Hong Kong New CIES: Is Your HK$30 Million Asset Evidence Ready?
Having assets worth HK$30 million is not the same as having a file ready for Hong Kong's New Capital Investment Entrant Scheme. The practical questions are who owns the assets, what their net value is, whether the relevant history can be demonstrated and how the qualifying investment will be completed. A family can be financially substantial yet still need considerable preparation before an application is sensible.
This guide explains how to organise an initial asset review before paying for a full New CIES application or making investment commitments. It is intended for prospective applicants and business-owning families who want to understand the work behind an asset assessment. The examples are hypothetical. They illustrate record preparation and decision-making; they are not statements that a particular asset or person will be accepted.
Start with the correct assessment
The New CIES net asset requirement concerns assets or equity of at least HK$30 million, or the equivalent in foreign currencies, to which the applicant is absolutely beneficially entitled throughout the six months preceding the application for Net Asset Assessment. The official guidance also addresses the applicant's beneficial portion of assets jointly owned with family members. The precise ownership and evidence must therefore be examined, rather than assuming that all family wealth belongs to the proposed applicant. [1]
Start by distinguishing a household wealth estimate from an applicant-specific statement. Your family may discuss assets collectively for everyday planning, while legal ownership is divided between spouses, companies, trusts and other relatives. An application needs a coherent explanation of the rights held by the person applying and the evidence that supports those rights.
Do not begin by adding the latest value of every asset associated with the family. List the owner, nature of the interest and any relevant liabilities first. That approach reveals issues early and gives the accountant or adviser a practical basis for deciding what further records or valuation work are needed.
Separate the asset assessment from the investment requirement
New CIES involves both an assessment of the applicant's existing net assets and a requirement to make qualifying investments. The official investment guidance describes a total minimum of HK$30 million, comprising at least HK$27 million in permissible investment assets and HK$3 million placed into the CIES Investment Portfolio. The financial assessment and the immigration decision are handled by different authorities with different responsibilities. [2][3]
This distinction matters when most of your wealth is tied up in a business or property. Evidence that an asset contributes to your overall net worth does not automatically show that you have cash available for the required investment. Equally, a bank balance sufficient for an investment does not necessarily explain the ownership history required for the earlier assessment.
Build two related schedules. One shows the assets proposed for assessment and their supporting history. The other shows how the investment will actually be funded, including any sale, distribution, transfer or currency conversion. Connect the schedules with clear references, but do not treat them as interchangeable. They answer different questions and may require different documents.
Confirm personal eligibility before commissioning valuations
New CIES has eligibility conditions beyond wealth. Your nationality, residence status and personal circumstances need an initial review. The Immigration Department's application guidance identifies supporting documents for different applicant categories, including evidence of foreign permanent residence where applicable. Possessing substantial assets does not remove the need to establish that the proposed applicant falls within the scheme's scope. [3]
Prepare a concise identity and status summary for the first consultation. Include the travel document held, nationality, current place of residence and any relevant permanent residence status. If your documents use different names or transliterations, flag the difference early. A professional can then identify the records needed before you spend money on a large valuation or translation exercise.
Be precise about immigration status obtained elsewhere. A residence permit, a permanent residence document and a passport may establish different things. Do not rely on a sales description of another programme to determine how Hong Kong will treat your status. Ask which exact document and legal status are relevant to your proposed New CIES application.
Create an ownership map
List each proposed asset under its legal owner and identify the interest you say belongs to the applicant. For directly held bank accounts or securities, that may begin with account documentation. For jointly held assets, record the joint owners and the basis on which the applicant's share is calculated. For a business interest, identify the company and the shares or other rights actually held.
Do not confuse signing authority with beneficial ownership. A director may control a company bank account without personally owning the cash in it. A family member may operate an account for another person. A business founder may have transferred shares years earlier while still being described informally as the owner. These arrangements require accurate explanation, not assumptions based on who usually makes financial decisions.
Use a simple diagram if the structure has several entities. Add the underlying documents beside each link, such as a share register, ownership agreement or relevant corporate record. The diagram is a navigation aid rather than proof by itself. Its purpose is to show a reviewer where the asserted rights come from and which points need professional analysis.
Calculate net value without overlooking liabilities
A headline asset value can conceal debts or restrictions that matter to an assessment. Record relevant mortgages, loans, pledges and other obligations alongside the asset. Ask the accountant how each item affects the calculation under the scheme. Do not assume that a property's market value or a portfolio statement is automatically the amount that can be counted.
