NCE HK$30 Million Threshold Eligible Assets and Restrictions

Introduction

Since its launch on 1 March 2024, the New Capital Investment Entrant Scheme (NCE) has become one of the core channels for high-net-worth individuals to obtain Hong Kong resident status. The scheme sets the asset threshold at HK$30 million, but this sum is not a lump sum of freely allocatable funds; rather, it is divided into two modules: not less than HK$27 million must be invested in permissible financial assets and/or real estate, and a mandatory HK$3 million must be allocated to the “Capital Investment Entrant Scheme Portfolio” managed by the wholly government-owned Hong Kong Investment Corporation Limited (HKIC). Based on the Immigration Department, the Financial Services and the Treasury Bureau and relevant regulations, this article breaks down, item by item, the investable asset classes within that HK$30 million, the specific scope covered by each asset class, and the investment restrictions that applicants must observe, providing a policy-level reference text for those who intend to relocate to Hong Kong through this route.

Scheme Overview and the Structure of the HK$30 Million Threshold

The core design of the NCE is to exchange capital investment for an “entry permit”, rather than immediate permanent resident status. Applicants must prove that throughout the entire six-month period preceding the submission of their net asset assessment application, they have continuously and absolutely beneficially owned net assets with a net value of not less than HK$30 million, and within six months after receiving approval in principle, invest net assets of not less than HK$30 million in permissible investment assets that they absolutely and beneficially own. The Immigration Department conducts its assessment under the Immigration Ordinance (Cap. 115) and the New Capital Investment Entrant Scheme Rules (Cap. 115Z). Applicants are generally granted a limit of stay of not more than 24 months, after which they may apply for an extension of stay in accordance with the extension provisions; the extension granted is generally for a period not exceeding three years, until they have been continuously and ordinarily resident in Hong Kong for seven years, at which point they may apply to become a permanent resident or apply for unconditional limit of stay.

The investment structure of that HK$30 million is as follows:

• Not less than HK$27 million must be invested in permissible financial assets (including equities, debt securities, certificates of deposit, subordinated debt, qualifying collective investment schemes, limited partnership funds, etc.) and/or real estate, of which the total investment cap on real estate counted towards the minimum investment threshold is HK$15 million, and the investment cap on residential real estate is HK$10 million (this amendment applies to real estate investments with a completion date of 17 September 2025 or after);
• A mandatory HK$3 million is allocated to the “Capital Investment Entrant Scheme Portfolio”, managed by HKIC, with the funds locked into projects relating to Hong Kong’s long-term economic development, which applicants may not allocate at their own discretion.

The legal basis for the above structure is found in Schedule 1 to the New Capital Investment Entrant Scheme Rules (Cap. 115Z) published by the Financial Services and the Treasury Bureau, which sets out in detail the definition and restrictions of each permissible asset. During the scheme period, applicants must maintain the total market value of such investments at no lower than the required level, and must periodically submit to the Immigration Department an asset verification report signed by a practicing accountant in Hong Kong.

Detailed Explanation of Investable Asset Classes: HK$27 Million in Permissible Financial Assets and/or Real Estate

The scope for allocating the HK$27 million may appear broad, but in reality each asset is subject to strict definitions and proportional limits. According to the Immigration Department’s scheme webpage [(https://www.immd.gov.hk/hkt/services/visas/new_capital_investment_entrant_scheme.html)] and the Schedule to the Rules, permissible financial assets cover the following categories:

1. Equities

Equities listed on a recognised exchange and traded in Hong Kong dollars or RMB. Applicable exchanges include major exchanges such as the Stock Exchange of Hong Kong (SEHK), the London Stock Exchange, the New York Stock Exchange and Nasdaq, but applicants should note that equities denominated in currencies other than Hong Kong dollars or RMB may require individual assessment for eligibility. Index constituent stocks and exchange-traded funds (ETFs) may also be counted if they meet the requirements.

2. Debt Securities

Covering debt instruments issued by the Government of the Hong Kong Special Administrative Region, the Hong Kong Mortgage Corporation Limited, the Airport Authority, the MTR Corporation Limited, and other entities wholly or substantially owned by the government. In addition, debt securities listed on SEHK and traded in Hong Kong dollars or RMB, as well as bonds issued by recognised financial institutions with at least two years of operating history and rated investment grade in Hong Kong dollars or RMB, are likewise permissible. In other words, higher-risk “high-yield bonds” that fail to meet the specified rating threshold will not be accepted.

