IMI Logo Black

Hong Kong’s CIES: HK$10.5 Billion Influx, Zero Property Investment

Six months after Siren Chen's cautiously optimistic assessment, the HK$10.5B in approved investments suggests her confidence was well-placed.

Siren Chen
Shenzhen

Six months after Siren Chen’s cautiously optimistic assessment, the HK$10.5B in approved investments suggests her confidence was well-placed.

Half a year ago, I painted a cautiously optimistic picture of how Hong Kong’s new-look Capital Investment Entrant Scheme (new CIES) might breathe life back into the city’s economic engine. Now, looking at fresh data the Legislative Council released on March 26, we finally have a chance to measure expectations against reality.

Momentum Builds as Application Numbers Grow

When I first made my predictions, the new CIES had barely started, registering just over 300 applications in total, and the government had only approved three. 

Fast-forward to February 2025, and the picture has changed considerably. The government has received 918 applications, approved 341, and granted 756 approvals in principle. This is no longer a promising pilot—it’s a full-fledged program gaining traction.

Webinar banner

If the government approves all the applications it has on hand, Hong Kong could see an infusion of over HK$27B (US$3.5B), nearly triple what the Hong Kong Government projected back in July 2024.

Capital Allocation: Finance Wins, Property Waits

I had forecasted that the CIES would pump fresh liquidity into the financial markets, especially in collective investment schemes, equities, and debt instruments. My prediction has aged well.

Among the HK$10.5B (US$1.35B) the government has approved in investments:

  • HK$5.17B (US$663M) into eligible collective investment schemes,
  • HK$3.57B (US$458M) into equities, and
  • HK$1.77B (US$227M) into debt securities.

This validates the scheme’s design as a magnet for capital market growth, even with the real estate restriction.

Interestingly, despite the government’s expansion in October 2024, allowing luxury residential property investment for no less than HK$ 50M (US$6.4M), not a single applicant has invested in residential real estate under CIES yet.

events banner

This could suggest that the HK$10M (US$1.3M) cap on real estate investments—while well-intentioned—is too conservative to motivate significant property transactions under this scheme.

This confirms my earlier forecast that Hong Kong’s financial services sector would benefit most from the scheme. As Hong Kong has not registered any residential property purchases under the CIES, it’s clear that high-net-worth individuals are favoring liquidity and market-linked growth over traditional bricks and mortar.

Policy Enhancements: A Clear Signal to Investors

The Hong Kong SAR Government is not leaving the success of CIES to chance. At the beginning of 2025, the government introduced major enhancements, sending a clear message: Hong Kong wants your capital—and your commitment.

Key Enhancements (Effective March 1, 2025):

Relaxed Net Asset Requirement (NAR):

Investors now need only demonstrate HK$30M (US$3.8M) net assets over six months, down from two years. The government also counts family-shared assets proportionally.

Family-Owned Investment Structures Allowed:

Applicants can invest through a Family-owned Investment Holding Vehicle (FIHV) or Special Purpose Entity (FSPE), offering flexibility and aligning CIES with the city’s push to become a family office hub.

Real Estate Now in Play (with Limits):

Since October 16, 2024, single residential properties priced at HK$50M (US$6.4M) or above are now eligible investments (within the HK$10M (US$1.3M) real estate cap). While no transactions have been made under this clause yet, the door is now open.

These changes are not just tweaks—they are strategic moves to broaden access, reduce barriers, and integrate CIES into Hong Kong’s wider asset management vision.

Family Offices: Foundations Are Taking Shape

Though no official data exists yet on family offices set up by CIES applicants (as the government did not require prior tracking), the policy changes now actively encourage their establishment through structures like the FIHV. This brings the long-term potential for cross-border wealth management, talent attraction, and sustainable investment growth.

The China Connection: Hong Kong as a Gateway, Not a Proxy

The policy enhancements—particularly the inclusion of Family-owned Investment Holding Vehicles (FIHVs) and Special Purpose Entities (FSPEs)—signal a deliberate move by the Hong Kong SAR Government to compete with regional hubs like Singapore, which already leverages family offices as a conduit for investment-linked immigration programs.

At first glance, some may view these reforms as being custom-built for Mainland Chinese capital, fueling concerns—especially in Western circles—about Hong Kong’s autonomy.

But a more grounded interpretation is that Hong Kong is leaning into its traditional role as the nexus where East meets West, offering a globally trusted legal and financial system that enables Mainland investors to internationalize under rule-based, bilingual, and compliant conditions.

In this light, it’s not about Hong Kong bending westward or eastward but about staying relevant and acting as a launchpad for outbound Chinese capital while maintaining its distinct institutional advantages.

The reforms are not just about attracting money; they’re about reaffirming Hong Kong’s unique geopolitical function in an increasingly bifurcated global economy.

Time for a Real Estate Recalibration?

Despite the overall success, there’s still room for refinement. Some in the Legislative Council have proposed recalibrating the HK$50M (US$6.4M) residential threshold to HK$30M (US$3.8M). If the government implements this change, it could finally activate the scheme’s dormant real estate clause.

As the government has promised continuous reviews, we can expect more iterative fine-tuning, especially as the city jostles for position against competing residency-by-investment programs globally.

The CIES: From Media Buzz to Backbone

Six months ago, the new CIES was a buzzworthy experiment. Today, it’s a key pillar in Hong Kong’s effort to reclaim its economic dynamism. As billions are already flowing in and a responsive policy environment is in place, the CIES isn’t just happening—it’s working.

By streamlining entry requirements, embracing family office structures, and balancing investment options, the SAR Government has made it clear: Hong Kong is open for business—at scale, with flexibility, and for the long haul.

The slumber is over. Hong Kong is stirring—with purpose, policy, and promise.


IMI Pro


For committed professionals

Monthly
€99

or €840 per year (30% discount)


  • Your own dedicated IMI Pro profile page in IMI

  • Access IMI Rolodex

  • Access to IMI Data Center

  • Access to IMI Private Briefings

  • IMI Citizenship Catalog

  • Unlimited articles

  • Quarterly Processing Time Data

  • IMI Reports included

  • Access IMI Inner Circle Telegram Group

  • Watch members-only interviews

  • Advance invitation to IMI Events

Sign up now

Cancel any time, no questions asked.

Explore IMI’s Tools and Resources

Browse the world’s biggest collection of investment migration statistics in the

IMI DATA CENTER

Find a specialist for any IM program with

IMI PROFESSIONALS

Not sure which program is right for you? Narrow down the search with our​

IMI PROGRAM FINDER

>> See all IMI tools and resources

Subscribe to the IMI Newsletter

Get investment opportunities, policy updates, and high-signal news from directly in your inbox each week.

As a special gift, we’ll even send you a free copy of 13 Special Regimes for Low-Tax Living in High-Tax Europe.

13 Special Regimes for Low-Tax Living in High-Tax Europe
Subscribe and Get Access

Trusted by 300,000+ investors, professionals, and global citizens