Panama updates its Qualified Investor Residency framework

Panama has updated its Qualified Investor Permanent Residency regime through Executive Decree No. 17 of September 8, 2026, published in Official Gazette No. 30613 on September 16, 2026. The Decree replaces the framework established under Executive Decree No. 722 of 2020 and its subsequent amendments.

The revised regime preserves Panama’s investment-based permanent residency route while introducing a more detailed framework for the structuring, verification and ongoing maintenance of qualifying investments.

For international investors and families considering Panama as part of a broader relocation, investment or wealth planning strategy, the changes place greater emphasis on the economic substance of the investment, the provenance of funds and the documentation supporting the transaction.

Differentiated thresholds for real estate investments

One of the principal changes is the distinction between newly developed property and real estate acquired on the secondary market.

A minimum investment of US$300,000 applies to the initial acquisition of a new and previously unoccupied property transferred by the developer, promoter or its successor.

For property that has previously been sold, occupied, leased or transferred to an unrelated third party, the minimum qualifying investment increases to US$500,000.

The classification of the asset therefore becomes an important consideration when structuring a real estate investment intended to support a residency application.

Greater scrutiny of value and source of funds

The Decree reinforces the requirement that qualifying investments be made with the applicant’s own funds originating from a foreign source.

Amounts received as gifts, donations or other gratuitous transfers from third parties cannot be used to satisfy the minimum investment threshold. Applicants must also provide sufficient banking, financial or legal documentation to establish ownership, origin and traceability of the funds.

Investments may continue to be held through legal entities or private interest foundations, including foreign entities, provided that the applicant’s ultimate beneficial ownership and effective control of the investment are properly documented.

For real estate investments, the authorities may also require an independent commercial appraisal where objective circumstances raise questions regarding the relationship between the declared purchase price and the market value of the property. For purposes of determining the qualifying amount, the recognized investment value will generally be the lower of the amount actually paid and the reasonably established commercial value, net of relevant encumbrances.

Pre-construction investments remain available, with additional protections

A qualifying investment through a promise to purchase agreement remains available from US$300,000.

The revised framework distinguishes between investments held through a licensed Panamanian trust arrangement and transactions in which the investor pays 100% of the property price directly to the developer before completion or registration.

In the latter case, the investor’s payment must be supported by an irrevocable banking instrument issued by a licensed bank in Panama, such as a stand-by letter of credit, bank guarantee or performance guarantee.

Where a transaction fails to close for reasons attributable to the developer, the investor may substitute the investment within the periods established by the Decree. Residency supported exclusively by promise to purchase agreements may not remain under that structure for more than three cumulative years.

Securities and banking investments

The revised regime also maintains investment routes through the Panamanian securities market and the banking system.

Qualifying investments through licensed securities firms require a minimum aggregate amount of US$500,000, which must generally remain invested for at least five years. The Decree expands the description of eligible instruments, including certain investment funds, government securities and registered corporate securities.

For time deposits, the minimum qualifying amount is US$750,000 when placed with a privately owned bank holding a general banking license in Panama, and US$500,000 when placed directly with Banco Nacional de Panamá or Caja de Ahorros. The deposit must remain free of pledges and other qualifying encumbrances for a minimum period of five years.

Ongoing compliance becomes part of the residency structure

The qualifying investment must be maintained for at least five years.

During that period, the resident, acting through legal counsel, must provide annual evidence to the Ministry of Commerce and Industries confirming that the investment continues to satisfy the applicable requirements. The filing must generally be made within the 30 calendar days preceding the anniversary of the immigration resolution.

If the investment is sold, terminated, substituted or otherwise ceases to qualify before the five-year period expires, the investor must notify the Ministry and may be granted up to 90 calendar days to document an equivalent qualifying reinvestment.

This annual verification component makes post-approval monitoring part of the broader residency and investment planning process.

Defined processing periods and pre-arrival filings

Once a complete investment file has been admitted, the Ministry of Commerce and Industries has up to 15 business days to issue the Investment Certification. The National Immigration Service then has up to 30 business days to resolve the complete immigration application.

Applications may also be filed through legal counsel before the applicant and dependents enter Panama, although biometric registration and enrollment with the National Immigration Service must be completed before the corresponding immigration card is issued.

Transitional treatment of existing investments

Applications already filed before the new regime entered into force remain subject to the requirements and investment thresholds applicable at the time of filing.

The Decree also provides transitional treatment for certain investments and binding agreements completed before its effective date. These may remain eligible under the previous framework if the corresponding residency application is filed within six months following the entry into force of the new Decree.

This makes the timing of the application particularly relevant for investors who had already committed capital or entered into binding transactions before September 16, 2026.

A broader global mobility consideration

For internationally mobile individuals and families, the Qualified Investor regime now requires closer coordination between investment structure, beneficial ownership, banking documentation, real estate or financial asset selection and immigration strategy.

The revised framework also permits qualifying residents to add certain spouses and children who become dependents after the principal residency has been approved, subject to maintaining the underlying investment and satisfying the applicable requirements.

Patton, Moreno & Asvat advises international clients on Panama-based investment structures, private client matters and global mobility planning, coordinating the legal and immigration aspects of establishing a presence in Panama.