong is where his life is centred, and it is this limb, not the day count, that defeats an applicant who has kept his household and his tax base elsewhere.

Unconditional stay is a separate route for those who have not in fact lived in Hong Kong. The Scheme Rules: “If the Entrant is unable to fulfill the continuous ordinary residence requirement while continuously satisfying the Portfolio Maintenance Requirements under the Scheme for not less than seven years, the Entrant and his dependants … may apply to DoI for unconditional stay.” Before that application the New CIES Office verifies “continuous compliance of the Portfolio Maintenance Requirements for not less than seven years”.

Here is the scheme’s central commercial consequence, and it fits in one sentence: the HK$30 million is locked for a minimum of seven years on either route. An entrant who relocates and lives in Hong Kong obtains the right of abode after seven years of ordinary residence. An entrant who does not relocate obtains unconditional stay after seven years of continuous portfolio compliance. In both cases the assets are released only after seven years. The Scheme Rules tie the release expressly to approval of unconditional stay: “the Entrant will be free to dispose of the Permissible investment assets under the Scheme subject to the terms and conditions of the underlying investments.”

The Scheme Rules impose no physical presence requirement for extensions. The condition for extension is compliance with the Portfolio Maintenance Requirements, not a number of days in Hong Kong. This analysis records that as the absence of a provision rather than as an affirmative rule: no official statement says that presence is not required.

The difference between the two routes is substantive and worth understanding before applying. The right of abode confers permanent status, access to a permanent identity card, and does not depend on keeping the investment in place afterwards. Unconditional stay removes the conditions from the permission to stay but is not permanent residence. Author’s assessment: an applicant who intends to relocate takes the first route, and for him the seven-year ordinary-residence clock and the seven-year capital lock run together — provided he can also make the permanent-residence declaration and support it. An applicant who intends to keep his tax residence elsewhere takes the second — and receives a less valuable status for the same price and the same term.

The ordinary residence requirement, how it is construed and how permanent residence is established after seven years are analysed in Hong Kong Work and Relocation Visas 2026.

Portfolio Maintenance: What Is Allowed and What Is Not

The investor is not required to top up the portfolio if its market value falls — even on a total loss. But he may not withdraw appreciation, pledge the assets or create third-party interests in them, and every switch of asset must be carried out inside a deadline that runs from 14 calendar days to three months depending on what is sold and what replaces it.

Paragraph 7.1 of the Scheme Rules is the most commercially significant provision in the whole section: “The Applicant/Entrant is not required to top-up the value of his investment in Permissible investment assets should its Market value fall below the requisite minimum level of HK$30 million Net even in the event of a total loss.”

That provision defines the scheme’s entire risk profile, and its effect is the opposite of how it is usually read. The investor carries the market risk, but the immigration risk of a fall in value is not transferred to him: a depreciating portfolio does not end his participation. Author’s assessment: this makes the scheme materially softer than any structure tying visa status to maintaining an asset value, and it is one of the few genuinely applicant-friendly terms in the Rules.

What is permitted.

Action	Provision	Condition
Switching assets	para 6.1(a)(viii)	Reinvest “NOT LESS THAN the entire Market value” of the asset sold — the whole proceeds, not the original cost
The switching window	para 8.2	Four different deadlines depending on the direction of the switch — see the table below. A 14-day limit appears in two of the four: contract to contract between financial assets, and as the earlier limb when moving out of real estate
Withdrawing dividends and interest	para 6.1(a)(vii)	“may at any time withdraw from the designated account(s) any cash dividend income or interest income arising directly from the Permissible financial assets”
Withdrawing rental income	para 5.2	“Rental income from the real estate can be paid and retained”
Withdrawing Surplus Equity	definition	The excess over the equity in the property fixed at the purchase date
Redeeming a mortgage	para 5.2	Permitted

What is prohibited.

Prohibition	Wording
Withdrawing appre­cia­tion	“the Appli­cant/E­ntrant is not allowed to withdraw or remove any appre­cia­tion from his Permissible investment assets”
Pledging the assets	“must not … incur any indebtedness in any form whatsoever using the Permissible investment assets as collateral”
Creating third-party interests	“not entitled to charge, assign or create any interest in favour of a third party in any Permissible financial assets held in the designated account(s)” — save a lien for unpaid professional fees

The asymmetry between a fall and a rise is the defining feature of the regime. A fall in value creates no obligation to top up. A rise in value creates no right to take the gain out. The practical consequence: what is locked is not the sum of HK$30 million but the entire value of the portfolio, whatever it becomes over seven years. Only current income — dividends, interest and rent — may be withdrawn.

The switching deadlines are the single most misreported rule in the scheme. There is no general 14-day rule: paragraph 8.2 sets four separate windows, of which only one is a plain 14 days.

Direction of the switch	Deadline	Measured from and to
Real estate → real estate	Not more than three calendar months	From the date of the contract for sale of the property sold to the date of completion of the replacement purchase
Financial asset → financial asset	Not more than 14 calendar days	From the date of the contract for sale to the date of the contract for purchase — contract to contract
Real estate → financial asset	The earlier of two calendar months after the contract for sale of the property, or 14 calendar days after co­mple­tion of that sale	To the date of the contract for purchase of the replacement asset
Financial asset → real estate	Not more than two calendar months	From the date of the contract for sale to the date of completion of the replacement purchase

Two things follow, and both cut against the way the rule is usually summarised. First, only the financial-to-financial window is contract-to-contract; the other three end on a completion date, which the buyer controls far less. Second, the real-estate-to-financial case carries a “whichever is the earlier” test, so a sale that completes quickly shortens the window from two months to 14 days after completion. Practical consequence: selling an illiquid asset without a replacement lined up creates a breach risk even where intentions are impeccable — and in a property switch the risk sits in the conveyancing timetable, not in the decision to sell.

A financial intermediary is mandatory for financial assets. Paragraph 6.1(a)(ii) admits three categories:

•          an authorised institution within the meaning of the Banking Ordinance;

•          a corporation licensed for Type 1 or Type 9 regulated activities under the Securities and Futures Ordinance;

•          an insurer permitted to carry on Class C business under the Insurance Ordinance.

No more than three intermediaries may be used, and they must be of different categories: “these three intermediaries shall be of different categories.” Assets sit in designated accounts in the sole beneficial ownership of the entrant or his Holding Company. The agreement with the intermediary must incorporate the terms set out in Annex A to the Scheme Rules.

Reporting comprises four distinct obligations on different cycles.

Who	What	When
The inte­rmedia­ry	Event notification to the DGIP — the Dire­ctor-Ge­neral of Investment Promotion of InvestHK, not the Immigration Department and not a financial regulator: withdrawals, failure to reinvest in time, account transfers, third-party charges, loss of sole beneficial ownership, account closure, cessation of appointment	7 working days from the event
The inte­rmedia­ry	Annual report on account composition and compliance	14 working days after each anniversary
The entrant	Declaration to the DGIP confirming he remains the absolute beneficial owner of the assets	every 12 months
The entrant	The Fulfillment document and Portfolio Maintenance Requirements Anniversary Statement from the practising accountant	within one month of each anniversary of Formal Approval

The intermediary must answer queries directly. Annex A, paragraph 5: “The Financial Intermediary shall promptly answer all queries addressed to it by DGIP … The Applicant/Entrant irrevocably authorises the Financial Intermediary to answer all such questions and provide such documents.”

