Introduction
Panama implemented substantial changes to its Qualified Investor Immigration program on September 16, 2026 through Executive Decree No. 17, which replaced the regulatory framework established under Executive Decree No. 722 of 2020 and its amendments.
The decree amends the qualifying investment criteria under the program and introduces more stringent requirements relating to investment valuation, source-of-funds verification, and ongoing compliance during the five-year holding period.
Below, we set out what changed, what it means for applicants at every stage, and how we can help clients navigate the new regime.
Panama Qualified Investor Immigration Program In Brief
Panama’s Qualified Investor Immigration program offers foreign nationals permanent residency in return for a qualifying investment, and much of its appeal lies in how simple and quick it is.
Investors may qualify by investing in Panamanian real estate, Panamanian securities, or a fixed-term bank deposit. Once the investment has been made, a Panamanian lawyer can submit the residency application on the investor’s behalf, even before the investor arrives in the country. If everything proceeds smoothly, the application is typically approved within one month from submission of the application.
The program is also designed with families in mind. The principal applicant may include qualifying dependents in the application. Under the 2026 rules, the program expressly provides for the inclusion of new dependents acquired after approval, including spouses and children who qualify under the applicable immigration requirements.
Key changes under Decree No. 17
- Two tiers for real estate
The most significant change introduced by Executive Decree No. 17 of September 8, 2026 is the amount of investment required for new (first-sale) property and resale (secondary-market) property. Prior to September 16, 2026, a qualifying Panamanian real estate investment of at least USD 300,000 could support an application under the Panama Qualified Investor Immigration Program, regardless of whether the property was new or resale. Under the current rules, however, the USD 300,000 threshold applies only to a new, never-occupied property acquired directly from the developer or its legal successor as a first sale. Resale properties now require a minimum investment of USD 500,000. Consequently, although some units may appear brand new, if they have already been sold, leased, occupied, or otherwise transferred into the secondary market, they will generally be treated as resale property for purposes of the Qualified Investor Program.
The decree also clarifies that certain transactions, such as inheritance, subdivisions, or corporate reorganizations, do not automatically cause a property to lose its first-sale status. Instead, the immigration authorities will examine the property's ownership and transfer history to determine whether it qualifies for the USD 300,000 first-sale investment threshold.
- Other Updates to Investment Requirements
Aside from changes to the real estate investment requirements, the decree also revisits the minimum investment requirements for Panama’s other investment routes, and the table below shows how each one compares before and after September 16, 2026.
|
Investment route |
Before Sept 16, 2026 |
From Sept 16, 2026 |
|
New, first-sale real estate |
USD 300,000 |
USD 300,000 |
|
Pre-construction (promise to purchase) |
USD 300,000 |
USD 300,000 |
|
Resale (secondary-market) real estate |
USD 300,000 |
USD 500,000 |
|
Panamanian securities |
USD 500,000 |
USD 500,000 |
|
Fixed-term deposit at Panama private licensed bank |
USD 750,000 |
USD 750,000 |
|
Fixed-term deposit, at Panama state owned banks (i.e. Banco Nacional or Caja de Ahorros) |
USD 750,000 |
USD 500,000 (new) |
As shown above, the most notable change is a new, lower threshold for fixed-term deposits at Panama’s state-owned banks. An investor can now qualify by placing USD 500,000 with Banco Nacional or Caja de Ahorros. That is USD 250,000 less than the USD 750,000 typically required for fixed term deposit at a private bank in Panama.
Additionally, Investors may still qualify with USD 300,000 committed under a Promise of Purchase and Sale Agreement for a property under construction, but where payment is made directly to the developer, a bank guarantee is now mandatory. The securities option remains at USD 500,000, to be held for a minimum of five years, though it is now divided into three subcategories: private capital funds, Panamanian sovereign bonds or other public debt instruments, and other registered corporate securities.
- Introduction of the Computable Net Value Test
Executive Decree No. 17 also introduced a new method for determining the value of a qualifying real estate investment. Rather than relying solely on the purchase price, the authorities now consider the property’s computable net value, which is calculated as the lower of (i) the amount actually paid and (ii) the supported market value of the property, less any registered liens, mortgages, or other encumbrances.
Where there is reason to question whether the purchase price accurately reflects the property’s market value, the authorities may require an independent commercial appraisal. In such cases, the valuation must be supported by a recent appraisal prepared by a qualified valuer recognized by Panama’s designated state banking institutions. The qualifying value will then be assessed using the lower of the purchase price and the supported appraised value.
- Stricter source-of-funds rules
Additionally, Executive Decree No. 17 strengthens the source-of-funds requirements for Panama Qualified Investor Immigration applicants. Qualifying investment funds must belong to the applicant, originate from a foreign source, and be supported by documentation demonstrating their ownership, origin, and traceability. Funds received through gifts, donations, or other gratuitous transfers from third parties cannot be used to satisfy the minimum investment threshold.