3. Certificates of Deposit

Limited to certificates of deposit issued by authorised institutions under the Banking Ordinance (Cap. 155), denominated in Hong Kong dollars or RMB, with a maturity of not less than one year. This asset class is subject to an overall investment cap: the total value of certificates of deposit held by an applicant must not exceed 10% of the investment threshold, i.e. a maximum of HK$3 million. This restriction is intended to prevent applicants from concentrating most of their funds in extremely low-risk bank instruments, deviating from the scheme’s original intent of encouraging diversified investment.

4. Subordinated Debt

Subordinated debt instruments issued by authorised institutions and denominated in Hong Kong dollars or RMB also qualify as eligible assets. However, such instruments rank behind ordinary creditors in the event of the issuer’s liquidation, carry a higher risk weighting, and applicants should assess them with caution.

5. Qualifying Collective Investment Schemes

This category has the widest scope, covering unit trusts and mutual funds authorised by the Securities and Futures Commission (SFC) under the Securities and Futures Ordinance (Cap. 571), real estate investment trusts (REITs) listed on SEHK, and open-ended fund companies (OFCs). In addition, closed-ended funds managed by SFC-licensed corporations and denominated in Hong Kong dollars or RMB are also accepted. Insurance-linked securities and investment-linked assurance schemes (ILAS) may likewise be counted if they comply with SFC rules. Applicants should note that the scheme does not accept collective investment schemes that invest solely in residential property; even if such a scheme is itself registered with the SFC, it remains ineligible if the vast majority of its assets are Hong Kong residential properties.

6. Limited Partnership Funds (LPFs)

Limited partnership funds established and registered in Hong Kong may be counted provided they comply with the Limited Partnership Fund Ordinance (Cap. 637) and invest principally in permissible asset classes. This measure is intended to align with Hong Kong’s policy of promoting itself as a private equity hub, attracting family offices and asset management companies to set up here.

Real Estate

Applicants may deploy funds into real estate in Hong Kong, with a total investment cap of HK$15 million counted towards the minimum investment threshold, of which the cap on residential real estate investment is HK$10 million. Non-residential real estate includes offices, retail shops, industrial buildings and car parking spaces; residential properties may also be counted, but the transaction price threshold for a single residential property must be HK$30 million, and this amendment applies only to real estate investments with a completion date of 17 September 2025 or after. Bare land (without any built property) is not eligible. The property must be a completed project. Investors may hold the asset directly, or invest indirectly through a special purpose vehicle (SPV) that holds the real estate, provided that such SPV is a private company incorporated in Hong Kong and holds only that property. It is worth noting that the total value of real estate counted towards the minimum investment threshold must not exceed the HK$15 million cap (of which residential real estate must not exceed HK$10 million); the excess will not be included in the HK$27 million calculation and must be made up by other financial assets.

The Mandatory HK$3 Million Portfolio: The Role of HKIC and the Policy Rationale

Compared with the previous Capital Investment Entrant Scheme, the most significant change under the NCE is the mandatory allocation of HK$3 million to a government-led investment portfolio. This portfolio is managed by the Hong Kong Investment Corporation Limited (HKIC), established in 2022, and the funds will be allocated to strategic industries and projects beneficial to Hong Kong’s long-term economy, such as innovation and technology, financial technology, biomedical science and green finance. According to a press release of the Financial Services and the Treasury Bureau [(https://www.info.gov.hk/gia/general/202401/17/P2024011700340.htm)], the lock-up period for this HK$3 million is tied to the stay period of the entire scheme, and applicants may not withdraw or transfer this portion of investment before obtaining unconditional limit of stay or permanent resident status.

HKIC has an independent investment committee and risk management framework; investment decisions are independent of the applicants, and applicants may not interfere with the portfolio’s operations or demand conversion into other assets. When the portfolio generates returns, the relevant amounts, after deduction of management fees, will accrue to the portfolio assets on a pro-rata basis and will not be directly distributed to individual investors. If an applicant ultimately fails to meet the residence requirement and exits the scheme, that HK$3 million will be refunded together with the change in the portfolio’s market value (which may result in a loss or gain), but the administrative and redemption arrangements are yet to be further announced by HKIC with implementation details.

The thinking behind this design is to ensure that the NCE is not merely a “parking” tool for personal capital, but becomes a long-term source of funding supporting the local real economy and industrial upgrading. The government estimates that, as the scheme gradually attracts applications, the portfolio’s scale will continue to expand, injecting funds amounting to tens of billions of Hong Kong dollars into the local innovation and technology ecosystem.

