Hong Kong New CIES Property Investment and the HK$30 Million Threshold: How Can Financial Assets Bridge the Shortfall?

Eligible Hong Kong real estate may count for no more than HK$10 million towards permissible investments under the New CIES. Therefore, where real estate is counted at the cap, the applicant must still make up the HK$30 million threshold with HK$20 million in non-real-estate permissible investments, including HK$3 million in the CIES Investment Portfolio.

Author: Au Yi-hon (CPA)

This article is compiled based on information available on the official website of Invest Hong Kong’s New Capital Investment Entrant Scheme (New CIES) as at 18 July 2026. New CIES rules, asset eligibility, documentation requirements and financial intermediary information may be updated. Before submission, applicants should rely on the latest official guidance and written confirmation for their individual case.

How Do the Two HK$30 Million Requirements Under New CIES Differ?

As at 18 July 2026, New CIES requires applicants to have continuously held net assets of no less than HK$30 million throughout the two years preceding the date of application, and separately to complete investments of no less than HK$30 million in permissible investment assets.

This is the distinction most easily confused and most consequential for property owners’ planning. The net-assets assessment focuses on the applicant’s overall financial capacity during the specified two-year period, whereas the permissible-investment assessment counts only investments that meet New CIES requirements concerning asset category, amount, holding and documentation. These two requirements are separately addressed under InvestHK New CIES Eligibility and the related investment rules.

From an accounting reconciliation perspective, the two HK$30 million requirements should not be mechanically added together to conclude that HK$60 million must be held at the same time. The assessment dates and subject matter of the two requirements differ; however, cash flows arising from asset restructuring, property sales, mortgage repayments and transfers into investment accounts must be fully traceable and substantiated.

How Much Can Hong Kong Real Estate Count Towards New CIES?

Hong Kong non-residential real estate may qualify as a New CIES permissible investment asset. Hong Kong residential property with a transaction price of no less than HK$50 million may also be included, but all real estate may collectively be counted only up to HK$10 million.

In other words, even where an applicant holds a Hong Kong property with a transaction price or market value substantially exceeding HK$50 million, that property can contribute no more than HK$10 million towards the HK$30 million permissible-investment threshold. For residential property, the official threshold is the transaction price, rather than a subsequent market valuation alone. Asset categories and conditions should be determined by reference to InvestHK New CIES Investment Requirements and Permissible Investment Assets Information.

Formula for Calculating the Amount of Real Estate That May Be Counted

When real estate is counted at the HK$10 million cap, the applicant must still make up the balance with HK$20 million in non-real-estate permissible investments, of which HK$3 million must be allocated to the CIES Investment Portfolio.

The table above illustrates only the allocation of threshold amounts and does not constitute investment advice. The amount ultimately recognised for a property depends on the official assessment of the asset, holding structure, relevant timing, documentation and case-specific facts.

How Should a HK$20 Million Property Shortfall Be Made Up with Financial Assets?

Where real estate is counted at the HK$10 million cap, the remaining HK$20 million must consist of non-real-estate permissible investments. Of that amount, HK$3 million must be invested in the CIES Investment Portfolio, while at least HK$17 million must be allocated to other eligible categories.

The HK$3 million invested in the CIES Investment Portfolio is included within the HK$30 million investment requirement; it is not an additional HK$3 million on top of the HK$30 million. The remaining allocation must first be confirmed as permissible investment assets before considering liquidity, concentration, currency, maturity, exit costs and the individual’s risk tolerance.

Confirm Asset Eligibility Before Discussing Allocation Percentages

Permissible investment assets listed by InvestHK include, but are not limited to, Hong Kong-listed equities, eligible debt securities, certificates of deposit and subordinated debt issued by authorized institutions, eligible collective investment schemes, limited partnership funds, Hong Kong-listed real estate investment trusts, and eligible private-company investments. Each asset class has its own issuer, listing, management, currency or other applicable conditions. Eligibility cannot be determined by the product name alone.

• Ring-fence the mandatory allocation first: Reserve HK$3 million of the overall HK$30 million for the CIES Investment Portfolio.
• Then calculate the countable real-estate amount: Calculate the funding shortfall based on the actual countable amount between HK$0 and HK$10 million, rather than a property’s advertised price or subjective valuation.
• Use permissible categories to make up the balance: Confirm that the product itself meets New CIES conditions, and retain purchase, custody, valuation and source-of-funds documentation.
• Allow for liquidity and replacement flexibility: Before selling, redeeming or replacing an investment, verify the maintenance and replacement rules then in force to avoid inadvertently affecting compliance status.

How Should Financial Intermediaries Be Verified So That Product Sales Are Not the Only Focus?

Financial assets intended for New CIES should first be checked against InvestHK’s published financial intermediary information to determine whether the intermediary can provide the relevant New CIES documentation, rather than being selected solely on the basis of product returns, private-banking relationships or market profile.

InvestHK provides New CIES Financial Intermediaries Information as a starting point for verification. Where authorized institutions or securities services are involved, the nature of the services should also be checked against the Hong Kong Monetary Authority Register of Authorized Institutions and Local Representative Offices and the SFC Public Register of Licensed Persons and Registered Institutions. Inclusion in the information does not constitute government endorsement of a particular investment product, investment performance or case eligibility.

