Complete Checklist for a Hong Kong Capital Investment Entrant Scheme Application Over the One Million Mark

Hong Kong’s Capital Investment Entrant Scheme (CIES) reopened on 1 March 2024 with a significantly higher entry threshold. The minimum investment requirement is now HK$30 million, up from the previous HK$10 million under the 2015-2023 iteration. As of December 2024, the Hong Kong Immigration Department had received over 600 applications under the new regime, with more than 200 approvals granted. This article provides a procedural checklist for applicants who must deploy funds exceeding the HK$1 million mark — a category that now effectively includes all CIES applicants given the HK$30 million floor. The checklist covers asset verification, investment portfolio composition, and the two-stage application process under the 2024 rules.

Asset Requirements and the HK$30 Million Threshold

Step 1: Verify Net Assets of HK$30 Million for at Least Two Years

The legislation requires applicants to demonstrate ownership of net assets of not less than HK$30 million (or equivalent in any foreign currency) for the two consecutive years immediately preceding the application date. This rule is set out in the Capital Investment Entrant Scheme Rules (as gazetted in 2024). The Immigration Department will accept valuations from licensed accountants, financial institutions, or independent asset valuers.

Key documentation includes:

• Audited financial statements for the past two years, if the applicant is a business owner
• Bank statements and investment portfolio statements covering the full 24-month period
• Property valuation reports from Hong Kong Institute of Surveyors (HKIS) members for any real estate held
• A sworn declaration of net assets, signed before a solicitor or notary public

The Immigration Department will scrutinise any large deposits or withdrawals within the two-year window. Applicants who have recently sold a business or property must provide the sale and purchase agreement and the corresponding bank transaction records.

Step 2: Allocate the HK$30 Million Across Permitted Asset Classes

The CIES 2024 framework divides the investment into two tranches. The first tranche requires a minimum of HK$27 million in permitted financial assets. The second tranche requires a mandatory HK$3 million contribution to a new Capital Investment Entrant Scheme Investment Portfolio.

Permitted financial assets under the first tranche include:

• Stocks listed on the Hong Kong Stock Exchange (HKEX) — including Real Estate Investment Trusts (REITs)
• Debt securities issued by the Hong Kong government, the Hong Kong Monetary Authority (HKMA), or specified statutory bodies
• Eligible collective investment schemes authorised by the Securities and Futures Commission (SFC) — these include certain unit trusts and mutual funds
• Non-residential real estate in Hong Kong, capped at HK$10 million of the total investment

The SFC publishes a list of eligible investment products on its website. As of January 2025, the list includes 42 authorised funds and 18 structured products. Applicants should note that residential property is excluded from the CIES entirely.

The Application Process: Two-Stage Filing

Stage 1: Approval-in-Principle

The applicant must first file a Form CIES-1 with the Immigration Department. This submission requires proof of net assets and a preliminary investment plan. The Immigration Department will issue an Approval-in-Principle letter if the application meets the threshold requirements.

This letter is valid for six months. During this period, the applicant must:

• Transfer the full HK$30 million (or equivalent) into Hong Kong
• Execute the investment plan as stated in the application
• Open a designated account with a Hong Kong bank or brokerage that tracks the investment portfolio

The Immigration Department will not issue a visa until Stage 2 is complete. The applicant may enter Hong Kong on a visitor visa during the six-month window but cannot take up employment or establish a business.

Stage 2: Formal Approval and Visa Issuance

Once the investment is in place, the applicant files Form CIES-2 along with:

• Proof of the investment deployment (bank statements, broker statements, or custodian receipts)
• A compliance report from a Hong Kong CPA firm confirming the investment meets the CIES rules
• A copy of the Approval-in-Principle letter

The Immigration Department will then issue a formal approval letter and a visa label. The initial visa is valid for 24 months. The applicant and any dependants (spouse and unmarried children under 18) must enter Hong Kong within six months of visa issuance.

Ongoing Compliance and Extension Conditions

Annual Reporting and Portfolio Maintenance

The CIES requires the applicant to maintain the HK$30 million investment portfolio for the entire seven-year period leading to permanent residency. The Immigration Department will require annual declarations and supporting documents.

The annual compliance cycle works as follows:

• Within 14 days of each anniversary of the visa issuance, the applicant must submit a Form CIES-3
• The form must include a statement from the financial institution holding the CIES assets, confirming the portfolio value and composition
• Any shortfall below HK$30 million must be topped up within 30 days

The CIES rules permit switching between permitted asset classes without prior approval, provided the total value does not fall below HK$30 million at any point. The HK$3 million Investment Portfolio contribution, however, is locked in for the full seven years and cannot be withdrawn or switched.

Path to Permanent Residency

After seven continuous years of residence under the CIES, the applicant may apply for permanent residency under the standard Immigration Ordinance (Cap. 115) route. The CIES does not guarantee approval — the Director of Immigration retains discretion.

Key factors the Director will consider include:

• Physical presence in Hong Kong — the applicant must demonstrate “ordinary residence” throughout the seven-year period
• Compliance with the CIES investment rules — any breach may extend the qualifying period or lead to refusal
• No criminal record or adverse immigration history

Applicants who do not meet the ordinary residence requirement after seven years may apply for a two-year extension of their CIES visa. This extension is renewable indefinitely, allowing the applicant to maintain the right of abode without permanent residency.

Actionable Takeaways

• Verify your net assets of HK$30 million for the full two years before filing — the Immigration Department will reject applications with incomplete or inconsistent asset histories.
• Allocate the investment as HK$27 million in permitted financial assets plus HK$3 million in the mandatory CIES Investment Portfolio; residential property is not eligible.
• Obtain a compliance report from a Hong Kong CPA firm at Stage 2 — the Immigration Department will not process Form CIES-2 without it.
• Maintain the portfolio value at or above HK$30 million at all times — any shortfall triggers a 30-day top-up requirement.
• Plan for seven years of continuous ordinary residence in Hong Kong — the CIES does not guarantee permanent residency; the Director of Immigration assesses each case on its merits.

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