Investment Restrictions and Ineligible Asset Classes

Beyond positively listing permissible assets, the NCE rules also explicitly exclude various categories of investment. Should an applicant mistakenly place funds in an ineligible item, it may lead to rejection of the visa application or failure of an extension. The main restrictions are as follows:

• Residential real estate: From 17 September 2025, residential properties meeting the specified conditions may be counted towards the investment (see the real estate section above), but are subject to investment caps and the transaction price threshold; residential properties with a completion date before that day are not accepted. Rental income or capital appreciation cannot be included in the portfolio calculation.
• Land (without built property): Holding bare land is not eligible; it must be a completed building.
• Private company shares (non-SPV): Unless the company is a special purpose vehicle set up to hold real estate, ordinary private company equity does not constitute a permissible asset. Applicants may not satisfy the asset requirement by taking a stake in a family business or a start-up.
• Pure collectibles and consumable assets: Jewellery, artworks, antiques and precious metals (such as gold bars and gold coins), even if of high market value, are not permissible. Likewise, consumable assets such as yachts and private aircraft are not regarded as financial assets.
• Leveraged or derivative products: Most structured notes, warrants, callable bull/bear contracts, futures and options contracts, even if traded on SEHK, are excluded because of their high-risk and leveraged nature; however, certain notes linked to equities may be exceptions if they meet specific criteria, but applicants must confirm with the Immigration Department and a qualified professional in advance.
• Debt instruments failing to meet the credit rating requirement: As mentioned above, bonds issued by non-government entities must attain the specified investment grade rating and be denominated in Hong Kong dollars or RMB. High-yield bonds, perpetual bonds and the like will not be accepted if they fail to meet the rating threshold.
• Insurance products (non-investment-linked): Traditional life insurance, savings insurance and medical insurance, even if they carry a cash value, are not eligible assets; only the portion of an investment-linked assurance scheme recognised by the SFC that meets the relevant conditions may be counted.

In addition, applicants should note the concept of “maintaining capital”. Throughout the entire visa period, the total market value of permissible assets must at all times be maintained at no less than HK$30 million (of which HK$27 million is financial assets and/or real estate, and HK$3 million is the book value of the portfolio). If market fluctuations cause the asset market value to fall, the applicant need not immediately make up the shortfall, but the Immigration Department will review the asset position of the preceding period when processing an extension. If an applicant actively sells part of the assets and thereby causes the portfolio value to fall below the threshold, they must repurchase eligible assets within 30 days of the sale and retain transaction records for inspection.

Key Points on Eligibility and the Application Process

The NCE application procedure is divided into two stages: the “net asset assessment” and the “investment requirement assessment”. Applicants must first submit documents to Invest Hong Kong proving that throughout the entire six-month period preceding the submission of their net asset assessment application, they have continuously and absolutely beneficially owned net assets with a net value of not less than HK$30 million. The asset classes contemplated at this stage are relatively loose; they may include overseas real estate, private company equity, cash deposits, etc., and need not yet have been converted into permissible assets. After Invest Hong Kong approves the assessment, it issues a “Certificate of Compliance with the Net Asset Requirement”; on the strength of this, the applicant submits a visa application to the Immigration Department, and upon approval in principle may enter Hong Kong and complete the investment within six months.

After completing the investment, the applicant then engages a practicing accountant in Hong Kong to issue a report, and submits it together with relevant proof (such as bank statements, holding records, property sale and purchase agreements and stamp duty certificates, etc.) to the Immigration Department, whereupon formal approval is granted and a limit of stay of generally not more than 24 months is given. For each subsequent extension, the applicant must prove that the invested assets still comply with the scheme rules and submit the latest portfolio report.

From a practical standpoint, applicants are well advised to consult a team of lawyers and accountants familiar with the scheme rules when planning their asset allocation, so as to avoid delaying their status application through technical non-compliance. In particular, the valuation of real estate and the SPV structure, the eligibility of collective investment schemes, and the calculation of the certificate of deposit cap all require precise documentary preparation.

Conclusion

The NCE’s HK$30 million threshold is not a simple round number, but a finely designed asset allocation framework. The HK$27 million in permissible financial assets and/or real estate gives applicants ample investment freedom, yet the restrictions and caps on each category (for example, the 10% cap on certificates of deposit and the HK$15 million overall cap on real estate) mean that the asset diversification strategy must be carefully planned. The mandatory HK$3 million portfolio, meanwhile, links personal wealth to Hong Kong’s long-term economic development, not only reinforcing the public-policy rationale of the scheme but also adding a degree of policy-directed risk to the applicant’s funds. Those who are interested should repeatedly study the official documents of the Immigration Department [(https://www.immd.gov.hk/hkt/services/visas/new_capital_investment_entrant_scheme.html)] and the Financial Services and the Treasury Bureau, and conduct a comprehensive legal and tax due diligence before asset allocation, so as to ensure that every step meets the scheme’s requirements and pave the way to obtaining permanent resident status after seven years.

This article is for information reference only and does not constitute legal advice. Anyone with questions about the specific applicability of this scheme should consult a licensed lawyer and professional adviser.