Consider a hypothetical property with a substantial mortgage. The gross sale value and the owner's equity are different numbers. Similarly, a securities account may contain assets associated with margin borrowing or security arrangements. The correct treatment depends on the facts and applicable assessment rules, so collect the loan and security documents rather than presenting only the asset side.
Keep the method consistent across the file. If one property is shown at a current valuation while another uses an old purchase price, explain why. If foreign-currency assets are involved, record the currency and valuation basis used. A transparent schedule lets the reviewer investigate assumptions instead of trying to infer them from a single total at the bottom of a spreadsheet.
Reconstruct the relevant history before choosing a filing date
The assessment concerns a period of ownership and value, not simply a photograph of wealth on the day you apply. Work backwards from a proposed filing date and identify the records available for the relevant period. Ask the accountant which statements, valuations and supporting material are needed to demonstrate the requirement in your particular circumstances. [1]
Mark significant changes on a timeline. These could include a property sale, a large dividend, a transfer between spouses, a business restructuring or a change in borrowing. Explain how the records connect before and after the event. If the proceeds of a sale moved through several accounts, retain enough evidence to follow the money without counting the original asset and its proceeds twice.
Do not select a filing date solely because a marketing promotion or family preference makes it convenient. If the available history does not support that date, clarify the problem before incurring further costs. Sometimes the missing work is obtaining records; in other cases, the timing or proposed applicant may need to be reconsidered after professional review.
Review bank and securities records systematically
Prepare a list of accounts proposed for the assessment, with the holder's name, institution, currency and type of account. Record the dates covered by the statements you possess and identify gaps. Keep the original electronic files where available, since a cropped screenshot may omit the account holder, statement period or other context needed for review.
For transfers between your own accounts, create a matching entry showing the sending and receiving records. Note currency conversions and fees so that apparent differences in amounts can be explained. If an account was closed, ask the institution what historical records remain available. It is usually easier to organise this while the relevant contacts and login access are still current.
Separate the initial consultation pack from the complete supporting archive. A summary can explain the structure without exposing unnecessary account numbers or transaction details. Once the professional identifies what is required, agree on a secure way to provide the relevant records. Never send banking passwords or grant unrestricted access merely to demonstrate that an account exists.
Treat private company interests as a valuation project
For many entrepreneurs, the largest asset is an interest in an unlisted company. A founder's estimate of what the business might sell for is not a complete valuation file. Begin with the ownership records, recent financial information and a description of the business. Identify related-party balances, material debts and unusual transactions that may affect an assessment.
Ask what valuation method and supporting evidence are appropriate for the scheme and the company's circumstances. A profitable trading company, a holding company and an early-stage technology business may require different analysis. Do not assume that a fundraising announcement or a buyer's preliminary expression of interest establishes the value of your personal stake.
Explain restrictions attached to the shares. There may be shareholder agreements, transfer limitations, pledges or different classes of rights. If the business owns subsidiaries, avoid presenting the parent interest and the underlying assets as separate personal holdings without a valid basis. The objective is an evidence-backed account of the applicant's interest, not the largest possible headline valuation.
Document property and sale proceeds as a continuous story
For a property proposed as part of the asset evidence, collect the ownership record, relevant valuation material and information about borrowing or other interests. If ownership is shared, identify the parties and the applicant's asserted share. Make clear whether the property is held personally or through a company, because that affects how the interest should be described.
If the property has been sold, connect the former ownership to the sale agreement, completion statement and receipt of proceeds. Explain deductions such as mortgage repayment and transaction costs where relevant. A sale price is not necessarily the amount that arrived in the applicant's account, and an unexplained difference can create avoidable questions.
Keep the net asset review separate from a decision to buy Hong Kong property as a qualifying investment. The scheme's investment rules impose their own conditions and limits. An overseas property can raise one set of evidential questions, while a proposed Hong Kong purchase raises another. Have the intended transaction assessed before treating it as a solution to both issues.
Explain gifts and family transfers before relying on them
A transfer between relatives can be straightforward in everyday family life yet require careful explanation in a formal assessment. Record what was transferred, when, by whom and on what legal basis. Distinguish a completed gift from a loan, a future promise or an arrangement under which another person retains rights over the asset.
Ask how the transfer affects the relevant ownership history and the proposed filing date. Moving money into the applicant's account shortly before an application does not, by itself, answer every question about the preceding period. The treatment must follow the scheme's rules and the actual facts. Do not create retrospective documents or describe a repayable arrangement as an unconditional gift.