The practical side of opening an account of this size — bank requirements, compliance and timing — is analysed in Corporate Bank Accounts in Hong Kong for Non-Residents 2026.

Dependants: Who Is Included and on What Terms

The application may include a spouse or a partner in a legally recognised same-sex or opposite-sex civil partnership or union, and unmarried children under 18. The scheme sets no separate financial threshold for dependants.

The Scheme Rules wording: “the spouse or partner in a legally recognised same-sex or opposite-sex civil partnership/union” and “unmarried dependent children aged under 18 years”.

Recognition of same-sex and opposite-sex civil partnerships is written into the scheme’s own rules, which distinguishes it from a number of comparable programmes. The test is legal recognition of the union, not its form.

Item	Rule
Who is included	A spouse or partner in a legally recognised civil partnership or union; unmarried children under 18
Dependants’ period of stay	“will normally be the same as that of their sponsors” — it tracks the principal applicant
Separate financial threshold	None. No additional investment and no separate net asset test applies to dependants
What is tested	Genuineness of the relationship; no adverse immigration record; the sponsor’s ability to support them “at a standard well above subsistence” and to provide suitable accommodation
Fees	HK$600 application fee and the applicable visa fee for each dependant separately
Right of abode	Dependants who have ordinarily resided in Hong Kong continuously for at least seven years may apply alongside the principal
Unco­ndi­tional stay	The Scheme Rules extend this route expressly to “the Entrant and his dependants”

The Immigration Department adds an important caveat about mutability: “the entry of dependants will be subject to any other policy applicable to such entry at the time.” The practical consequence: the dependant admission rules are not frozen as at the date the principal is approved and may change by the time the family actually relocates.

The children’s age limit is a hard line, and it creates a planning risk that is barely discussed. Only unmarried children under 18 are included. A child aged 17 at the date of application is included; a child aged 18 needs an independent basis of stay — a student visa, the Top Talent Pass, or another route, and those routes and their thresholds are set out in Hong Kong Work and Relocation Visas 2026: GEP and the Top Talent Pass. Author’s assessment: for a family with children approaching or in their teens, the filing date should be planned from the eldest child’s age, not from when the portfolio is ready.

Whether dependants may work or study without further permission is not expressly settled by the scheme’s official materials. The general position on permissions granted “on time limitation only” imposes no employment condition, but no affirmative statement specific to New CIES dependants could be found in the official sources. This analysis does not resolve the point and treats it as one to confirm with the Immigration Department on the specific family.

The Holding Company Route: the Link to the Family Office Regime

Since 1 March 2025 the scheme investment may be held through a private company wholly owned by the applicant. This is not an ordinary holding structure: the company must be a Family-owned Investment Holding Vehicle or a Family-owned Special Purpose Entity managed by an Eligible Single Family Office.

Paragraph 1.12 of the Scheme Rules defines the Holding Company by five cumulative conditions:

No.	Condition
(a)	Incorporated or registered in Hong Kong under the Companies Ordinance
(b)	Wholly owned by the applicant or entrant
(c)	Used e­xclusi­vely for transacting permissible investment assets
(d)	Is a FIHV or FSPE within the meaning of Schedule 16E to the Inland Revenue Ordinance, the FIHV requiring at least two full-time employees in Hong Kong and at least HK$2 million of operating expenditure annually
(e)	Managed by an Eligible Single Family Office as defined in section 2 of Schedule 16E, “which manages assets specified under Schedule 16C to the Inland Revenue Ordinance … for the FIHV (or multiple FIHVs) of the family with an aggregate Net asset value of not less than HK$240 million”. The threshold attaches to the specified assets under management, not to the family office’s own balance sheet — the Inland Revenue Department states the same test as “the aggregate value of assets specified under Schedule 16C … managed by an eligible SFO for the FIHV (or multiple FIHVs) of a family must be at least HK$240 million”

The conditions must be met before the investment requirements application and throughout the permitted period of stay.

The point of this construction is not the holding company as such but its dovetailing with the family office tax concession. The HK$240 million family-office threshold and the two-employee and HK$2 million expenditure tests are lifted from the Schedule 16E regime, which gives concessionary profits tax treatment to an FIHV. The practical consequence: the route is designed for an applicant whose family already has at least HK$240 million of Schedule 16C specified assets under the management of its Hong Kong single family office — an order of magnitude above the scheme’s own threshold. Note what the threshold does and does not require: the assets must be managed by the Hong Kong office, but Schedule 16C imposes no requirement that they be situated in Hong Kong. Only the two employees and the HK$2 million of expenditure must be in Hong Kong.

The 1 March 2026 change removes one bottleneck. Until then the five conditions had to be satisfied “during the entire six months preceding the date the Applicant lodged his application”, which in practice meant the company had to have been in existence for that whole period. The official wording of the change: “the New CIES has updated the conditions of a private holding company starting from March 1, 2026, allowing an applicant to use an eligible private holding company which has been set up in less than six months for his/her application for assessment on investment requirements without a minimum incorporation period.” NOTE (9) to the Scheme Rules records the amendment itself in a single line — “the conditions of the eligible private company have been updated” — without stating what changed, so the substance has to be taken from the Government’s own description.

The scheme also expressly permits transferring existing assets into the Holding Company during the permitted stay — the structure can be built after status is obtained, not only before.

A source qualification that should be made honestly. The effective date — 1 March 2026 — is published, and the change is described in identical terms in two Government sources: the press release of 2 March 2026 and the dedicated page on the Financial Services and the Treasury Bureau’s family office portal. What could not be established is the announcement date: the change appears in neither the 2025 Policy Address nor the 2026-27 Budget, the family office portal page carries no date, and the earliest dated official mention describes the change as already in force. This analysis therefore gives the effective date and gives no announcement date.

The tax side of the route requires a calculation of its own, and it does not always favour the structure.

Holding configuration	FSIE perimeter	Comment
Assets held personally	Outside the FSIE regime — it applies only to entities within multinational groups, and natural persons fall outside it entirely	The simplest configuration
Assets held through a Holding Company (FIHV)	Potentially inside the perimeter: a Hong Kong entity enters the picture, and FSIE reaches it only if it is a member of a multinational group. A standalone Hong Kong vehicle owned by one individual with no group presence in another jurisdiction is outside FSIE too — but a family that already holds entities abroad brings the vehicle inside	Requires two employees, HK$2 million of expenditure and a family office managing HK$240 million; the Schedule 16E concession conditions apply

Author’s assessment: this is a genuine structural trade-off created by the 2025 and 2026 changes, and it is rarely spelled out. For an applicant whose object is residency plus a held portfolio, simple personal ownership is cheaper, simpler and outside the FSIE perimeter with certainty rather than on analysis. The holding structure earns its place only where a Hong Kong family office is being established for independent reasons and the scheme’s requirement coincides with a decision already taken about how the capital will be governed — and the FSIE question then has to be answered on the family’s actual group footprint, not assumed either way.

The concession’s conditions, the FIHV definition, the two-employee and HK$2 million tests and the HK$240 million family-office threshold are analysed in The Hong Kong Family Office Tax Concession 2026.

The Tax Position of an Entrant

Hong Kong levies no capital gains tax and no withholding tax on dividends or interest, so portfolio returns under the scheme are generally untaxed. But obtaining status under the scheme does not of itself make a person a Hong Kong tax resident for double taxation agreement purposes.

