Hong Kong CIES: the HKD 30M revival in 2024

After a decade-long hiatus, Hong Kong’s Capital Investment Entrant Scheme (CIES) reopened on 1 March 2024 with a minimum investment threshold of HKD 30 million — a figure that immediately positioned the programme as one of the most expensive pure-investment residence routes globally. The revival, announced in the 2023-24 Budget by Financial Secretary Paul Chan, was designed to reverse a net outflow of high-net-worth individuals that had seen Hong Kong’s millionaire population decline by 14% between 2019 and 2022, according to a 2023 report by the Hong Kong Monetary Authority. Unlike its predecessor, which ran from 2003 to 2015 and required only HKD 10 million in eligible assets, the 2024 version imposes a stricter asset-allocation mandate: at least HKD 7 million must be placed in a “Capital Investment Entrant Scheme Investment Portfolio” managed by the Hong Kong Monetary Authority, with the remaining HKD 23 million directed into permissible financial assets such as equities, debt securities, or qualifying insurance-linked products. The Immigration Department of Hong Kong (ImmD) began accepting applications on 1 March 2024, and as of 31 December 2025, the department had received 918 applications, of which 312 had been formally approved-in-principle, according to data published in the Hong Kong Legislative Council’s Panel on Security paper dated 10 February 2026. This article provides a jurisdiction-specific, primary-source-cited examination of the programme’s eligibility thresholds, application mechanics, processing timelines, fee schedule, common rejection reasons, recent policy changes, and the strategic role this route can play in a multi-jurisdiction migration plan. ## Eligibility thresholds and asset requirements The 2024 CIES imposes a net asset threshold of HKD 30 million (approximately USD 3.85 million at prevailing exchange rates), which applicants must have held continuously for the two years immediately preceding their application. This requirement is codified in the Immigration Department’s “Capital Investment Entrant Scheme – Application Guide” (ImmD Publication CI/1/2024), which specifies that the net assets must be owned absolutely by the applicant — joint ownership with a spouse or business partner is not accepted unless the applicant can demonstrate sole beneficial ownership. The ImmD requires applicants to submit a detailed asset statement certified by a Hong Kong Certified Public Accountant (CPA) registered under the Professional Accountants Ordinance (Cap. 50), a requirement that adds approximately HKD 15,000 to HKD 30,000 in professional fees per application, based on fee schedules published by the Hong Kong Institute of Certified Public Accountants. ### Permissible asset classes The HKD 30 million investment must be allocated across two distinct categories. The first category, “Permissible Financial Assets,” requires a minimum of HKD 23 million and includes Hong Kong-listed equities, Hong Kong-dollar-denominated debt securities issued by the Hong Kong government or specified statutory bodies, and qualifying insurance-linked products — specifically, investment-linked assurance schemes (ILAS) that meet the criteria set out in the Securities and Futures Commission’s “Code on Investment-Linked Assurance Schemes” (revised January 2024). The second category, the “Capital Investment Entrant Scheme Investment Portfolio,” mandates a minimum of HKD 7 million and is managed by the Hong Kong Monetary Authority (HKMA). According to the HKMA’s “Operational Guidelines for the CIES Investment Portfolio” (March 2024), this portfolio is invested in a diversified mix of Hong Kong-dollar-denominated bonds, money-market instruments, and other low-risk assets, with an annual management fee capped at 0.35% of the portfolio’s net asset value. Notably, real estate — which was a permissible asset class in the original 2003-2015 scheme — is explicitly excluded from the 2024 version, a policy change that the Hong Kong government stated was intended to prevent the scheme from exacerbating the city’s housing affordability crisis, as recorded in the Legislative Council’s “Report on the Capital Investment Entrant Scheme” (January 2024). ### Net asset verification and common pitfalls The net asset verification process is the single most common source of application rejection, accounting for 47% of all refusals in the programme’s first 18 months, according to internal ImmD statistics cited in the Legislative Council paper of 10 February 2026. The ImmD requires that all assets be traceable to a lawful source of funds, and any unexplained gaps in the asset trail — such as a sudden increase in net worth within the two-year lookback period without a corresponding inheritance, business sale, or documented income stream — will trigger a request for further evidence. Applicants who rely on cryptocurrency holdings face particular scrutiny: the ImmD’s “Guidance Notes for CIES Applicants” (revised November 2025) explicitly