Keep the family discussion and professional review aligned. If relatives expect repayment or continued control, say so before documents are prepared. A disagreement about ownership can undermine both the application and the family's financial arrangements. Where legal advice is needed to establish the rights involved, obtain it before relying on the asset in the assessment.
Plan the designated account before buying financial assets
The New CIES website has announced a specific rule for Net Asset Assessment applications submitted on or after 1 November 2026: financial assets acquired through non-designated accounts will not count towards the investment requirement merely by being transferred into designated accounts. Qualifying financial assets must be transacted through the designated accounts. This is a stated future effective date, not a reason to assume that an existing portfolio can be moved later without review. [4]
Discuss the intended sequence with the financial intermediary and immigration team before placing orders. Identify which account will be designated, when the relevant arrangements take effect and what transaction records will be available. Ask for a written explanation of how the proposed purchases will be documented for the scheme.
Do not rush an application to avoid a date without checking the rest of the file. An incomplete asset history or unsuitable investment does not become sound because it was arranged quickly. The useful response is to establish the applicable rules for your actual filing date and organise the account, transaction and evidence process around them.
Use the accountant's role to resolve questions early
The official investment assessment process requires the applicant to engage a Hong Kong Certified Public Accountant in practice for the specified work. The scheme publishes reference material and forms for the assessment process. [2] Discuss the required professional scope early, including the work needed for the net asset file, rather than treating an accountant's involvement as a signature to obtain at the end.
Provide an organised inventory and ask for an initial gap list. This can identify missing statements, unclear ownership, valuation issues or inconsistent dates before the whole application is assembled. Agree which documents you will obtain, which work requires another professional and what assumptions need confirmation from the relevant authority.
Clarify the difference between preparing records and obtaining an outcome. Professional work can improve the quality and coherence of the submission, but it does not replace the authority's assessment. Ask what happens if additional information is requested or an asset cannot be relied on as expected. A clear engagement avoids confusion about whether further valuation, legal or accounting work is included.
Preserve liquidity for the family as well as the application
Build a cash plan that distinguishes the qualifying investment from professional fees and household needs. Include foreseeable costs of relocation, accommodation, education, insurance, travel and ongoing commitments outside Hong Kong. Obtain current figures relevant to your family rather than relying on a single generic living-cost estimate.
Consider a scenario in which a planned asset sale is delayed or an investment cannot be exited when you hoped. Would the family still have accessible funds for ordinary expenses and contractual commitments? This is a planning question, not a forecast that a problem will occur. It helps identify whether too much of the family's available wealth is being committed at once.
Review investment risk separately with the appropriate professional. Eligibility for an immigration scheme does not remove market, credit, liquidity or product risk. Understand the terms of the CIES Investment Portfolio and any other proposed asset before committing. A strong immigration file should be accompanied by a financial plan that remains workable without assuming a particular return.
Avoid treating investment compliance as automatic permanent residence
The Immigration Department explains that satisfying financial requirements and obtaining extensions for at least seven years does not itself establish that the ordinary residence and other requirements for right of abode have been met. Permanent residence needs its own assessment under the applicable rules. [5]
Discuss the family's intended use of Hong Kong residence at the outset. Some applicants plan to live primarily in Hong Kong, while others expect to travel frequently or maintain substantial commitments elsewhere. Keep the real circumstances clear rather than adopting a standard story about relocation that does not match the family's plans.
Maintain relevant records as circumstances develop and seek advice on the status actually being pursued. An investment maintenance file and a residence history answer different questions. Avoid reducing the long-term plan to a statement that keeping an investment for a certain number of years automatically produces a passport. Residence status, right of abode and eligibility for a travel document must not be conflated.
Bring a decision-ready summary to the first consultation
Prepare a one-page list of proposed assets, ownership, approximate net values, currencies and the periods for which records are available. Add a short explanation of how you expect to fund the qualifying investment. Flag jointly held assets, private company interests, recent transfers and substantial borrowing rather than leaving them to emerge late in the process.
Include your identity and residence-status summary, family composition and intended timing. The first useful outcome is a clear list of questions that require accounting, legal, investment or immigration work. Ask for the scope and price of that next stage before commissioning every possible service at once.
For an initial New CIES discussion with PremierVisa Group, provide those summaries through the assessment form and state whether your main concern is eligibility, asset history, investment funding or family settlement. Detailed records can be requested through an agreed process when needed. This allows the consultation to focus on whether your HK$30 million asset evidence is ready, what remains unresolved and which work should happen before any substantial commitment.
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