The framework is set out by the Financial Services and the Treasury Bureau: “Only profits/income arising in or derived from Hong Kong is chargeable to tax”; “There is no value-added or sales tax; no capital gains tax; no withholding tax on dividends and interest; and no estate duty in Hong Kong.”

Type of return	Hong Kong treatment
Capital gains on permissible assets	Not taxed — there is no capital gains tax
Dividends on shares and funds	Not taxed; no withholding
Interest on debt securities and certificates of deposit	No withholding tax
CIES Investment Portfolio distri­butio­ns	Not taxed — on the same logic
Rental income from Hong Kong property	Property tax applies — this is Hong Kong-source income
Salary, if the entrant works in Hong Kong	Salaries tax applies

One qualification changes the picture for an active investor, and it should be stated plainly. The capital gains exemption works because profits from the sale of capital assets are excluded from the profits tax base. Where dealing is frequent and systematic, the tax authority may characterise the activity as trading rather than investing — and the profits become business income. The scheme sets a demanding replacement tempo: a switch from one financial security to another allows 14 calendar days to reinvest the proceeds. It does not encourage selling — paragraph 7.2 bars withdrawal of any appreciation, which cuts the other way — but once a decision to sell is taken, the replacement must be fast. No IRD guidance addresses CIES entrants specifically. This is the author’s assessment rather than a stated official position, and it should be tested individually where the portfolio is actively rotated. The boundary between capital and trading treatment is analysed in Territorial Taxation and Offshore Status in Hong Kong 2026.

Salaries tax if the entrant works in Hong Kong. The tax is charged on income from employment, office and pension “arising in or derived from Hong Kong”. Rates run on a progressive scale of 2 to 17 per cent, or at the standard rate of 15 per cent on the first HK$5 million of net income and 16 per cent on the remainder. Section 8(1B) of the Inland Revenue Ordinance relieves a person who renders services in Hong Kong during visits totalling not more than 60 days in the basis period. The source mechanics, the 60-day rule and departure clearance are analysed in Hong Kong Salaries Tax 2026.

The FSIE regime does not touch an individual entrant. The IRD’s guidance confines the perimeter expressly: “only members of MNE groups (MNE entity) will be subject to the FSIE regime”, and an entity means “a legal person (other than a natural person)” or a partnership or trust that prepares separate accounts. The practical consequence: an individual holding the portfolio personally sits outside FSIE with certainty. Using a Holding Company introduces a Hong Kong entity, but that alone does not bring it inside FSIE: the regime reaches only members of multinational groups. A standalone Hong Kong company owned by one individual with no related entities abroad falls outside it; a company within a family group that already holds structures in other jurisdictions falls inside. The answer turns on the group’s actual footprint and cannot be assumed either way.

Tax residence is where the scheme is most often overstated. The IRD treats an individual as a Hong Kong resident for treaty purposes where he “ordinarily resides in Hong Kong” or stays in Hong Kong for more than 180 days in a year of assessment or more than 300 days in two consecutive years of assessment. Status under the scheme confers the right to be in Hong Kong; it displaces neither the ordinary residence test nor the day count. The IRD separately directs applicants to check the relevant article of the relevant treaty. Author’s assessment: the proposition “invest HK$30 million and become a Hong Kong tax resident” is wrong; a certificate of resident status is issued on substance, not on the existence of a visa. The IRD’s criteria and the application process are analysed in Hong Kong Certificate of Resident Status 2026.

A separate consequence of holding a HK$30 million portfolio is automatic exchange of information. Accounts with Hong Kong financial intermediaries fall within the CRS, and information about them is reported to the jurisdiction of the holder’s tax residence. The practical consequence: for as long as the entrant remains tax-resident elsewhere, the data on the Hong Kong portfolio flows to that jurisdiction. Account classification and the common self-certification errors are analysed in CRS and Automatic Exchange of Information in 2026.

What the Official Statistics Show

As at 28 February 2026, 3,166 applications had been received, 1,762 applicants had Formal Approval, and expected investment stood at about HK$95 billion. Verified investment was HK$55,636 million.

The most recent published figure is from mid-April 2026. In a speech by the Secretary for Financial Services and the Treasury on 13 April 2026, the scheme “has already drawn over 3,300 applications with an expected investment value of about HK$99 billion”. No later official data had been published as at the end of August 2026.

The trajectory in the official releases.

Data as at	Applications	Formal approvals	Expected investment
31 May 2024	over 250	—	over HK$7.5 billion
end-2024	over 800	—	over HK$24 billion
28 February 2025	918	341	over HK$27 billion
30 April 2025 — first-year review	1,257	512	over HK$37 billion
28 February 2026 — two-year milestone	3,166	1,762	about HK$95 billion
13 April 2026 — SFST speech	over 3,300	—	about HK$99 billion

The scheme’s second year produced a 145 per cent increase in applications, to 2,248.

The composition of verified investment as at 28 February 2026.

Asset class	HK$ million	Share
SFC-au­tho­rised funds	21,448	38.6%
Equities	16,116	29.0%
Inve­stment-li­nked assurance schemes	5,498	9.9%
CIES Investment Portfolio	5,511	9.9%
Debt securities	5,276	9.5%
Other	1,787	3.2%
Total	55,636	100.0% as printed

The release prints the total as 100.0 per cent, but the six component percentages sum to 100.1 — a rounding artefact in the source. The HK$ million column reconciles exactly to 55,636. **The release also footnotes the CIES Investment Portfolio line “*Including capital pending deployment”, so that figure is money committed rather than money invested.**

Three conclusions follow from these figures and are almost never drawn.

First: real estate is invisible in the current breakdown, and negligible in the one that showed it. At 28 February 2026 real estate is not itemised at all — the sixth line is a residual “Other” at 3.2 per cent. In the finer breakdown given for end-February 2025, non-residential real estate did appear, at HK$18 million against more than HK$10 billion in financial assets, and the Government stated expressly that no applicant had invested in residential property. Author’s assessment: two rounds of liberalising the real estate rules have produced no measurable response, and on the published data this component of the scheme remains ornamental.

Second: the CIES Investment Portfolio’s share sits just below the mandatory minimum. The mandatory ratio of HK$3 million to HK$30 million is 10.0 per cent; the portfolio’s actual share is 9.9 per cent. What that supports is a narrow proposition: whatever excess sits in the other permissible classes outweighs any excess in the portfolio by more than nine to one. It does not establish that nobody contributes above the mandatory HK$3 million, and the residual is small — about HK$526 million across roughly 1,800 entrants, which indivisible lot sizes alone could produce. Author’s assessment: on this evidence the portfolio behaves like an obligation rather than an opportunity, but the published figures will not carry a stronger claim than that.

Third: two thirds of the capital goes into funds and equities. SFC-authorised funds — funds authorised for public offer, which is a different test from being managed by a Type 9 licensee — and SEHK-listed equities together account for 67.6 per cent of verified investment. Author’s assessment: in practice the scheme operates as a channel of inflows into Hong Kong’s asset management industry rather than into property or private equity, and the breakdown demonstrates that better than any policy statement.

