New CIES applicants: the designated account rule from 1 November 2026

Context

The New Capital Investment Entrant Scheme (New CIES) opened on 1 March 2024. It allows people with substantial investable assets to obtain residence in Hong Kong by committing to invest in the city, and, like other residents, they may apply for permanent residence after seven years of ordinary residence.

The process has two main stages. First, the Office for Attracting Strategic Enterprises (OASES), part of InvestHK, assesses whether the applicant meets the net asset requirement, broadly HK$30 million in net assets held over the prior six months. After approval in principle, the applicant has a set period to make the committed investment of HK$30 million: at least HK$27 million in permissible investment assets, such as listed shares, bonds, certificates of deposit, eligible funds, limited partnership fund interests and certain insurance products, and HK$3 million in the CIES Investment Portfolio managed by the Hong Kong Investment Corporation. Permissible investments must be held through designated accounts opened for the scheme.

The scheme has proved popular. According to a government paper to the Legislative Council, by 18 June 2026 it had received 3,967 applications, with 2,377 approved and more than HK$119 billion invested. Data as at the end of February 2026 showed investments in funds accounted for 38.6% of the total, equities 29%, investment-linked assurance schemes 9.9%, the CIES Investment Portfolio 9.9% and debt securities 9.5%.

What changed

The New CIES website has published an important update to its FAQ on investment requirements. For all Net Asset Assessment applications submitted on or after 1 November 2026, financial assets acquired through non-designated accounts will not be treated as meeting the investment requirement. Transfers of financial assets from non-designated accounts into designated accounts will no longer be accepted. Only financial assets transacted through designated accounts will count towards the committed investment.

Until now, many applicants have met part of their commitment by transferring existing holdings, such as shares or funds already held with a private bank, into their designated accounts. Advisory firms noted the change in September; Conatus Mobility, for example, published a summary on 18 September. Applicants who submit from 1 November must instead purchase qualifying assets within designated accounts after approval in principle.

The family office route

A separate measure took effect on 1 March 2026. An applicant can now hold scheme investments through a private company wholly owned by the applicant, incorporated in Hong Kong and used only for permissible investment assets. The company must take the form of a family-owned investment holding vehicle (FIHV) or family-owned special purpose entity under the Inland Revenue Ordinance, with the FIHV employing at least two full-time staff in Hong Kong and incurring at least HK$2 million of operating expenditure there each year. It must be managed by an eligible single family office whose family's FIHVs hold at least HK$240 million in aggregate net asset value.

This gives wealthier applicants a way to combine residence with Hong Kong's family office tax regime, which the 2026 fund and family office bill has expanded.

Implications for investors, families and businesses

For prospective applicants, the timing of submission now matters. Those planning to rely on transferring existing assets should consider whether they can submit their Net Asset Assessment application before 1 November, or whether they are comfortable buying new assets through designated accounts.

For families, the change can affect portfolio construction and costs. Selling existing positions to repurchase them inside designated accounts can trigger transaction costs and, depending on the applicant's tax residence, tax on gains. Planning ahead with the bank or adviser holding the assets is sensible.

For applicants already in the process, the rule applies to applications submitted on or after 1 November, so those who have already submitted should confirm their position but are not the main target.

For larger families, the FIHV route offers more flexibility and combines immigration with an institutional structure, but brings real substance and cost commitments.

Questions to consider

• When will we submit our Net Asset Assessment application, and does that fall before or after 1 November 2026?
• Which of our current holdings would we have wanted to transfer, and what would selling and repurchasing cost?
• Are we tax resident anywhere that would tax gains on such sales?
• Does the FIHV route make sense given our total assets and family office plans?
• How does our asset allocation compare with the scheme's overall mix, and does it suit our long-term goals?

Closing

The designated account rule is a procedural change, but it closes a route many applicants relied on. It reflects a policy aim that the scheme's money should represent new investment in Hong Kong rather than relabelled holdings. Families considering the scheme should plan their timing and portfolio with that aim in mind.