Immigration & Residency
Executive Summary
Panama has introduced a new regulatory framework for its Qualified Investor Permanent Residency Program through Executive Decree No. 17 of September 8, 2026, effective September 16, 2026.
The decree replaces Executive Decree No. 722 of 2020 and its subsequent amendments, establishing updated investment thresholds, eligibility criteria, documentary requirements, and procedures for obtaining and maintaining permanent residency.
The principal changes include:
A USD 300,000 minimum investment for qualifying newly built, first-sale real estate.
A USD 500,000 minimum investment for secondary-market real estate.
A new USD 500,000 fixed-term deposit option through Panama's two designated state-owned banks.
Expanded eligibility for investments through Panama's regulated securities market.
Stronger verification of beneficial ownership, source of funds, property valuation, and investment maintenance.
New safeguards for preconstruction investments, together with clearer administrative deadlines and family-dependent provisions.
The revised framework preserves the possibility of obtaining permanent residency through qualifying investment while imposing more detailed requirements for demonstrating that the investment is genuine, traceable, and maintained for the prescribed period.
1. Introduction: Panama's New Qualified Investor Residency Framework
Panama's Qualified Investor Program, also known as Inversionista Calificado, allows eligible foreign nationals to apply for permanent residency through qualifying investments in the country.
The program was originally established under Executive Decree No. 722 of October 15, 2020, and subsequently modified by Executive Decrees No. 109 of 2022 and No. 193 of 2024.
Executive Decree No. 17 of 2026 consolidates and replaces these provisions.
The reform also reflects Panama's stated policy of directing foreign capital toward new construction, productive investment, financial markets, and the national banking system.
For foreign investors, the regulatory changes affect not only the amount required to qualify but also the legal and financial arrangements through which an investment may be structured.
2. What Are the Main Changes Under Executive Decree No. 17 of 2026?
The following comparison summarizes the principal differences between the previous framework, as amended in 2024, and the new rules effective September 16, 2026.
Real Estate Investment
Previous framework: USD 300,000 for qualifying property.
New framework: USD 300,000 for new, first-sale property; USD 500,000 for secondary-market property.
Preconstruction Real Estate
Previous framework: From USD 300,000, subject to contractual and guarantee requirements.
New framework: From USD 300,000, with additional safeguards, substitution deadlines, and an aggregate three-year limit.
Securities Investment
Previous framework: USD 500,000 through eligible securities investments.
New framework: USD 500,000, with expressly expanded eligible instrument categories.
Fixed-Term Deposits
Previous framework: USD 750,000 through eligible banks.
New framework: USD 750,000 in private banks, or USD 500,000 at Banco Nacional de Panamá or Caja de Ahorros.
Investment Maintenance
Previous framework: Five years.
New framework: Five years, with express annual verification, notification, and reinvestment rules.
The reform does not establish a uniform USD 500,000 minimum for every investment. The amount depends on the selected investment route and its applicable conditions.
3. Real Estate Investment: New Properties vs. Secondary-Market Properties
One of the most significant changes is the introduction of separate investment thresholds for first-sale properties and properties in the secondary market.
3.1 New, First-Sale Real Estate: USD 300,000
Under Article 4, a foreign investor may qualify through an investment of at least USD 300,000 in a new, unoccupied property acquired through its initial sale from the developer, promoter, or their successor in title.
The decree identifies certain transactions that do not automatically eliminate a property's first-sale status, including segregation, condominium arrangements, transfers into trusts, and qualifying corporate reorganizations that do not involve commercialization to an unrelated third party.
The property's status must be supported by appropriate documentation, which may include Public Registry certificates, construction or occupancy permits, and relevant tax records.
3.2 Secondary-Market Real Estate: USD 500,000
A higher minimum of USD 500,000 applies to secondary-market properties.
This category generally covers properties previously commercialized, occupied, leased, or transferred to an unrelated third party.