The gap between “expected” and “verified” investment is systematic and needs explaining. At 28 February 2026 the expected figure was about HK$95 billion and the verified figure HK$55.6 billion. The difference reflects applicants who have cleared the early stages but not yet completed and had verified their deployment: the expected figure is derived from the number of applications, the verified figure from portfolios actually checked.

The nationality mix is not officially published. Neither the two-year milestone nor the first-year review gives a breakdown by nationality. The only official colour is a June 2024 Legislative Council reply: applicants come “from Europe, the United States, Singapore, and other regions”. Any numerical nationality split appearing in industry publications is unsupported by official sources, and this analysis does not reproduce one.

The last full funnel was published as at 30 April 2025: 1,257 applications, 1,153 net asset verifications, 911 Approvals-in-Principle, 543 investment verifications and 512 Formal Approvals. The two-year review does not disclose the intermediate stages, so stage-by-stage conversion cannot be computed from official data as things stand.

Comparison: the Old Scheme, Singapore and the UAE

The New CIES is not Hong Kong’s first investment scheme. Its predecessor ran from October 2003 and has been suspended since 15 January 2015 — suspended rather than abolished, and existing entrants continue under the old rules.

The old Capital Investment Entrant Scheme: thresholds and history.

Item	Old scheme	New CIES
Launch	October 2003	1 March 2024
Original threshold	HK$6.5 million	HK$30 million
Raised threshold	HK$10 million from 14 October 2010	unchanged
Real estate	suspended as an asset class from 14 October 2010	admitted: non-re­side­ntial from 2024, residential from 16 October 2024
Mandatory state portfolio	none	HK$3 million into the CIES Investment Portfolio
Extension pattern	2 + 3 + 3 years — the same as the new scheme	2 + 3 + 3 years
Status	suspended from 15 January 2015	in force

The reason for suspension was stated openly: attracting capital investment entrants “should no longer be our priority”, in favour of “attracting talent, professionals and innovative entrepreneurs”; the Immigration Department also had a backlog of more than 12,000 applications to clear. The old scheme’s lifetime result as at 31 December 2015: Formal Approval for 28,243 applicants, Approval-in-Principle for a further 1,345, and up to HK$243.6 billion of investment attracted.

There is no migration path from the old scheme to the new one. They are separate schemes: the old one is suspended but not abolished, and its entrants continue to extend on the same 2 + 3 + 3 pattern under the old rules. The stay pattern is therefore not a point of difference between the two schemes — a common error — and neither is the number of extensions, which is unlimited in both.

Comparing the two schemes’ results requires care, because the published figures are not like for like. The old scheme attracted up to HK$243.6 billion over roughly eleven years, but for the first seven of them the threshold was HK$6.5 million, not HK$10 million — the increase took effect only on 14 October 2010. And the HK$243.6 billion is investment attracted, whereas the new scheme’s HK$99 billion is investment expectedand derived from applications; the comparable verified figure is HK$55.6 billion. Author’s assessment: on verified investment against investment attracted, the new scheme is running at roughly HK$26 billion a year against roughly HK$22 billion for the old one — faster, but not dramatically so, and nothing like the gap the headline figures suggest.

Comparison with the two principal alternatives for the same applicant profile.

Item	Hong Kong, New CIES	Singapore, Global Investor Programme	UAE, Golden Visa (investor route)
Threshold	HK$30 million	S$10 million (business) / S$25 million (GIP-select fund) / S$200 million family office AUM, of which S$50 milliontransferred into Singapore	AED 2 million — property, a stake in a company or a bank deposit; or an annual tax contribution of at least AED 250,000
What is granted at the outset	Permission to stay for up to 24 months	Permanent residence	A long-term residence visa
Route to permanent status	7 years of ordinary residence for the right of abode; or 7 years of portfolio compliance for unconditional stay	Imme­dia­tely, formalised by a 5-year Re-Entry Permit	No permanent residence; the visa is renewed
Capital lock	Yes, for the whole period of parti­cipa­tion; the mandatory HK$3 million until the seven-year term of its annual batch expires — a fixed fund-level date, not seven years from the individual payment — with no published exit procedure	No formal lock; conditions are tested on renewal of the 5-year permit	Yes for property: disposal is prohibited and a lien securing continued ownershipis registered
Ci­tize­nship	Not conferred	Not conferred; citizenship is a separate discretionary application	Not conferred
Date of the current version	Changes of 1 March 2026	Current factsheet dated 5 May 2025, from which date the S$20,000 application fee applies; EDB publishes no commencement date for the thresholds themselves	No 2026 change identified

The key difference between Hong Kong and Singapore is not the amount but the moment status arises.Singapore grants permanent residence on entry; Hong Kong grants a temporary permission, with permanent status only after seven years. Author’s assessment: on entry price alone Hong Kong is cheaper than the Singapore family office route and comparable to the business route, but it sells a fundamentally different product — deferred status against immediate status.

A qualification on the UAE data that should be made honestly. The UAE’s own official sources diverge on the duration of the investor golden visa on the property route: the federal portal u.ae states 5 years for real estate investment and 10 years for public investment, while the GDRFA Dubai service page states 10 years for the property route as well. The divergence cannot be resolved from official sources; the GDRFA page is more specific and belongs to the issuing authority, but this analysis gives both figures and states no single number. In addition, neither u.ae, nor icp.gov.ae, nor gdrfad.gov.ae cites the instrument numberestablishing these routes, so no specific Cabinet resolution is cited here. The UAE investor thresholds and practice are analysed in UAE Golden Visa Through Business 2026 and Property Investor Visa in the UAE.

None of the three programmes leads to citizenship. Singapore’s GIP confers permanent residence, from which citizenship is a separate discretionary application; the UAE describes the golden visa expressly as long-term residence; Hong Kong confers the right of abode, which is permanent residence but not PRC nationality.

Step-by-Step: How to Apply

Sequence matters more than speed: the portfolio configuration is better agreed before the trades than argued after a refusal at stage four.

1.        Check eligibility by nationality before anything else. The scheme is open to foreign nationals, PRC nationals with permanent residence abroad, Macao residents and Chinese residents of Taiwan. Nationals of Afghanistan, Cuba and North Korea are excluded.

2.        Check the children’s ages. Only unmarried children under 18 are included; for a family with teenagers this, not the readiness of the capital, sets the filing deadline.

3.        Assemble evidence of net assets of HK$30 million held continuously for six months before the application, bearing in mind that jointly held family assets count to the extent of the applicant’s beneficial share.

4.        Engage a Certified Public Accountant (Practising) and agree the scope of procedures. Remember that this is an agreed-upon procedures engagement, not an audit, and no opinion is expressed.

5.        Lodge the Net Asset Assessment application within 14 calendar days of the Fulfillment document’s date. The same 14-day limit applies again between the Fulfillment document and the application for assessment on investment requirements at stage four. Missing either means a fresh document and paying the accountant again.

6.        Await Approval-in-Principle and take the visitor visa for not more than 180 days.

7.        Agree the portfolio configuration with the New CIES Office before trading. Check the venue and the currency: equities and debt securities must be SEHK-listed and traded in HKD or RMB.

8.        Check the sub-caps before buying: certificates of deposit no more than HK$3 million; private OFCs and LPFs no more than HK$10 million combined; real estate no more than HK$15 million, of which residential no more than HK$10 million.

9.        Sign with a financial intermediary and open the designated account. No more than three intermediaries, and they must be of different categories.