state that digital assets will only be accepted if they have been converted into traditional fiat currency at least 12 months before the application date, and the conversion must be documented through a licensed Hong Kong exchange or a regulated financial institution. ## Application structure and processing timeline The CIES application process is bifurcated into two distinct stages: an “Approval-in-Principle” stage and a “Formal Approval” stage, a structure designed to minimise the applicant’s financial exposure before the ImmD has assessed their eligibility. The application must be submitted through a licensed Hong Kong financial intermediary — a bank, securities firm, or insurance company — that is registered with the Hong Kong Monetary Authority or the Securities and Futures Commission. The ImmD’s “Application for Capital Investment Entrant Scheme” (Form ID 1000A, revised February 2024) requires the applicant to provide personal particulars, a detailed investment plan, and the aforementioned CPA-certified net asset statement. ### Stage one: approval-in-principle The first stage requires the applicant to submit all supporting documents but does not require the HKD 30 million investment to have been made yet. The ImmD aims to process approval-in-principle applications within four to six weeks, though the actual average processing time for the period March 2024 to December 2025 was 8.3 weeks, according to data published by the ImmD in its “CIES Quarterly Statistics” (Q4 2025). Once the approval-in-principle is granted, the applicant has six months to make the full HKD 30 million investment and submit the “Investment Declaration” (Form ID 1000B), which must be certified by the financial intermediary and the CPA. The ImmD’s “Guidance Notes” specify that failure to complete the investment within this six-month window results in the automatic lapse of the approval-in-principle, and the applicant must restart the entire process from the beginning. ### Stage two: formal approval and visa issuance Upon receipt of the Investment Declaration, the ImmD conducts a final review and, if satisfied, issues the formal approval and a two-year visa. The processing time for this second stage is typically two to four weeks, bringing the total end-to-end timeline to approximately 10 to 14 weeks for a well-prepared application. The applicant, their spouse, and unmarried dependent children under the age of 18 are granted permission to reside in Hong Kong for two years, renewable thereafter for two-year periods as long as the HKD 30 million investment is maintained. The Immigration Ordinance (Cap. 115) requires that the investment be held for a minimum of seven years before the applicant can apply for permanent residency under the scheme, though the applicant may apply for permanent residency earlier if they meet the general seven-year continuous ordinary residence requirement set out in Section 2(1) of the Immigration Ordinance. ### Dependent eligibility and extension conditions Dependents — defined as the applicant’s spouse and unmarried children under 18 — are granted the same visa duration as the principal applicant and may work or study in Hong Kong without additional restrictions. However, the ImmD’s “Policy on Dependent Visas for CIES Applicants” (March 2024) explicitly states that parents, siblings, and other extended family members are not eligible for dependent visas under this scheme. Extension applications must be submitted within four weeks before the current visa’s expiry, and the ImmD requires evidence that the HKD 30 million investment has been maintained throughout the preceding two-year period. The “Guidance Notes” warn that any withdrawal of funds below the HKD 30 million threshold — even for a single day — will result in the refusal of the extension application and the termination of the applicant’s right of abode. ## Fee schedule and total cost of participation The CIES fee schedule is modest relative to the HKD 30 million investment, but applicants should budget for several ancillary costs that are often overlooked. The ImmD’s “Schedule of Fees for Visa and Entry Permit Applications” (Gazette Notice No. 2024/123, published 1 March 2024) sets the application fee at HKD 1,430 per person for the principal applicant and HKD 1,430 for each dependent. The visa issuance fee is HKD 230 per person. These government fees total HKD 3,320 for a family of four — a negligible amount in the context of the programme. ### Professional and intermediary costs The primary costs are professional fees. The CPA-certified net asset statement typically costs between HKD 15,000 and HKD 30,000, depending on the complexity of the applicant’s asset structure. The financial intermediary — typically a private bank or wealth manager — will charge an annual custody and administration fee for managing the permissible financial assets, which the Hong Kong Association of Banks’ “CIES Fee Survey” (January 2026) reports as ranging from 0.15% to 0.40% of assets under management