Certain transactions, such as inheritance or qualifying corporate reorganizations, do not necessarily constitute a prior sale. However, the authorities retain the power to disregard simulated arrangements intended to avoid the applicable investment threshold.
Consequently, an investor acquiring an existing property should verify its transaction history before relying on the USD 300,000 threshold.
3.3 Financing and Net Investment Value
Article 5 also clarifies how the qualifying value of real estate is calculated.
The amount recognized for immigration purposes is based on the lower of the price effectively paid and the reasonably supported commercial value, less the outstanding balance of any real security interest affecting the property.
Financing may be used for the excess purchase price, provided the transaction is documented and traceable and the qualifying net investment remains above the applicable minimum.
For example, an investor purchasing an eligible first-sale property for USD 450,000 may finance part of the acquisition, provided the qualifying net investment of at least USD 300,000 is preserved.
A property's advertised or contractual price, by itself, is insufficient to establish the qualifying investment.
4. New Property Valuation and Verification Requirements
Executive Decree No. 17 introduces more detailed verification mechanisms to determine whether an investment meets the relevant threshold.
Article 6 maintains the requirement for cadastral information issued by Panama's National Land Administration Authority (ANATI).
However, the Ministry of Commerce and Industries (MICI) may require an independent private or commercial appraisal where objective circumstances create reasonable doubts about the relationship between the declared purchase price and the property's market value.
When required, the appraisal must:
Have been issued within the preceding six months.
Be prepared by a qualified professional recognized under the applicable requirements.
Be independent of the investor, seller, developer, intermediary, and financing institution.
Identify potential conflicts of interest and support its valuation methodology.
The investor bears the appraisal cost.
The value recognized for qualifying-investment purposes cannot exceed the amount actually paid by the applicant, even if an appraisal indicates a higher property value.
Practical consideration: Investors should complete property valuation, title, financing, and source-of-funds due diligence before committing funds to an acquisition.
5. Preconstruction Investments: Additional Safeguards and Deadlines
Article 7 retains the possibility of qualifying through a promissory purchase agreement for real estate, beginning at USD 300,000, but introduces additional conditions for investments involving properties that have not yet been completed or registered.
5.1 Permitted Investment Arrangements
The investment may be structured through either:
A deposit into a trust administered by a bank or licensed fiduciary in Panama, subject to the required contractual conditions.
Payment of 100% of the property's value to the developer or promising seller.
In both arrangements, the promissory purchase agreement must be supported by an appropriate banking instrument issued by an institution licensed to operate in Panama.
The permitted instruments include a standby letter of credit enforceable on first demand, an irrevocable bank guarantee, or a performance guarantee.
The instrument must cover at least the total amount invested and remain effective until the property is completed, segregated, and registered in the investor's name.
Although the previous framework already contemplated guarantees for certain developer-payment arrangements, the new decree expressly addresses both investment structures and details the related requirements.
5.2 New Rules for Replacing an Unsuccessful Investment
Where a purchase agreement fails to close due to circumstances attributable to the developer or promising seller, the investor may replace the investment within 180 business days, calculated from the first business day following the contractual deadline.
Substitution through a new promissory purchase agreement is permitted only once.
If the second agreement also fails, the investor must use an eligible completed-property, securities, or fixed-term deposit investment to maintain the relevant immigration status.
Additionally, the cumulative period during which residency is supported exclusively by promissory purchase agreements cannot exceed three years.
Failure to complete or replace the investment within the applicable period may result in cancellation of the residence permit.
6. Expanded Securities Investment Opportunities
Article 8 establishes a minimum aggregate investment of USD 500,000 through a securities firm licensed by Panama's Superintendency of the Securities Market (SMV).
The decree expressly recognizes several categories of eligible instruments.
Private Equity and Venture Capital Funds
Eligible regulated funds supporting productive investments, businesses, or strategic projects in Panama.
Government Bonds and Financial Instruments
Securities issued or directly guaranteed by the Republic of Panama.
