The possibility of financing a qualifying investment for a golden‑visa or citizenship‑by‑investment program varies widely. Some jurisdictions expressly permit loans or mortgages, others allow them only under strict conditions, and a number of programs ban any borrowed funds outright. Understanding the four ways financing can enter a deal—and how each country’s rules treat them—is essential for applicants whose wealth is real but not fully liquid.
How financing can be used
- Mortgage on the qualifying asset – a loan secured against the property or fund unit that generates the permit.
- Local‑bank loan – a loan from a bank within the program country, typically secured against the applicant’s assets.
- Foreign loan – borrowing abroad (e.g., against a home or portfolio in another country) with the proceeds transferred to the applicant’s account.
- Developer installment plan – the seller extends credit through staged payments, common for off‑plan property.
Most rulebooks address only one or two of these mechanisms; silence on the others often determines whether a financing structure is acceptable.
Programs that explicitly allow financing
| Country / Program | Financing rules | Key figures / conditions |
|---|---|---|
| UAE – 10‑year Golden Visa | Mortgage or partial payment accepted. A circular dated 20 Feb 2026 removed the 50 % upfront requirement. | Minimum DLD‑certified value ≥ AED 2 million (≈ US$545 k). 80 % mortgage allowed; 100 % financing prohibited. Off‑plan buyers may qualify after paying 10 % of the contract. |
| United States – EB‑5 | Court‑ordered (Zhang v. USCIS, 2020) and USCIS policy (22 Jul 2021) treat loan proceeds as cash capital, provided the investor remains personally liable. | Minimum investment US$800 k. Loans may be home‑equity, securities‑backed, family loans, or third‑party lenders. The investment itself cannot be pledged as collateral. |
| Malaysia – My Second Home (MM2H) | Local banks actively offer mortgages on the mandatory property purchase. | Loan‑to‑value up to 85 %; tenures can run for decades. |
| Japan – Business Manager Visa | Borrowed capital for the qualifying company is allowed if the loan is genuine and traceable. | Minimum capital increased to ¥30 million (Oct 2025). |
| Panama – Qualified Investor Visa | The required US$300 k must be unencumbered equity; any amount above that may be mortgaged. | Example: US$500 k property with a US$200 k loan still qualifies. |
| New Zealand – Active Investor Plus | Borrowed funds prohibited except when secured against the applicant’s own assets and liquidation would be impractical. | Carve‑out for investors preferring to borrow against a portfolio rather than sell assets. |
Programs that allow financing with caveats
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Portugal – The law bans borrowing the minimum from a Portuguese bank, but foreign‑sourced loans are permissible. Since the shift to a €500 k fund route, operators market financed subscription structures using non‑Portuguese lenders. The test focuses on the source of funds, not on whether they were borrowed.
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Greece – The qualifying amount (€250 k, €400 k or €800 k) cannot be mortgaged, yet foreign‑origin loans are accepted because the funds must simply move from the applicant’s account to the seller’s Greek account. Lawyers verify the source but do not investigate whether the money originated from a loan.
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Cyprus – For the €300 k‑plus‑VAT permanent residency, the investment must be made with foreign‑sourced funds; a Cypriot loan cannot meet the threshold. The amount that must be paid at submission is debated (some cite €200 k, others the full amount), but any borrowing must occur abroad before the wire transfer.
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Turkey – The $400 k property must be free of any mortgage or lien; off‑plan purchases require full payment in a single notarised contract. Upstream borrowing (i.e., a loan taken before the funds are transferred) is the only viable route.
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Egypt – The $300 k real‑estate contribution may be paid in installments over a maximum of one year after preliminary approval. A six‑month temporary residence permit is issued to allow the applicant to complete payments; citizenship is granted only after the full amount is received.
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Mauritius – For properties > US$750 k, the first US$750 k must be the buyer’s own foreign funds; local bank financing is allowed for any amount above that. Registration duty for non‑citizens rose to 10 % in July 2026, affecting the economics of financed purchases.
Hard prohibitions (financing not allowed)
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Caribbean citizenship programs (St. Kitts & Nevis, Dominica, Grenada, Antigua & Barbuda) – Under the 2024 Memorandum of Agreement, the $200 k minimum must be actual cash received, escrow must be in‑jurisdiction, and any developer‑financing arrangement can lead to revocation. Underselling is a criminal offence in St. Kitts.
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Saudi Arabia – Premium Residency (real‑estate track) – The SAR 4 million (≈ US$1.1 m) property must be free of mortgages and any financing.
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Malta – Permanent Residence – Only personal funds are accepted; loans and mortgages are excluded.
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Italy – Investor Visa – Explicitly forbids loans and mortgages.
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Hong Kong – Capital Investment Entrant Scheme – Borrowed or leveraged assets are excluded from the HK$30 million test.
Practical takeaways
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For applicants with illiquid assets, the UAE offers the most straightforward path: the qualifying property can carry a mortgage from day one. The U.S. EB‑5 and Malaysia’s MM2H are the next most permissive, allowing a wide range of loan structures.
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In Europe, the cash must arrive as the applicant’s own funds, but the source can be a documented foreign loan. Greece, Cyprus, and Portugal accept such upstream borrowing as long as the money lands in the seller’s account and the lender’s documentation is complete.
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In the Caribbean and several strict residency programs, any financing arrangement is a deal‑breaker. The escrow and source‑of‑funds requirements are designed to catch and reject financed deals, and authorities have shown willingness to revoke passports obtained through prohibited financing.
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Documentation is critical. Programs that permit financing often require a no‑objection certificate from the lender (UAE) or full transparency of the lender’s registration, tax returns, and bank statements (U.S. EB‑5). Failure to provide complete lender documentation can lead to outright denial, with no opportunity to cure the deficiency later.
When evaluating a golden‑visa or citizenship‑by‑investment option, the decision tree is now simple:
- Is financing allowed at all? – Check the program’s explicit rules.
- If allowed, what type of financing? – Identify whether a mortgage, local loan, foreign loan, or developer plan is acceptable.
- What documentation is required? – Prepare lender statements, loan agreements, and proof that the funds have been transferred to the seller’s account.
- Are there caps or equity requirements? – Some programs (UAE, Egypt) still require a minimum equity component or prohibit 100 % financing.
Understanding these nuances helps applicants choose a jurisdiction that aligns with their financial structure and avoid costly rejections or future revocations.
Source article: www.imidaily.com