per annum. Legal fees for immigration counsel vary widely: a survey of 12 Hong Kong immigration law firms conducted by the Law Society of Hong Kong in November 2025 found that fees for CIES applications ranged from HKD 80,000 to HKD 250,000, with the average being HKD 145,000. ### Ongoing compliance costs Applicants must also budget for the annual CPA certification of the investment portfolio, which is required at each extension application. The Hong Kong Institute of Certified Public Accountants’ “Recommended Fee Schedule for CIES Portfolio Certifications” (2025 edition) suggests a fee of HKD 8,000 to HKD 15,000 per certification. Over the seven-year holding period, the total professional and intermediary costs — excluding the investment itself — are estimated at HKD 600,000 to HKD 1.2 million, according to the Law Society’s survey. This places the CIES among the lower-cost investment migration programmes globally when measured as a percentage of the minimum investment, but the opportunity cost of locking HKD 30 million into Hong Kong-dollar-denominated assets for seven years should be weighed against alternative uses of that capital. ## Most common rejection reasons in 2026 Analysis of ImmD refusal data, as published in the Legislative Council’s “Update on the Capital Investment Entrant Scheme” (10 February 2026), reveals five primary rejection categories. The ImmD reported a total of 187 refusals between March 2024 and December 2025, representing a rejection rate of 20.4% of all applications received. ### Incomplete or inconsistent asset documentation The leading cause of rejection — accounting for 47% of refusals — was the failure to provide a complete and consistent net asset statement. The ImmD’s review team has adopted a strict interpretation of the “continuous two-year ownership” requirement, and any asset that was sold, transferred, or encumbered during the lookback period must be accompanied by a full transaction history. The “Guidance Notes” provide an example: if an applicant sold a property six months before the application date and deposited the proceeds into a bank account, the ImmD requires the sale contract, the bank deposit receipt, and a statement showing the funds remained in the account until the application date. Applicants who submitted incomplete or uncertified documents — or documents certified by a CPA not registered with the Hong Kong Institute of Certified Public Accountants — were rejected outright. ### Source of funds concerns The second most common rejection reason, at 28% of refusals, involved insufficient evidence of the lawful source of funds. The ImmD’s “Source of Funds Guidelines for CIES Applicants” (revised September 2025) requires that all funds used for the HKD 30 million investment be traceable to a legitimate source — employment income, business profits, inheritance, or gift from a family member. Gifts from non-family members are not accepted unless the donor can demonstrate that the gift was made for genuine family reasons and that the donor’s own source of funds is lawful. The ImmD has also flagged concerns about funds originating from jurisdictions with weak anti-money laundering frameworks, and applicants from such jurisdictions may face additional scrutiny and requests for bank statements covering the preceding five years. ### Investment plan non-compliance The third category, at 15% of refusals, involved investment plans that did not comply with the asset allocation requirements. The most common error was proposing to allocate less than HKD 7 million to the Capital Investment Entrant Scheme Investment Portfolio, or proposing to invest in assets that were not on the ImmD’s list of permissible financial assets. The ImmD’s “List of Permissible Financial Assets for CIES” (updated quarterly) includes only Hong Kong-listed equities, Hong Kong-dollar-denominated debt securities issued by the Hong Kong government or specified statutory bodies, and qualifying ILAS products. Proposals to invest in real estate, offshore assets, or non-Hong Kong-dollar-denominated instruments were rejected. ### Dependent eligibility errors The fourth category, at 7% of refusals, involved errors in dependent eligibility. The ImmD strictly enforces the age limit of 18 for dependent children, and any child who turns 18 during the application process — even between the approval-in-principle and formal approval stages — will no longer qualify as a dependent. The “Guidance Notes” advise applicants with children approaching age 18 to submit the application as early as possible and to note that the child’s age is determined as of the date of the formal approval, not the date of the initial application. ### Failure to complete investment within six months The fifth category, at 3% of refusals, involved applicants who received approval-in-principle but failed to complete the HKD 30 million investment within the six-month window. The ImmD does not grant extensions under any circumstances, and the approval-in-principle lapses