Registered Corporate Securities
Eligible shares, corporate debt, mutual funds, real estate investment funds, and other regulated instruments.
The relevant securities must comply with the authorization, registration, trading, or applicable exemption conditions established by the decree.
The investor must maintain the qualifying capital investment for at least five years.
Market fluctuations not attributable to the investor do not, by themselves, constitute noncompliance, provided there has been no voluntary withdrawal, disposal, or encumbrance and the amount is restored within 90 calendar days following MICI's notification.
The eligibility of a particular security or investment fund should be confirmed before acquisition.
7. Fixed-Term Deposits: A New USD 500,000 State-Owned Banking Option
Under Article 9, foreign investors may qualify through a fixed-term deposit in Panama's banking system.
The new framework establishes two distinct thresholds.
Private Banking Institutions: USD 750,000
Minimum qualifying deposit in an eligible privately owned bank with the required general banking license.
Designated State-Owned Banks: USD 500,000
Minimum qualifying deposit at Banco Nacional de Panamá or Caja de Ahorros.
Both alternatives require a minimum uninterrupted five-year term.
The deposited funds must originate from a verifiable foreign source, and the deposit must remain free from liens, third-party financing arrangements, and pledges.
Applicants must provide the bank's original certification and an authenticated copy of the fixed-term deposit certificate.
The USD 500,000 threshold represents a new incentive specifically applicable to the two designated state-owned banks.
Practical consideration: The lower investment threshold does not guarantee account approval, deposit acceptance, or a particular rate of return. Those matters remain subject to the bank's onboarding, compliance, and commercial procedures.
8. Source of Funds, Beneficial Ownership, and Investment Traceability
The new decree strengthens the documentation required to establish the legitimacy and ownership of qualifying investments.
Articles 2, 3, and 11 require the investment to be made with the applicant's own funds, originating from a foreign source.
Amounts received as gifts, donations, gratuitous transfers, or similar arrangements from third parties cannot be used to satisfy the minimum qualifying investment.
Investors must support the transaction using appropriate banking, financial, or legal documentation. Depending on the circumstances, this may include bank letters, authenticated account statements, or notarized documentation supported by original banking evidence.
Funds already held in a Panamanian financial institution may qualify where their origin in a previous international transfer can be adequately documented.
8.1 Can a Panamanian Company or Private Interest Foundation Hold the Investment?
Yes. The decree expressly recognizes investments maintained through qualifying legal entities, including corporations and private interest foundations, whether incorporated in Panama or abroad.
However, the applicant must demonstrate beneficial ownership and effective control of the underlying investment.
Where the entity is foreign, supporting corporate documents may require apostille or legalization and an authorized Spanish translation.
The use of a legal entity does not eliminate the obligation to establish the identity of the ultimate beneficial owner or demonstrate the investment's origin and traceability.
8.2 Joint Investments by Spouses and Dependents
Article 3 addresses investments held jointly or through a legal entity with multiple beneficial owners.
As a general rule, each principal applicant must independently satisfy the minimum qualifying investment.
An exception permits the investment to be treated jointly where the principal applicant and their spouse or qualifying dependents are included in the same application, subject to proof of their respective legal interests and the applicable minimum net investment.
These provisions should be considered when structuring real estate ownership, joint accounts, or investments through a family holding structure.
9. Immigration Fees and Application Requirements
Article 11 establishes the following immigration-related payments.
Principal Applicant
National Treasury: USD 5,000.
National Immigration Service: USD 5,000.
Each Dependent
National Treasury: USD 1,000.
National Immigration Service: USD 1,000.
The payment to the National Immigration Service is established as a repatriation deposit. The separate payment to the National Treasury relates to immigration processing rights.
These amounts do not include the qualifying investment itself, professional fees, banking expenses, notarial costs, translations, apostilles, or other transaction-related charges.