10.    Deploy at least HK$27 million into permissible assets inside the window your chosen option gives you — under option (iii), within 180 days of Approval-in-Principle; under option (ii), by the 180th day after Approval-in-Principle with the window having opened up to 180 days before the net asset assessment application; under option (i), before that application is lodged at all.

11.    Place the separate HK$3 million into the CIES Investment Portfolio, noting that the lock-up attaches to the annual batch, not to the date of your payment.

12.    Budget transaction costs on top of the HK$30 million — stamp duty, commissions and legal fees do not count towards the threshold.

13.    Clear the Investment Requirements Assessment and obtain Formal Approval with permission to stay for up to 24 months.

14.    Set up the annual reporting cycle immediately. The beneficial ownership declaration is due every 12 months; the Fulfillment document and Anniversary Statement within one month of each anniversary of Formal Approval.

15.    Do not withdraw appreciation. Dividends, interest, rental income and Surplus Equity on property may be taken out.

16.    Check which switching window applies before you sell, reinvesting the whole market value rather than the original cost: 14 calendar days contract to contract between financial assets; three calendar months to completion for real estate to real estate; two calendar months to completion for financial assets to real estate; and for real estate to financial assets the earlier of two months from the sale contract or 14 days from completion of the sale.

17.    Approach the New CIES Office for verification of the Portfolio Maintenance Requirements no earlier than three months before the limit of stay expires — that is where paragraph 4.10 puts the three-month limit — and lodge the extension application with the Immigration Department before the limit of stay runs out, whether or not the verification has come back.

18.    Decide at the outset which of the two seven-year routes you want — the right of abode through ordinary residence, or unconditional stay without relocating — because it determines your presence pattern for all seven years.

Common Mistakes and What They Cost

Mistake 1. Assuming the increase in the real estate cap to HK$15 million applies to residential property. NOTE (8) to the Scheme Rules raises the aggregate cap to HK$15 million “among which the cap on residential real estate remains at HK$10 million”, cutting only the residential price floor from HK$50 million to HK$30 million; paragraph 102 of the 2025 Policy Address adds that the increase is for non-residential property with no price threshold at all. Cost: buying a residential property for HK$40 million expecting HK$15 million of credit produces HK$10 million, leaving a HK$5 million hole to be filled with financial assets in a hurry — either inside the 180-day window or after a refusal at stage four.

Mistake 2. Buying securities that are not SEHK-listed or not traded in HKD or RMB. Sub-paragraphs (a) and (b) of paragraph 5.1 require the Hong Kong venue and those two currencies specifically. Cost: the assets acquired count for nothing rather than partially; under option (iii) that means the 180-day window is spent on trades irrelevant to the scheme.

Mistake 3. Filling the threshold with your own private fund structures. Private OFCs and private LPFs are capped at HK$10 million combined. Cost: at least HK$17 million must still go into public instruments, real estate or other permissible classes, and a structure built on the contrary assumption has to be rebuilt after a refusal.

Mistake 4. Treating the accountant’s report as confirmation that the requirements are met. It is an agreed-upon procedures engagement under HKSRS 4400 (Revised): “not an audit, review or other assurance engagement”. Cost: the applicant relies on a signature that by its nature confirms nothing, and does not check the underlying documents himself — yet those documents decide the assessment.

Mistake 5. Missing the 14 days between the Fulfillment document and the application. Paragraph 4.2 admits no exception. Cost: re-engaging the accountant and paying for the engagement again, plus a shift in the whole chain of deadlines.

Mistake 6. Withdrawing appreciation from the portfolio. The Rules expressly prohibit withdrawing or removing “any appreciation”. Cost: a breach of the Portfolio Maintenance Requirements, which the financial intermediary must report to the DGIP — the Director-General of Investment Promotion of InvestHK — within seven working days, and a risk to the next extension of stay.

Mistake 7. Selling an asset without a replacement lined up — or applying the wrong switching deadline. Paragraph 8.2 sets four different windows. Only the financial-to-financial one is a plain 14 days contract to contract; the real-estate-to-financial case has a 14-day limb too, but it runs from completion of the sale and applies only if that is earlier than two months from the sale contract; and the two windows that end in a property purchase run to a completion date the buyer controls far less. The whole market value must be reinvested, not the original cost. Cost: with an illiquid asset the deadline is breached even where intentions are impeccable; and an applicant who assumes he has three months on a property switch when completion of his purchase runs long has breached a rule he did not know applied — the consequence in both cases being an intermediary notification to the DGIP and a risk to the extension.

Mistake 8. Pledging scheme assets against borrowing. The Rules prohibit any encumbrance over permissible assets and any assignment of rights to third parties. Cost: a breach of an express prohibition; and because the definition of “Net” deducts encumbrances, the portfolio simultaneously stops reaching the threshold.

Mistake 9. Planning to live off the return on the invested sum. The criteria expressly require the ability to support oneself and one’s family “without relying on any return on the Permissible investment assets”. Cost: failure of an admission criterion detected at the very first stage — possibly after the portfolio has already been assembled under option (i).

Mistake 10. Assuming scheme status confers Hong Kong tax residence. The IRD applies the ordinary residence test or a day count — more than 180 days in a year of assessment or more than 300 days across two consecutive years. Cost: planning built on a residence that does not exist, refusal of a certificate of resident status, and consequently no treaty relief on the very income the structure was built for.

Mistake 11. Planning an exit from the CIES Investment Portfolio before seven years. The term attaches to the batch: 1 January 2025 for the 2024 batch and 1 January 2026 for the 2025 batch. Cost: the HK$3 million is unavailable for longer than the model assumed, the exit mechanism has never been published, and there is no track record of getting the money back.

Mistake 12. Building a holding structure for the scheme’s sake. A Holding Company must be a FIHV or FSPE managed by an eligible single family office that manages at least HK$240 million of Schedule 16C specified assets for the family, with two full-time employees in Hong Kong and HK$2 million of annual expenditure there. Cost: permanent running costs, the Schedule 16E concession conditions, and — for a family that already holds entities abroad — exposure to the FSIE regime, all for a structure the portfolio does not need, when personal ownership requires no employees, no expenditure and sits outside FSIE with certainty because FSIE does not reach natural persons.

Mistake 13. Planning against the 2024 processing times. The three-weeks-per-stage figure was given when some 250 applications had been received in total; by February 2026 there were 3,166. Cost: relocation plans pinned to a school year, and exits from assets in the previous jurisdiction, timed against a date nothing supports.

Mistake 14. Forgetting the annual reporting cycle once status is granted. There are four obligations, on different cycles and to different recipients. Cost: a missed declaration or Anniversary Statement is a breach of the Portfolio Maintenance Requirements — and those requirements are the condition for every three-year extension.

Mistake 15. Buying certificates of deposit in the wrong window. Paragraph 2.1(d) opens “subject to paragraph 5.1(c) on investment in certificates of deposits” and closes with an express carve-out: deposits count only if bought in the period from the grant of Approval-in-Principle to the 180th day thereafter, and they must then be held throughout their term. Cost: an applicant who assembles his portfolio in advance under option (i) and includes deposits finds that those deposits count for nothing — and because a deposit is the class most likely to be used to park the last few million, the shortfall surfaces at stage four with only the remainder of the 180-day window left to fix it.