The decree continues to allow investments to be held through Panamanian or foreign legal entities, as well as private interest foundations. However, applicants must provide evidence establishing their status as the ultimate beneficial owner of the relevant entities and demonstrating effective control over the investment.
The decree also accepts co-ownership. A real estate purchase can be made personally, through a company or through a foundation, and may be shared between spouses or with dependents. This gives families applying together under the same visa greater flexibility in how they structure their investment.
- Tighter pre-construction protections
Regarding pre-construction real estate investments, while the investment requirement remains unchanged at USD 300,000, the decree introduces protections in the event of developer default or where the investment otherwise ceases to qualify. In such circumstances, the investor is granted a one-time period of 180 business days to substitute the investment with another qualifying investment.
The decree also introduces a new condition for investments in properties under construction made through a Promise of Purchase and Sale Agreement. Where payment is made directly to the developer, the investor must now obtain a bank guarantee, such as a standby letter of credit or an equivalent instrument, to secure compliance with the investment requirements. The guarantee must be renewed annually.
- Annual compliance for five years
Moreover, to ensure investors under the Panama Qualified Investor Immigration program continue to comply with the 5-year investment requirement following approval of the permanent residence application, evidence of the maintained investment must be submitted to the immigration authorities during the 30 calendar days preceding each anniversary of the resolution granting permanent residence.
Failure to maintain a qualifying investment, comply with the notification requirements, or complete a timely replacement investment may result in the cancellation of the immigration benefits granted under the program.
- Family, processing and citizenship improvements
Executive Decree No. 17 also introduces several practical improvements for qualified investors and their families. In addition to allowing spouses and dependent children to be included in the original application, the decree permits certain family members acquired after approval to join the investor’s residency status. A spouse married after approval, as well as a child born or legally adopted thereafter, may be added as dependents upon payment of the applicable government fees.
The decree also establishes clearer processing timelines. Once a complete application has been admitted, the Ministry of Commerce and Industries (MICI) is required to issue the investment certification within 15 business days, after which the National Immigration Service has 30 business days to issue a decision on the residency application.
The decree also creates a more structured pathway toward Panamanian citizenship. Naturalization applications filed by qualified investors and their dependents after consecutive years of residency in Panama are now submitted through MICI’s investment directorate, which verifies compliance with the investment requirements before the application proceeds under Panama's constitutional and legal framework.
What it means for Investors under Panama Qualified Investor Immigration Program
The impact of Executive Decree No. 17 largely depends on an investor’s position as of September 16, 2026, when the new rules took effect. Applications submitted before September 16, 2026 are unaffected by the latest reforms and they are still processed under the previous rules. Investors who had already made a qualifying investment, or who had entered into a binding purchase agreement before September 16, 2026, but had not yet filed their permanent residence application under the Panama Qualified Investor Immigration Program, may still benefit from the previous rules. However, this transitional protection is available only if the application is submitted within six months of the decree’s effective date, meaning no later than March 16, 2027. Once that grace period expires, any new application becomes subject to the revised investment thresholds, valuation rules, and eligibility requirements, regardless of when the funds were originally committed.
For new applicants, careful planning has become more important than ever. The distinction between first-sale and resale property means that an investment that would previously have qualified may no longer meet the minimum threshold. Additionally, investors should assemble comprehensive source-of-funds documentation before transferring any money, as the authorities now require clear evidence that qualifying funds belong to the applicant, originate abroad, and are fully traceable.
Why it pays to work with a firm that tracks program changes
The 2026 reforms to Panama Qualified Investor Immigration Program are a perfect example of how quickly immigration regulations can change and how easily misinformation can spread throughout the market.
For much of 2026, many real estate agents and industry commentators advised prospective investors that the USD 300,000 qualifying threshold would expire on October 15, 2026, and be replaced by a higher minimum investment requirement. However, the actual legislative reform arrived earlier than anticipated. Executive Decree No. 17 was published in Panama's Official Gazette on September 16, 2026, introducing significant changes to the program.
More importantly, the government’s approach differed substantially from what many industry commentators had predicted. Rather than imposing a blanket increase on all real estate investments, Panama adopted a two-tier system, where investors purchasing a new, first-sale property directly from a developer may still qualify with an investment of USD 300,000, while investments in resale properties now require a minimum investment of USD 500,000.
The Panama reforms serve as a reminder that while commentators and market participants often attempt to anticipate future changes, governments remain free to adopt entirely different approaches when legislation is ultimately enacted. Staying informed through verified legal sources helps ensure that important decisions are made based on what the law says, rather than what others expect it to say.
Having advised investors on Panama’s Qualified Investor Immigration Program since its inception, we have witnessed firsthand how frequently market expectations diverge from legislative reality. Our experience with the program enables us to monitor developments closely, interpret regulatory changes as they occur, and assess their practical implications for prospective applicants.
If you are considering the Panama Qualified Investor Immigration Program, or have an investment currently in progress, please do not hesitate to reach out to our team at contact@harveylawcorporation.com. We would be pleased to review your position under the new rules and discuss any implications the recent reforms may have for your application.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