Applicants must also comply with the applicable common immigration requirements under Article 28 of Decree Law No. 3 of 2008, except as expressly provided by the new decree.
10. Investment Maintenance: Five-Year Requirement and Annual Verification
Article 12 establishes detailed requirements for maintaining the investment supporting permanent residency.
The qualifying investment must remain in place for a minimum of five years.
During this period, the investor must:
Verify and document the investment's continued existence annually through MICI.
Submit the applicable supporting documentation within the 30 calendar days preceding the anniversary of the immigration resolution.
Notify MICI within 30 calendar days if the investment is disposed of, replaced, or ceases to exist.
Complete a qualifying replacement investment within the applicable 90-calendar-day reinvestment period, where required.
Failure to replace or restore the qualifying investment within the prescribed period may result in cancellation of permanent residency.
For preconstruction properties, specific annual evidence of trust disbursements or the continued validity of the applicable bank guarantee is required.
Practical consideration: Permanent residency under this program should not be treated as permission to immediately liquidate the qualifying investment. The investor must maintain documentary and financial controls throughout the required five-year period.
11. New Processing Deadlines and Special Application Procedures
Executive Decree No. 17 clarifies administrative deadlines for investment certification and immigration approval.
Under Article 15, MICI has a maximum of 15 business days to issue the investment certification following admission of a complete application.
Where the application is incomplete or defective, the applicant is granted 15 business days following notification to address the deficiencies. The certification period does not begin until the file has been fully corrected and admitted.
Once certification has been issued and the complete immigration application formally received, the National Immigration Service must resolve the application within a period not exceeding 30 business days, subject to legally applicable suspensions.
Article 16 also permits applications to be submitted before the applicant and their dependents enter Panama through a duly authorized attorney.
However, biometric registration and enrollment in the immigration registry must be completed before obtaining the corresponding immigration card.
These statutory periods should not be presented as an unconditional guarantee of approval within 45 business days. Document preparation, banking procedures, required corrections, and other circumstances may affect the overall process.
12. Family Benefits: Inclusion of New Dependents
Article 17 expressly permits investors who maintain valid permanent residency and continue to satisfy the investment requirements to incorporate certain dependents after the principal application has been approved.
This includes children born or adopted subsequently and a new spouse following a qualifying marriage.
The application requires evidence of the qualifying family relationship, updated investment certification, the applicable immigration documentation, and the relevant payments.
The decree also addresses subsequent changes affecting dependent status, including the principal investor's death, divorce, and a dependent reaching the age of majority.
Such events do not automatically terminate the dependent's residence permit without an individualized administrative determination under the applicable immigration legislation.
13. Naturalization: Eligibility After Five Years of Residence
Article 14 addresses naturalization applications involving Qualified Investors and their dependents.
Foreign nationals who have completed five consecutive years of residency in Panama may seek Panamanian citizenship through the applicable naturalization procedure, subject to the Constitution and relevant legislation.
MICI is responsible for issuing certification concerning the qualifying investment, and the application is submitted through the relevant MICI investment office for the applicable immigration processing.
Permanent residency does not automatically confer citizenship. Naturalization remains subject to the applicable constitutional and legal conditions, administrative review, and approval procedures.
14. Transitional Provisions: What Happens to Existing Investors?
Articles 18 and 19 introduce transitional arrangements for investments, applications, and immigration statuses existing before September 16, 2026.
14.1 Applications Submitted Before the Effective Date
Applications filed with MICI or the National Immigration Service before the decree entered into force remain subject to the requirements, conditions, and investment amounts applicable when they were submitted, without prejudice to the immediate application of more favorable procedural rules.
Previously issued investment certifications remain valid until their expiration.
14.2 Pre-Existing Investments and Binding Contracts
Investments made and binding contracts perfected before September 16, 2026 may qualify under the previous framework, provided the corresponding application is submitted within six months of the new decree's effective date.
The resulting transitional period runs to March 16, 2027.