Mistake 16. Treating seven years of presence as sufficient for the right of abode. A person who is not a Chinese national must also lodge a declaration in the form the Director of Immigration stipulates “that he/she has taken Hong Kong as his/her place of permanent residence”, supported where required by evidence of habitual residence, family in Hong Kong, means of income and tax payment history. Cost: a plan built on counting days alone. An entrant who has maintained his household, his family and his tax base elsewhere may satisfy the day count and still fail the declaration limb — leaving unconditional stay, a materially weaker status, as the only outcome after seven years of locked capital.

Who the Scheme Suits, Who It Does Not, and When Professional Review Is Needed

The scheme is built for an investor who can take HK$30 million out of circulation for seven years and who is either prepared to relocate to Hong Kong or content with the less valuable status of unconditional stay.

It suits:

•          families intending an actual move to Hong Kong — seven years of ordinary residence yields the right of abode, and the capital lock runs in step with the status clock;

•          investors already holding a Hong Kong portfolio assembled for independent reasons — option (i) allows assets acquired within 180 days before the application to count;

•          families with children under 18, since dependants are included without a separate financial threshold and receive the same period of stay;

•          families already establishing or running a Hong Kong single family office that manages at least HK$240 million of Schedule 16C specified assets for the family — for them the Holding Company requirement coincides with a decision already taken.

It does not suit:

•          PRC nationals resident in the Mainland — the scheme is closed to them whatever the capital;

•          anyone planning to live off the return on the invested sum — the admission criterion expressly forbids it;

•          anyone who needs status quickly — permanent status arises no earlier than seven years out, whereas Singapore grants permanent residence on entry;

•          investors who need liquidity — the whole value of the portfolio is locked, not just the entry sum, and appreciation cannot be withdrawn;

•          anyone seeking tax residence — scheme status does not create it;

•          residential property investors — credit is capped at HK$10 million on a property costing HK$30 million or more, and the statistics show that almost nobody uses this route.

Professional review is needed: when setting the portfolio configuration before trading; when using private OFCs or LPFs, because of the combined sub-cap; when buying property, because residential and non-residential are treated differently; when choosing between personal ownership and a Holding Company; where the portfolio is actively rotated, because of the capital-versus-trading line; and when choosing between the right of abode and unconditional stay.

Frequently Asked Questions

How much must be invested under the New CIES?

HK$30 million: at least HK$27 million in permissible financial assets and/or real estate, plus a mandatory HK$3 million into the CIES Investment Portfolio. The threshold has not changed since the scheme opened on 1 March 2024. Transaction costs — stamp duty, commissions, legal fees — do not count towards it and are paid on top.

Does the New CIES grant permanent residence immediately?

No. Formal Approval grants permission to stay for not more than 24 months, followed by extensions of not more than three years each. The right to apply for the right of abode arises after seven years of continuous ordinary residence in Hong Kong. For those who cannot demonstrate ordinary residence there is an alternative — unconditional stay after seven years of continuous compliance with the portfolio requirements.

Can a Hong Kong flat be bought and counted towards the threshold?

Yes, but only up to HK$10 million and only on a single property costing HK$30 million or more, with completion on or after 16 October 2024. The aggregate real estate cap is HK$15 million, and NOTE (8) to the Scheme Rules states that within it “the cap on residential real estate remains at HK$10 million”; the increase from HK$10 million to HK$15 million is for non-residential property, which carries no price threshold at all. For purchases completed before 17 September 2025 the earlier parameters apply: an aggregate cap of HK$10 million under footnote 13 and a residential price floor of HK$50 million under footnote 15.

Can the HK$3 million in the CIES Investment Portfolio be recovered?

Only after the seven-year life of the relevant annual batch expires, and no operational exit procedure has been published. The clock runs from 1 January 2025 for the 2024 batch and 1 January 2026 for the 2025 batch — a fixed fund-level date, not seven years from your own payment. Paragraph 5.3 of the Rules does provide that after the lock-up expires the sum “may be withdrawn by or distributed to” the investor, but it is expressed to be subject to paragraph 5.3.1, which states that “capital preservation and dividends are not guaranteed, and distribution may be made on a discretionary basis at appropriate junctures”. No redemption track record exists — the earliest date is 1 January 2032.

What happens if the portfolio falls in value?

Nothing so far as status is concerned: no top-up is required. Paragraph 7.1 of the Scheme Rules provides that the investor “is not required to top-up the value of his investment … even in the event of a total loss”. The converse also applies: appreciation may not be withdrawn — only dividends, interest, rental income and Surplus Equity on property.

Is living in Hong Kong necessary to extend the status?

The Scheme Rules impose no physical presence requirement for extensions — the condition is compliance with the Portfolio Maintenance Requirements. Presence does, however, determine which status is available after seven years: the right of abode requires seven years of ordinary residence and, for a person who is not a Chinese national, a declaration that Hong Kong has been taken as the place of permanent residence. Without both, only unconditional stay is open.

Who may apply?

Foreign nationals, PRC nationals with permanent residence in a foreign country, residents of the Macao Special Administrative Region, and Chinese residents of Taiwan. Nationals of Afghanistan, Cuba and North Korea are excluded; stateless persons with permanent residence abroad and proven re-entry facilities are eligible. PRC nationals resident in the Mainland cannot use the scheme.

Does participation make an entrant a Hong Kong tax resident?

No. The IRD applies the ordinary residence test or a day count — more than 180 days in a year of assessment or more than 300 days across two consecutive years. The visa confers the right to be in Hong Kong, but a certificate of resident status is issued on substance, not on the existence of the status.

How long does processing take?

The only official figures date from June 2024: around three weeks for the net asset assessment and around three weeks for Approval-in-Principle. No official time has ever been published for the investment requirements assessment or for Formal Approval. Those figures described a period in which some 250 applications had been received in total; by 28 February 2026 the cumulative figure was 3,166, and the Immigration Department gives no processing pledge.

Can a spouse and children be included?

Yes: a spouse or partner in a legally recognised same-sex or opposite-sex civil partnership or union, and unmarried children under 18. There is no separate financial threshold for dependants, and their period of stay matches the principal’s. The HK$600 application fee and the applicable visa fee are payable for each of them separately.

What does the applicant pay the government?

HK$600 per person per application and HK$1,300 for a visa valid for more than 180 days. The application fee was introduced on 26 February 2025 and is non-refundable in all circumstances. No charge for InvestHK’s services is published on the official pages.

Is a financial intermediary compulsory?

Yes, for permissible financial assets. It may be an authorised institution under the Banking Ordinance, a corporation licensed for Type 1 or Type 9 regulated activities under the Securities and Futures Ordinance, or an insurer permitted to carry on Class C business. No more than three intermediaries may be used and they must be of different categories. The requirement does not extend to real estate or to the CIES Investment Portfolio.

Key Takeaways

•          The threshold is HK$30 million: HK$27 million in permissible assets plus a mandatory HK$3 million into the CIES Investment Portfolio. Unchanged since 1 March 2024.

•          The scheme is administrative, not statutory, and operates within the Immigration Ordinance (Cap. 115).

•          The increase in the aggregate real estate cap to HK$15 million does not reach residential property, which stays capped at HK$10 million on a property costing HK$30 million or more.

•          The accountant’s report is an agreed-upon procedures engagement under HKSRS 4400 (Revised) — not an audit and not an assurance engagement.

