Hong Kong New CIES property: how much of the purchase price counts?

Buying a Hong Kong home outright for HK$30 million does not, on its own, fulfil the HK$30 million investment requirement under the New Capital Investment Entrant Scheme. For residential purchases meeting the current conditions, HK$30 million is the minimum transaction price of a single property. No more than HK$10 million of residential investment counts, within a HK$15 million cap for all real estate.[1]

For a family combining a home purchase with an application, the distinction changes the funding calculation. The purchase price establishes the cost of the property; the recognised investment determines what must still be invested elsewhere. These property thresholds apply to purchases completed on or after 17 September 2025.[2]

Establish the property's eligibility

A qualifying residential investment must be in a single Hong Kong property with a transaction price of at least HK$30 million. Adding together the prices of several cheaper homes does not satisfy that condition. Mixed-use property that is partly residential also falls within the residential category.[1][3]

The non-residential category covers qualifying commercial and industrial property in Hong Kong, including offices, commercial premises, retail premises and factories, with pre-completion property also possible. Land and mixed-use property that is partly residential are excluded from that category. There is no general limit on the number of non-residential properties acquired, but the amount counted remains capped.[1][3]

The property's legal classification and the evidence supporting it therefore come before the investment calculation. A marketing description or the family's intended use is not a substitute for establishing the applicable category.

The residential cap sits inside the overall property cap

The HK$10 million residential limit is part of, not additional to, the HK$15 million real-estate limit. Together they do not create a HK$25 million property allowance.[1][2]

Suppose a qualifying residential holding has already used HK$10 million of the property allowance. Only HK$5 million remains. If the applicant then buys a qualifying non-residential property outright for HK$6 million, no more than HK$5 million of that new purchase can count in this simplified example. An applicant using no residential property could instead fill the entire HK$15 million property allowance with qualifying non-residential investment. The calculation must reflect the allowance already used and the net equity actually acquired.[3][4]

The scheme requires at least HK$27 million in permissible financial assets and real estate, plus a separate HK$3 million in the CIES Investment Portfolio. Using the full HK$15 million property allowance therefore still leaves at least HK$12 million to be invested in other permissible financial assets. The separate portfolio contribution also remains due.[1][5]

Borrowing reduces the equity available to count

A mortgaged property's full price cannot be reported as the applicant's investment. Borrowing from a Hong Kong-licensed bank or financial institution is permitted for real estate, but only the applicant's net equity counts, subject to the applicable caps.[2][3]

Consider an arithmetic illustration: a HK$30 million home, an assumed HK$21 million mortgage and no other charges or encumbrances. Net equity is HK$9 million. Although the home meets the transaction-price test, and assuming the property allowance is unused, the starting amount eligible to count is HK$9 million, not the HK$10 million maximum. The example does not suggest that a lender would approve that loan or loan-to-value ratio.[2][3]

Where equity exceeds HK$10 million, the residential sub-cap still applies. Additional personal capital does not automatically increase the recognised investment. Later sales, refinancing and surplus equity have their own portfolio-maintenance rules; the initial calculation is not a licence to withdraw money whenever the owner chooses.[2][4]

An outright purchase can require more capital than the headline threshold

Assume an applicant has no existing counted investment and buys a qualifying home outright for HK$30 million. The completion date, ownership and all other conditions are satisfied. The rest of the permissible-investment requirement will be met with financial assets, and transaction costs are excluded for this illustration.

The home costs HK$30 million but contributes HK$10 million towards the requirement. The applicant must therefore invest another HK$17 million in permissible financial assets and HK$3 million in the CIES Investment Portfolio. Personal capital committed to those assets totals HK$50 million, while the minimum recognised investment composition totals HK$30 million.[1][5]

The example applies the published limits to one purchase and funding plan. HK$50 million is not a universal government threshold, and the example is not an investment recommendation. A different purchase price, borrowing level or asset mix changes the funding needed. Stamp duties, commissions, taxes and other transaction expenses do not count as committed investment and require a separate budget.[3]

Completion determines which property thresholds apply

Purchases completed on or after 17 September 2025 fall under the current HK$15 million aggregate property cap and HK$30 million single-property residential price threshold. Earlier completed purchases remain subject to the HK$10 million aggregate cap. For residential property in that earlier period, the single-property threshold remains HK$50 million, and completion must have been on or after 16 October 2024.[1][2]

Paragraph 1.8 defines completion as the date of payment on completion or, where payment is by instalments, the date of the final instalment. Signing a preliminary agreement or paying a deposit may therefore occur on a different date from completion for scheme purposes.[2]

The investment must also fall within the overall permitted period under paragraph 2.1(d). A property bought years before an application cannot simply be assumed eligible because its present value or original price exceeds a threshold.[2]

Connect the calculation to the ownership evidence

The investment-assessment checklist calls for Land Registry records showing ownership and transaction price, proof of property type, and the mortgage deed or outstanding-loan statement. A sole proprietorship or company ownership structure requires the corresponding business-registration or ownership evidence.[4]

The property rules permit holding in the applicant's own name, through a sole proprietorship in that name, or through a company of which the applicant is the sole shareholder, subject to the scheme's conditions, including absolute beneficial ownership. The treatment of joint family assets at the earlier net-asset assessment cannot simply be imported into the later property-investment test.[1][2]

A useful purchase budget separates price, borrowing, eligible net equity, remaining category allowances and transaction expenses. It then shows the further qualifying investment required. Recognition ultimately depends on the authority's assessment of the transaction and evidence; a property at the right price does not guarantee residence approval.

Official sources

1. InvestHK: Investment Requirements, property categories, amounts and dates
2. New CIES Scheme Rules: text amended 1 March 2026, paragraphs 1.8, 2.1(d), 5.2 and 6.1(b)
3. New CIES: Investment Requirements FAQs 1, 3 and 4
4. InvestHK: Reference Guide for Investment Assessment and Anniversary Submission, property evidence and cap calculations
5. InvestHK: full New CIES Guidebook, page 4 investment composition

General policy information; individual circumstances and the competent authority’s requirements govern each application.