The new provisions introduce significant changes to the requirements and procedures applicable to foreign nationals seeking permanent residency under the Qualified Investor Program.
Through Executive Decree No. 17 of September 8, 2026, published in the Official Gazette on September 16, 2026, Panama has updated the immigration regime applicable to Qualified Investors.
The new Decree replaces the Executive Decree that had governed the Program since 2020, together with its subsequent amendments, thereby comprehensively replacing the regulatory framework applicable to obtaining permanent residency through investment.
The updated regime maintains the Program’s principal investment options while introducing specific clarifications and adjustments to their requirements and conditions.
Same investment options, new parameters:
The regime continues to provide an avenue for obtaining permanent residency in Panama by maintaining an investment for five (5) years through one of the following investment options:
New minimum investment amounts
| Investment option | Minimum amount | Principal conditions |
|---|---|---|
| First-sale real estate | B/.300,000 | The property must be new and unoccupied and acquired directly from the promoter, developer or its successor in title. |
| Secondary-market real estate | B/.500,000 | Applies when the property has previously been marketed, occupied, leased or transferred to an unrelated third party. |
| Promise to purchase real estate | B/.300,000 | The investment may be made through an authorized trust or by paying 100% of the purchase price to the developer, subject to the requirements and safeguards established in the Decree. |
| Securities market | B/.500,000 | The required amount may be met through one or more eligible investments made through a securities brokerage firm authorized in Panama. New investment instruments have been incorporated. |
| Fixed-term deposit with a private bank | B/.750,000 | The deposit must remain free of liens or pledges. |
| Fixed-term deposit with Banco Nacional de Panamá or Caja de Ahorros | B/.500,000 | A new preferential amount applies to deposits maintained exclusively with either of these state-owned banks. |
The specific requirements and conditions applicable to each investment option are set forth in the new Executive Decree.
Summary of the most relevant changes:
I. Real Estate Investment
- The new regime establishes specific criteria for investments in first-sale properties and properties acquired on the secondary market.
- The minimum investment for secondary-market properties increases to B/.500,000. Properties that have previously been sold, occupied or leased now require an investment of B/.500,000.
- New properties: the minimum investment of B/.300,000 remains applicable to new, unoccupied properties acquired directly from the promoter or developer.
- New parameters have been established for evidencing the minimum investment amount. The authorities may also require a commercial or private appraisal when the property’s characteristics raise reasonable questions regarding the declared purchase price, the amount effectively paid or its value in the real estate market.
- Residency under the promise-to-purchase option may not be supported by promises to purchase whose combined duration exceeds three years.
II. Securities Investments
- The minimum investment amount of B/.500,000 remains unchanged.
- Eligible instruments include private equity funds, venture capital funds and other registered investment funds, government bonds, shares, corporate debt instruments, mutual funds and real estate investment trusts (REITs).
III. Fixed-Term Deposit Investments
- Reduced amount for state-owned banks: the minimum investment is reduced to B/.500,000 when the deposit is maintained with Banco Nacional de Panamá or Caja de Ahorros.
- For deposits maintained with private banks, the minimum amount remains B/.750,000.
IV. Obtaining Panamanian Citizenship
- New filing location for naturalization applications: Qualified Investors and their dependents may submit their applications for Panamanian citizenship by naturalization, after five years of residency and in accordance with the Constitution, through the filing office of the National Investment Directorate of the Ministry of Commerce and Industries (MICI).
- MICI certification confirming that the investment remains in effect: the Decree requires MICI to issue a certification addressed to the National Immigration Service (SNM), confirming that the investment remains in effect and continues to meet the requirements of the Qualified Investor Program. This certification will support the naturalization application.
V. Other Significant Changes
- Subsequent inclusion of dependents: children born or adopted, and spouses through a marriage entered into after the approval of the principal applicant’s residency, may subsequently be included and obtain permanent residency directly.
- Deadline for annual confirmation of the investment: the investment must be confirmed before MICI each year within the 30-day period preceding the anniversary of the residency resolution.
- Notification of termination or modification of the investment and reinvestment: any termination of or change to the investment must be reported within 30 days. From the date of such notification, the investor will have 90 days to make a new investment that complies with the Program’s requirements.
- Validity of the Investment Certification: the certification will remain valid for three months. MICI must issue it within 15 business days. If the application is incomplete or defective, or contains documentation that does not comply with the established requirements, the applicant will have 15 business days to remedy the deficiencies; otherwise, the application will be closed and archived.
VI. Transitional Provisions and Pending Applications
- Effective date: Executive Decree No. 17 became effective on September 16, 2026.
- Investments made and binding contracts perfected before that date may qualify under the previous regime, provided that the corresponding application is filed within six (6) months following the effective date of the new Decree.
- Applications already filed with MICI or the SNM will be governed by the regulations in effect at the time of filing, without prejudice to the application of any provision that may be more favorable to the applicant.
Conclusions and recommendations:
The updated regime does not alter the fundamental nature of the Qualified Investor Program. However, it formally replaces the previous regulatory framework and establishes new rules for its implementation.
Accordingly, both investors whose applications are already in progress and those considering filing a new application should carefully analyze the transitional provisions and the requirements applicable to their selected investment option.
How We Can Assist
Our team can assess the eligibility of the proposed investment, review contracts and ownership structures, coordinate the issuance of the Investment Certification before MICI and manage the permanent residency application before the SNM.
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.
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