1. Verify the financial intermediary’s name and the date on which the information was updated in the official resource.
2. Based on the intended banking, securities, fund-management or other services, verify the relevant regulatory registration or licensing information.
3. Before executing a transaction, obtain written confirmation that the intermediary can provide the account, custody, transaction and valuation documents required for a New CIES application in respect of the specified asset.
4. Check each product individually to confirm that it is a permissible investment asset, as a suitable intermediary does not mean that all of its products are eligible.
5. Include product documents, subscription or trading records, source-of-funds evidence and position records in a single evidence file.

Scenario Calculation: If You Hold a HK$60 Million Residential Property, How Much More Must You Invest?

Where eligible Hong Kong property may be counted only up to HK$10 million, holding a residential property with a transaction price of HK$60 million does not increase the countable New CIES investment amount above HK$10 million.

The following is a hypothetical scenario, not an actual client case, and does not constitute investment, tax, legal or immigration advice.

• The applicant holds a Hong Kong residential property with a transaction price of HK$60 million. Assume that it meets the transaction-price threshold for residential property and is confirmed by the authorities on a case-specific basis as eligible for inclusion as a permissible investment.
• The property may count for no more than HK$10 million towards the New CIES investment amount, rather than HK$60 million.
• The applicant must separately allocate HK$20 million to non-real-estate permissible investments, including HK$3 million in the CIES Investment Portfolio and at least HK$17 million in other eligible assets.
• At the same time, the applicant must still use documentation relating to assets, liabilities, title and valuations during the two years preceding the application to demonstrate net assets of no less than HK$30 million at every relevant point in time.

The key issue in this scenario is not how expensive the property is, but the cap on the amount that may be counted, whether the balance investments fall within permissible categories, and whether the two-year net-assets evidence can withstand asset-and-liability reconciliation.

What Are Common Practical Misconceptions for Property Owners Applying for New CIES?

The most common error is to mistake evidence of HK$30 million in net assets for completion of HK$30 million in permissible investments. These are assessed under different conditions.

• Misconception 1: A property with a market value of HK$50 million can be counted in full at HK$50 million. Many property owners overlook that all real estate may collectively count for no more than HK$10 million. Residential property must first meet the condition of having a transaction price of no less than HK$50 million.
• Misconception 2: If I have HK$30 million in net assets, I do not need to invest a further HK$30 million. Many applicants mistakenly assume that proof of assets is equivalent to completed investments, overlooking the category, documentation and allocation requirements for permissible investment assets.
• Misconception 3: Any bank or wealth-management product can be counted. Many investors subscribe to products based on returns or relationships before discovering that the product category, issuance arrangement or supporting documents may not meet New CIES rules.
• Misconception 4: The HK$3 million CIES Investment Portfolio is an ordinary fund position that can be freely substituted. This HK$3 million is a specified allocation within the New CIES investment requirement and cannot be directly replaced by other discretionary products.
• Misconception 5: An existing property will necessarily count directly towards the investment amount. Whether a property may be counted also depends on the asset category, transaction conditions, holding arrangements and documentation. Official rules should be checked before making decisions on sale, refinancing or portfolio transfers.

How Should an Evidence Chain for Property and Financial Assets Be Built Before Submission?

Before submitting a New CIES application, applicants should cross-check three lists—two years of net-assets evidence, the amount of property that may be counted, and the compliance of financial assets—rather than merely calculating the total market value of their assets.

1. Prepare two-year net-assets working papers: At relevant points in time, compile property title documents, valuation information, mortgages and other liabilities, bank statements, securities positions and source-of-assets documentation.
2. Determine the property’s investment treatment: Assess separately whether the property is to be used only as net-assets evidence or may be included as a permissible real-estate investment. In the latter case, no more than HK$10 million may be counted.
3. Reverse-engineer the financial-asset shortfall: Deduct the actual countable real-estate amount from HK$30 million, then earmark HK$3 million of the balance for the CIES Investment Portfolio.
4. Verify intermediary and product documentation: Before investing, confirm the financial intermediary information, product eligibility and the New CIES supporting documents that can be provided.
5. Follow official procedures for investment and immigration applications: InvestHK’s asset assessment and the Immigration Department’s visa or entry approval are separate processes. Applicants should also monitor the latest requirements in the Immigration Department New CIES Information.

Au Yi-hon (CPA)’s Practical Perspective

From the perspective of preparing accounting records, property-concentrated applications should address the balance sheet before selecting financial products. Mortgage balances, co-ownership arrangements, property transaction documents, valuation bases, sale proceeds and the subsequent cash flow into investments should be capable of being reconciled within one coherent set of documents.

Jirui International, as a Hong Kong cross-border professional services firm, can, within the scope of its engagement, coordinate the organisation of information for personalised tax planning, asset management, and immigration-related tax and financial planning. Where investment suitability, cross-border tax residency, trust or corporate ownership, property financing or New CIES eligibility is involved, the relevant qualified professionals should still assess the individual facts. Eligibility, asset recognition and immigration outcomes are ultimately determined by InvestHK and the Immigration Department.