•          A fall in portfolio value requires no top-up, even on a total loss; appreciation may not be withdrawn.

•          Switching an asset means reinvesting the whole market value inside one of four deadlines — 14 calendar days contract to contract between financial assets, three months to completion between properties, two months to completion from a financial asset into property, and the earlier of two months or 14 days from completion when moving out of property.

•          The HK$3 million in the CIES Investment Portfolio is locked until the seven-year term of its annual batch expires; the right to withdraw afterwards is stated in paragraph 5.3, but fees, valuation and the exit procedure are unpublished.

•          Permanent status arrives no earlier than seven years out, by one of two routes — and for an applicant who is not a Chinese national the right of abode route needs the permanent-residence declaration as well as the day count.

•          Scheme status does not create Hong Kong tax residence.

•          As at 28 February 2026: 3,166 applications and 1,762 Formal Approvals; as at 13 April 2026: over 3,300 applications and about HK$99 billion of expected investment.

•          Real estate is not itemised in the current official breakdown, and the CIES Investment Portfolio’s share sits at 9.9 per cent against a mandatory ratio of 10.0 per cent.

Summary

The New Capital Investment Entrant Scheme is Hong Kong’s investor entry route, open for applications since 1 March 2024 and administrative rather than statutory in nature: it was announced in paragraph 57(iv) of the 2023 Policy Address, its parameters were published by the Government on 19 December 2023, and it operates under the Director of Immigration’s general powers in the Immigration Ordinance (Cap. 115), with the Scheme Rules issued jointly by InvestHK and the Immigration Department. The threshold is HK$30 million, comprising at least HK$27 million in permissible financial assets and/or real estate and a mandatory HK$3 million into the CIES Investment Portfolio set up by the Hong Kong Investment Corporation Limited. Permissible assets are equities and debt securities listed on the Stock Exchange of Hong Kong and traded in Hong Kong dollars or renminbi; certificates of deposit in the same currencies with at least 12 months to maturity, subject to a HK$3 million sub-cap; subordinated debt; SFC-authorised funds, REITs, investment-linked assurance schemes and open-ended fund companies managed by Type 9 licensees; and interests in limited partnership funds, with private OFCs and private LPFs capped at HK$10 million combined. Real estate counts up to an aggregate HK$15 million, of which residential is capped at HK$10 million and must be a single property costing HK$30 million or more with completion on or after 16 October 2024; the increase in the aggregate cap from HK$10 million to HK$15 million took effect on 17 September 2025 and does not reach residential property, NOTE (8) to the Rules providing that “the cap on residential real estate remains at HK$10 million” while paragraph 102 of the 2025 Policy Address records that the increase is for non-residential property, for which there is no price threshold. The applicant must be aged 18 or above and must have held net assets of HK$30 million continuously throughout the six months preceding the application — a period cut from two years with effect from 1 March 2025 — evidenced by a Certified Public Accountant (Practising) through an agreed-upon procedures engagement under HKSRS 4400 (Revised), which is expressly not an audit or any other assurance engagement. The scheme is open to foreign nationals, PRC nationals with permanent residence abroad, Macao residents and Chinese residents of Taiwan, but not to nationals of Afghanistan, Cuba or North Korea. The procedure has six stages: the net asset and investment assessments are conducted by the New CIES Office within InvestHK, while Approval-in-Principle and Formal Approval are granted by the Director of Immigration; no more than 14 calendar days may elapse between issue of the Fulfillment document and lodging the application, and 180 days are allowed for making the investment after Approval-in-Principle. Formal Approval grants a stay of up to 24 months, with extensions of up to three years each on verification of the Portfolio Maintenance Requirements; the right of abode arises after seven years of ordinary residence, with a person not of Chinese nationality also required to declare that Hong Kong has been taken as his place of permanent residence, and unconditional stay after seven years of portfolio compliance. No top-up is required if the portfolio falls in value, even on a total loss, but appreciation may not be withdrawn — only dividends, interest, rental income and Surplus Equity; switching an asset requires the whole market value to be reinvested within one of the four windows in paragraph 8.2 — 14 calendar days contract to contract between financial assets, three calendar months to completion between properties, two calendar months to completion from a financial asset into property, and the earlier of two months from the sale contract or 14 days from completion when moving out of property. Immigration Department fees are HK$600 per person per application and HK$1,300 for a visa valid for more than 180 days, in force since 26 February 2025. The mandatory HK$3 million is locked for seven years from the annual batch date — 1 January 2025 for the 2024 batch and 1 January 2026 for the 2025 batch — with paragraph 5.3 providing that the sum may be withdrawn or distributed after the lock-up expires but expressing that right to be subject to paragraph 5.3.1, under which distribution may be made on a discretionary basis and neither capital preservation nor dividends are guaranteed, and with fees, valuation methodology and redemption procedure unpublished. As at 28 February 2026, 3,166 applications had been received and 1,762 had Formal Approval, with verified investment of HK$55,636 million, of which 38.6 per cent sat in SFC-authorised funds and 29.0 per cent in equities while real estate was not itemised at all; as at 13 April 2026 applications exceeded 3,300 with expected investment of about HK$99 billion.

If you are weighing the New CIES as a route for your family or as part of a wealth-structuring plan, the UPPERSETUP team can take you from the eligibility check and portfolio configuration through to the annual reporting cycle: Hong Kong company registration.

Sources

Scheme Rules and the official New CIES portal

1.        Rules for the New Capital Investment Entrant Scheme — current version as amended to 1 March 2026 (PDF)

2.        New CIES — Scheme Rules and Documents: the current rules, guidebooks, forms and templates

3.        Official portal of the New Capital Investment Entrant Scheme

4.        New CIES — Eligibility Criteria

5.        New CIES — Application Procedures

6.        New CIES — Investment Requirement

7.        New CIES — New Measures: scheme changes and their commencement dates

8.        New CIES — InvestHK frequently asked questions

9.        New CIES — news and press releases

10.    Guidebook for the New Capital Investment Entrant Scheme — full version (PDF)

11.    Guidebook for the New Capital Investment Entrant Scheme — simplified version (PDF)

12.    Guide on Preparation of Fulfillment Documents (PDF)

13.    Guidance Notes for Online Application — Net Asset Assessment (PDF)

14.    Reference Guide for Net Asset Assessment (PDF)

15.    Net Assets Statement — the prescribed form (PDF)

16.    Guidance Notes for Online Application — Assessment of Investment Requirements (PDF)

17.    Permissible Investment Assets Statement — the prescribed form (PDF)

18.    Portfolio Maintenance Requirements Anniversary Statement — the annual form (XLSX)

19.    Guidance Notes for PMR Anniversary Statement (PDF)

20.    Guidance Notes for Submission of Online Notifications by Financial Intermediary (PDF)

21.    New CIES Contract Template — the model contract with a financial intermediary (PDF)

Immigration Department

22.    Immigration Department — New Capital Investment Entrant Scheme: entry, period of stay, extensions and unconditional stay

23.    Immigration Department — New CIES frequently asked questions

24.    Immigration Department — Fee Tables, including the specified scheme application fee and the visa fee

25.    Immigration Department — new application fees for specified schemes with effect from 26 February 2025

26.    Immigration Department — suspension of the former Capital Investment Entrant Scheme from 15 January 2015 and the transitional arrangements