The decree also protects previously certified investments against retroactive application of the new valuation rules, except where objective evidence indicates falsification, simulation, fraud, or an illicit source of funds.
14.3 Conversion from the Own Economic Solvency Category
Foreign nationals with a pending application or valid status under the Permanent Residency for Own Economic Solvency category may apply to convert to Qualified Investor status within 12 months of the new decree's effective date.
However, investments made before October 15, 2020 are excluded from this transitional conversion mechanism. The investor must satisfy the applicable investment, ownership, and traceability requirements.
15. Practical Considerations for Foreign Investors
The new framework makes the structure and documentation of an investment particularly important.
Before proceeding with a Qualified Investor application, investors should evaluate the following matters.
Real Estate
Confirm whether the property meets the first-sale or secondary-market criteria.
Ownership Structure
Determine whether the investment will be held personally, jointly, or through a legal entity.
Source of Funds
Establish a documented audit trail from the foreign source to the qualifying investment.
Financing
Verify that outstanding secured financing does not reduce the recognized net investment below the minimum.
Preconstruction
Review contractual milestones, fiduciary arrangements, bank guarantees, and replacement deadlines.
Banking and Securities
Verify the institution's eligibility, regulatory status, investment terms, and applicable compliance requirements.
Ongoing Obligations
Establish a five-year monitoring calendar for annual certifications and investment maintenance.
These considerations are practical risk-management recommendations. They do not replace the statutory criteria or the authorities' individual review.
Frequently Asked Questions
What Is the Minimum Investment Required for Panama's Qualified Investor Residency in 2026?
The minimum is USD 300,000 for qualifying first-sale real estate and certain preconstruction investments. Secondary-market real estate requires USD 500,000, while securities investments require at least USD 500,000. Fixed-term deposits require USD 500,000 at the two designated state-owned banks or USD 750,000 at an eligible private bank.
Can I Obtain Permanent Residency by Purchasing an Existing Property for USD 300,000?
Under the new framework, an ordinary secondary-market property requires a minimum qualifying investment of USD 500,000. Transitional provisions may apply to eligible pre-existing investments or binding contracts.
Can I Apply Through a Private Interest Foundation or Corporation?
Yes. Qualifying investments may be held through legal entities, including private interest foundations, provided the applicant establishes beneficial ownership, effective control, and compliance with the relevant requirements.
Do I Have to Maintain the Investment After Obtaining Permanent Residency?
Yes. The decree requires the qualifying investment to be maintained for at least five years, with annual verification and applicable notification or reinvestment obligations.
Can I Include My Spouse and Children in the Application?
Yes, subject to the applicable dependent requirements. The decree also expressly allows qualifying new dependents to be added after the principal investor's approval.
Does the Qualified Investor Program Guarantee Panamanian Citizenship?
No. It provides a permanent residency route. Naturalization is a separate legal process, subject to the applicable constitutional and statutory requirements.
Can I Apply for Qualified Investor Residency Without Traveling to Panama?
The application may be submitted through an authorized attorney before the applicant enters Panama. However, the applicable biometric and immigration registration requirements must be completed before issuance of the immigration card.
Conclusion
Executive Decree No. 17 of 2026 establishes a revised framework for Panama's Qualified Investor Permanent Residency Program.
The reform differentiates new and secondary-market real estate, introduces a lower fixed-term deposit threshold for designated state-owned banks, broadens expressly eligible securities investments, and clarifies several administrative and family-related provisions.
At the same time, the decree establishes more detailed requirements concerning the source of funds, beneficial ownership, valuation, preconstruction guarantees, and ongoing investment maintenance.
For international investors considering Panama, the selected investment structure should be assessed together with the applicable immigration requirements, financial commitments, and long-term compliance obligations.
Panama Entity provides legal guidance on Panama's residency-by-investment options, investment structures, and the associated application requirements. Contact our team to discuss your specific circumstances.