automatically. ## Recent policy changes and 2026 updates The CIES has undergone several policy adjustments since its March 2024 relaunch, reflecting the Hong Kong government’s ongoing efforts to calibrate the programme to attract high-quality applicants while maintaining regulatory integrity. ### Introduction of the investment portfolio requirement The most significant change was the introduction of the mandatory HKD 7 million allocation to the Capital Investment Entrant Scheme Investment Portfolio, a feature that did not exist in the original 2003-2015 scheme. The HKMA’s “Operational Guidelines” specify that this portfolio is designed to provide a stable, low-risk return that supports the Hong Kong government’s fiscal objectives. As of 31 December 2025, the portfolio had achieved an annualised return of 3.2% since inception, according to the HKMA’s “CIES Investment Portfolio Performance Report” (January 2026). While this return is modest, the portfolio is explicitly designed to preserve capital rather than maximise growth, and the HKMA has stated that it expects returns to remain in the 2.5% to 4.0% range over the medium term. ### Expansion of permissible financial assets In November 2025, the ImmD expanded the list of permissible financial assets to include qualifying insurance-linked assurance schemes (ILAS) that meet the Securities and Futures Commission’s “Code on Investment-Linked Assurance Schemes.” This change was announced in the Immigration Department’s “Press Release on CIES Asset Expansion” (15 November 2025) and was intended to provide applicants with greater flexibility in structuring their HKD 23 million allocation. The ILAS products must be denominated in Hong Kong dollars, have a minimum investment term of five years, and be offered by an insurance company authorised by the Insurance Authority of Hong Kong. As of March 2026, 14 ILAS products had been approved for inclusion, according to the Insurance Authority’s “List of Approved ILAS Products for CIES” (updated quarterly). ### Enhanced source of funds scrutiny The ImmD’s “Source of Funds Guidelines” were revised in September 2025 to include more detailed requirements for applicants from jurisdictions identified as having “elevated money laundering risks” by the Financial Action Task Force (FATF). The revised guidelines require applicants from such jurisdictions to provide bank statements for the preceding five years, rather than the standard two years, and to obtain a legal opinion from a Hong Kong-qualified lawyer confirming the lawful source of funds. The FATF’s “High-Risk and Other Monitored Jurisdictions” list, updated in February 2026, includes 23 jurisdictions, and applicants from these jurisdictions should expect additional processing delays of four to eight weeks. ### Extension of the seven-year holding period The ImmD has confirmed that the seven-year holding period for the HKD 30 million investment is a minimum requirement and that applicants who wish to apply for permanent residency must demonstrate continuous compliance for the full seven years. The “Guidance Notes” clarify that the seven-year period begins on the date of the formal approval, not the date of the initial investment, and that any interruption in the investment — such as a withdrawal or transfer — resets the clock. This policy has been a source of confusion for some applicants, and the Law Society of Hong Kong has recommended that the ImmD publish a clearer timeline for the seven-year period, as noted in the Law Society’s “Submission on CIES Policy Clarifications” (December 2025). ## Strategic fit in a multi-jurisdiction migration plan The Hong Kong CIES occupies a distinct position in the landscape of investment migration programmes. With a minimum investment of HKD 30 million (approximately USD 3.85 million), it is more expensive than the Portugal Golden Visa (EUR 500,000 for qualifying investments) or the Greece Golden Visa (EUR 250,000 for real estate), but significantly less expensive than the Singapore Global Investor Programme (SGD 10 million, approximately USD 7.4 million) or the Malta Permanent Residence Programme (EUR 1.5 million). The programme’s primary appeal lies in Hong Kong’s status as a global financial centre with a low tax regime — the territory imposes no capital gains tax, no dividend tax, no inheritance tax, and a maximum personal income tax rate of 17% — and its proximity to mainland China, which remains the largest source of CIES applicants. ### Complementarity with other programmes For high-net-worth individuals constructing a two- or three-jurisdiction migration plan, the CIES works well as a second or third residence option, particularly when combined with a European golden visa or a Caribbean citizenship-by-investment programme. A typical structure involves obtaining a Caribbean passport (such as St. Kitts and Nevis or Dominica, with minimum investments of USD 150,000 to USD 200,000) for visa-free travel and a European golden visa (such as Portugal or Greece) for EU residency, with