27.    Immigration Department — right of abode: eligibility of persons who are not Chinese nationals

28.    Immigration Department — meanings of “ordinarily resident” and “right of abode”

29.    Immigration Department Annual Report 2015, chapter 1 — lifetime results of the former CIES as at 31 December 2015

30.    Immigration Department — the former Capital Investment Entrant Scheme: the 2 + 3 + 3 stay pattern and the entrant requirements

Hong Kong Government policy documents

31.    The Chief Executive’s 2025 Policy Address — full text, paragraph 102, under “International Asset and Wealth Management Centre” (PDF)

32.    2025 Policy Address — highlights page

33.    2023 Policy Address, paragraph 57 — announcement of the new scheme at HK$30 million excluding real estate

34.    2024 Policy Address, paragraph 38 — residential property admitted and the private company route announced

35.    Financial Services and the Treasury Bureau family office portal — enhancement measures for the New CIES, including the change to the private holding company conditions from 1 March 2026

Government press releases and replies in the Legislative Council

36.    19 December 2023 — Government announces details of the new Capital Investment Entrant Scheme

37.    19 April 2023 — reply on the scheme then in preparation

38.    12 June 2024 — LCQ4: about three weeks per stage and the statistics for the first three months

39.    16 September 2024 — launch of the online application platform

40.    16 October 2024 — enhancement measures, including the admission of residential property

41.    7 January 2025 — details of the enhancement measures

42.    26 February 2025 — introduction of application fees for specified schemes

43.    26 March 2025 — the net asset holding period cut from two years to six months

44.    25 May 2025 — first-year review of the scheme

45.    2 March 2026 — two-year milestone: 3,166 applications, 1,762 formal approvals, HK$55,636 million of verified investment

46.    13 April 2026 — speech by the Secretary for Financial Services and the Treasury: over 3,300 applications and about HK$99 billion of expected investment

47.    13 October 2010 — the former scheme’s threshold raised to HK$10 million and real estate suspended as an asset class

48.    14 January 2015 — suspension of the former Capital Investment Entrant Scheme

49.    New CIES — two-year milestone release with the breakdown of investment by asset class

50.    New CIES — opening of applications from 1 March 2024

Professional regulation of the reporting requirement

51.    Hong Kong Institute of Certified Public Accountants — Circular CIES3000R on reporting under Rules 4.2, 4.4, 4.6 and 6.2 of the New CIES, updated to 8 May 2026 (PDF)

Hong Kong Investment Corporation Limited (CIES Investment Portfolio)

52.    HKIC — operational details of the CIES Investment Portfolio, November 2024: a seven-year term from 1 January 2025

53.    HKIC — invitation for proposals for the portfolio administrator, December 2024

54.    HKIC — appointment of the 2024 batch managers and of BOCI-Prudential Trustee as administrator, 30 December 2024

55.    HKIC — operational details of the 2025 Capital Batch, 31 October 2025: a minimum size of HK$2 billion and a seven-year term from 1 January 2026

56.    HKIC — appointment of the ten managers of the 2025 Capital Batch, 2 December 2025

57.    HKIC — newsroom

Inland Revenue Department

58.    IRD — Certificate of Resident Status: the residence criteria for individuals and the 180-day and 300-day tests

59.    IRD — Profits Tax: the territorial basis of taxation

60.    IRD — the foreign-sourced income exemption (FSIE) regime

61.    IRD — Departmental Interpretation and Practice Notes No. 10: capital versus trading transactions in securities (PDF)

62.    IRD — the family office tax concession: the FIHV definition, the HK$240 million threshold of Schedule 16C assets managed by an eligible SFO, the two full-time employees and the HK$2 million of expenditure

Comparable programmes in other jurisdictions

63.    Singapore Economic Development Board — Global Investor Programme, the official programme page

64.    Singapore Economic Development Board — GIP Factsheet: the three investment options and the S$20,000 application fee (PDF)

65.    Singapore Economic Development Board — changes to the Global Investor Programme in force from 15 March 2023

66.    UAE Government portal u.ae — Golden Visa: the AED 2 million threshold, five years for real estate and ten years for public investment

67.    GDRFA Dubai — issuing a golden residence permit to investors: the AED 2 million threshold and a ten-year term on the property route

A note on sources and levels of confirmation. The Scheme Rules — including paragraphs 1.12, 2.1, 4.2, 4.10, 4.12, 5.1, 5.2, 5.3, 6.1 and 7.1, together with NOTES 1 to 9 and their amendment dates — were read directly from the current PDF on newcies.gov.hk. Paragraph 102 of the 2025 Policy Address was read from the full text of the address rather than from the highlights page: the highlights page mentions only the reduction of the price threshold from HK$50 million to HK$30 million, and it is the full text that records that the increase of the cap to HK$15 million is for non-residential property with no price threshold. The residential sub-cap itself is not buried at all — NOTE (8) and paragraph 5.2 of the Scheme Rules both state that residential remains capped at HK$10 million. The characterisation of the accountant’s report as an agreed-upon procedures engagement under HKSRS 4400 (Revised), and the 8 May 2027 effective date of the updated circular, were read from the text of the HKICPA circular itself. The lock-up terms of the CIES Investment Portfolio batches are confirmed by two separate Hong Kong Investment Corporation announcements: November 2024 for the 2024 batch and October 2025 for the 2025 batch.

What could not be confirmed, and is therefore not asserted here. The Legislative Council website (legco.gov.hk) is unreachable by automated access: the TLS certificate chain fails validation and archive mirrors are likewise closed. No paper hosted on legco.gov.hk is cited in this article. The Government’s written replies to Legislative Council questions — LCQ2 of 19 April 2023, LCQ4 of 12 June 2024 and LCQ9 of 26 March 2025 — are used, but from their official texts on info.gov.hk. The management fees of the CIES Investment Portfolio, the methodology for valuing its net assets and the operational redemption procedure at the end of the seven-year term are not published in any of the Hong Kong Investment Corporation announcements analysed; paragraph 5.3 of the Scheme Rules does state a qualified right to withdraw or receive a distribution after the lock-up expires, and this article marks the remaining parameters as unpublished rather than estimating them. No charge for the services of the New CIES Office or InvestHK is published on the official pages, so the section on costs states only the government fees. Official statistics are not published by nationality of applicant, and no country breakdown is given here. On the duration of the UAE investor golden visa two official sources diverge: the u.ae portal states five years on the real estate route while the GDRFA Dubai service page states ten years; the divergence cannot be resolved from primary sources, and the comparative table gives both figures without selecting one. The scheme’s transaction costs — stamp duty, brokerage commissions and the practising accountant’s fee — are not regulated by the Rules, and no specific amounts are stated here.

On non-primary sources. This article does not rely on publications by immigration or investment-migration consultancies, golden visa intermediaries, or “best investment visas of 2026” round-ups. Every threshold, cap, deadline and statistic is taken from the Scheme Rules, the official pages of newcies.gov.hk and immd.gov.hk, government policy documents, info.gov.hk press releases, the HKICPA circular and Hong Kong Investment Corporation announcements.

Disclaimer

This material is for information only and does not constitute legal, tax, financial, investment or consulting advice. Before taking any decision you should obtain individual professional advice reflecting your specific circumstances, jurisdiction, company status and the regulators’ current requirements.

Material current as at: August 2026.