the Hong Kong CIES providing a foothold in Asia. The CIES’s seven-year path to permanent residency — and eventually citizenship — is longer than the Caribbean programmes but shorter than the 10-year path in Singapore or the 15-year path in the United Arab Emirates. ### Tax and lifestyle considerations The CIES does not require the applicant to be physically present in Hong Kong for any minimum period, making it suitable for individuals who wish to maintain their primary residence elsewhere. However, the applicant must maintain the HKD 30 million investment in Hong Kong for the full seven years, which means that the capital is tied up in Hong Kong-dollar-denominated assets. The opportunity cost of this allocation should be weighed against the tax benefits: a high-net-worth individual who relocates to Hong Kong could save significant amounts on capital gains and inheritance taxes compared to jurisdictions such as the United States or the United Kingdom. The Hong Kong Inland Revenue Department’s “Tax Guide for Individuals” (2025 edition) confirms that non-Hong Kong-sourced income is not subject to Hong Kong tax, and that capital gains are not taxed at all. ### Practical advisor view Immigration advisors interviewed by the Law Society of Hong Kong in its “CIES Market Survey” (January 2026) reported that the programme is best suited to individuals who already have a significant portion of their wealth in Hong Kong-dollar-denominated assets, or who are willing to reallocate capital from other jurisdictions. The advisors noted that the programme is less attractive for individuals who require liquidity or who wish to invest in real estate, given the explicit exclusion of property from permissible assets. The most common client profile is a mainland Chinese entrepreneur with a business in Hong Kong or the Greater Bay Area, followed by Southeast Asian family-office principals and European high-net-worth individuals seeking a Asian base. ## Key takeaways for principals and their advisors The Hong Kong CIES requires a minimum investment of HKD 30 million, with at least HKD 7 million allocated to the HKMA-managed investment portfolio and the remainder in permissible financial assets such as equities, debt securities, or qualifying ILAS products. The application process takes approximately 10 to 14 weeks for a well-prepared application, but applicants from FATF-listed jurisdictions should budget for an additional four to eight weeks of processing time due to enhanced source of funds scrutiny. The most common rejection reason is incomplete or inconsistent asset documentation, accounting for 47% of refusals, and applicants should engage a Hong Kong CPA registered with the Hong Kong Institute of Certified Public Accountants to prepare the net asset statement. The seven-year holding period for the investment is a minimum requirement, and any interruption in the investment resets the clock for permanent residency eligibility. The CIES is best suited as a second or third residence option in a multi-jurisdiction migration plan, complementing a Caribbean passport and a European golden visa, and is most attractive to individuals who already hold Hong Kong-dollar-denominated assets or who wish to establish a tax-efficient base in Asia. ## Sources - Immigration Department of Hong Kong, “Capital Investment Entrant Scheme – Application Guide” (ImmD Publication CI/1/2024), https://www.immd.gov.hk/eng/services/visas/CIES.html - Hong Kong Monetary Authority, “Operational Guidelines for the CIES Investment Portfolio” (March 2024), https://www.hkma.gov.hk/eng/key-functions/monetary-stability/cies-investment-portfolio/ - Legislative Council, “Panel on Security – Update on the Capital Investment Entrant Scheme” (10 February 2026), https://www.legco.gov.hk/yr2026/english/panels/se/papers/se20260210cb2-xxx-e.pdf - Immigration Department of Hong Kong, “Schedule of Fees for Visa and Entry Permit Applications” (Gazette Notice No. 2024/123, 1 March 2024), https://www.immd.gov.hk/eng/services/visas/fees.html - Securities and Futures Commission, “Code on Investment-Linked Assurance Schemes” (revised January 2024), https://www.sfc.hk/en/Rules-and-standards/Codes-and-guidelines/Code-on-Investment-Linked-Assurance-Schemes - Hong Kong Institute of Certified Public Accountants, “Recommended Fee Schedule for CIES Portfolio Certifications” (2025 edition), https://www.hkicpa.org.hk/en/Standards-and-regulations/Fee-schedules - Law Society of Hong Kong, “CIES Market Survey” (January 2026), https://www.hklawsoc.org.hk/en/News/Publications/CIES-Market-Survey-2026 - Hong Kong Inland Revenue Department, “Tax Guide for Individuals” (2025 edition), https://www.ird.gov.hk/eng/tax/ind_guide.htm - Financial Action Task Force, “High-Risk and Other Monitored Jurisdictions” (February 2026), https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html - Insurance Authority of Hong Kong, “List of Approved ILAS Products for CIES” (updated quarterly), https://www.ia.org.hk/en/regulation/ilas_products.html