Panama has split the real estate route of its investor residency program in two. Buyers of resale property must now invest at least US$500,000, but a first purchase of a new property from its developer still qualifies at US$300,000.
President José Raúl Mulino and Minister of Public Security Frank Alexis Ábrego signed Executive Decree No. 17 on September 8. It appeared in the Official Gazette on September 16. The decree replaces “in all its parts” Decree No. 722 of 2020, which created the Qualified Investor Permanent Residency program, and its 2022 and 2024 amendments.
Article 21 provides that the decree “shall take effect from its promulgation.” Amounts in the decree appear in balboas, Panama’s own currency, which the country pegs at par to the US dollar.
Its preamble presents the property split as construction policy. New-build purchases, according to the text, serve “to promote the immediate reactivation of the construction industry, energize the local supply chain, and reduce the existing primary inventory.” Resale transactions carry a “multiplier impact on the creation of new jobs” that the decree calls “substantially lower.”
Horacio Mendoza, Director of Business Development at Panamanian developer Grupo Los Pueblos, calls the decree “a deliberate shift in Panama’s investor residency policy.” The split is “not a technical tweak,” he argues, because “the government states outright that new construction drives more employment and economic multiplier effect than resale transactions.” In his reading, Panama is “using the residency program to steer capital toward primary development.”
Immigration status, the preamble adds, is “a sovereign attribution of the Panamanian State and not an acquired right.” On that basis, the state keeps the power to set conditions, “directing migratory incentives toward the sectors of the economy that generate greater public utility and social interest.”
Jordi Vilanova, President of Mercan Group, sees “an important milestone in the evolution of the program.” The changes, in his assessment, “provide greater clarity around qualifying real estate investments, introduce a more structured administrative pathway for naturalization applications” and “expand flexibility for investor families.” His firm announced a partnership with the Panamanian government to promote the program in October 2025.
Ladislas Maurice of The Wandering Investor belives that “developers lobbied the government for this distinction between new buildings and resales as developers understand their product offerings are not as competitive as the resale market in Panama City in the current market environment”
Two property tiers
Article 4 defines a first-sale property as “the initial acquisition of a new and unoccupied property that the promoter, developer, or its successor transfers.” Applicants prove that status with a Public Registry certification and, where applicable, construction or occupancy permits and tax records.
A resale property is one that an owner has previously sold, leased, or transferred to “an unrelated third party,” or one that someone has already occupied. Any such purchase now requires US$500,000.
Segregation, a declaration of improvements, a trust contribution, a merger, or a corporate reorganization keeps first-sale status, unless it involves “the sale of the property to an unrelated third party.” Inheritance does not count as a prior sale either. Authorities may still “disregard simulated acts or acts that seek to evade the applicable minimum amount.”
Under the previous framework, a single US$300,000 minimum applied to “the purchase of a real property” free of liens. That figure began in 2020 as a temporary discount on a US$500,000 floor. Panama extended the discount in 2022 and made it permanent in October 2024 by scrapping a planned increase.
The commerce ministry was already steering investment toward new construction rather than resale before the decree, according to Eduardo Arango, then Vice Minister of Internal Commerce. In an interview published in December 2025, he argued that “to create jobs, we need to build stuff, we need to build apartments.”
Mendoza counts “a structural US$200,000 incentive favoring new-build projects,” one he expects will “meaningfully shift buyer behavior toward developer inventory.” From a developer’s standpoint, the decree “effectively formalizes what the market has long understood informally.”
New construction, in his words, “carries more weight for Panama’s economy than resale transactions.” As he sees it, the lower tier sends “foreign capital toward developers who are actively building,” a flow that generates “construction jobs, local supply-chain activity, and new housing stock.”
Established developers with active pipelines get “a meaningful tailwind,” in Mendoza’s view, one that “sharpens the value proposition for buyers weighing new development against resale.” It also “rewards the kind of long-term, ground-up investment that shapes a city’s skyline rather than just its property registry.”
For Vilanova, the split follows “Panama’s objective of directing foreign investment toward new developments.” He also attests that the higher resale threshold aims “to reduce pressure on the domestic housing market and help preserve access to housing for Panamanian residents.”
Valuation checks
Article 5 counts “the lesser of the price actually paid and the reasonably substantiated commercial value, minus the balance of any real lien affecting the property.” That figure must meet the minimum.
Buyers may still finance the portion above the threshold. The old decree specified “a mortgage loan with a local bank” for that balance. Any financing now qualifies if buyers can document and trace it, as long as no lien pulls the net value below the floor.
Article 6 keeps the certification from the National Land Administration Authority for cadastral data. It also lets the Ministry of Commerce and Industries (MICI) demand “an independent private or commercial appraisal.” MICI can do so when the cadastral value “does not reflect the current conditions of the property,” or when objective elements create “a reasonable doubt” about market value.
Appraisals must date from the previous six months and come from a professional that Banco Nacional de Panamá and Caja de Ahorros recognize. Each appraiser must be “independent of the applicant, seller, promoter, intermediary, and financier,” and “the applicant shall bear the cost.”
The preamble frames these powers as “a risk-based control model” to prevent “possible overvaluations.” Money the applicant has not “actually paid” to the seller, promoter, or trustee cannot count.
Vilanova describes provisions that “strengthen safeguards surrounding property valuations.” Their purpose, in his view, is to “reinforce the integrity of the program” so that “qualifying investments reflect genuine market values.”
Off-plan contracts
Off-plan purchases keep a US$300,000 minimum under Article 7. Investors sign a promise of sale and fund it through a trust at a Panama-licensed bank or trust company, or by paying the developer 100% upfront.
Paying the developer in full now requires a bank instrument that is “irrevocable, unconditional, and payable on first demand,” which a Panama-licensed entity issues in the investor’s favor. It must remain in force until the Public Registry records the finished property in the applicant’s name. Should the developer miss “the deadlines for construction, segregation, and registration of the property,” the investor can execute it.
The instrument can be a standby letter of credit, an irrevocable bank guarantee, or a performance guarantee, with an updated copy due at MICI each year. Panama’s 2024 rules already required a performance guarantee from the developer.
Mendoza sees the decree tightening “investor protection on pre-construction purchases,” with bank backing “covering 100% of the investment” until the buyer holds title. He calls it “a policy that rewards developers building new inventory while adding real cost and compliance weight to preconstruction sales.”
Guarantee rules also “raise the bar for developer credibility,” by his account. Buyers relying on promise-of-sale contracts, he predicts, “will increasingly favor developers with a proven track record of delivering on schedule, since that guarantee has real teeth if construction timelines slip.”
Failed projects now run on a clock. Under the old framework, an investor whose contract fell through could substitute “another promise of sale or any of the other forms of investment,” with no deadline in the text.
Article 7 now gives investors 180 business days to switch, starting the day after the contractual deadline, when the default is “attributable to the developer or promising seller.” Investors can use a new off-plan contract as the replacement only once.
If the replacement contract also fails, the investor must move “exclusively” into a direct investment, meaning a finished property, securities, or a fixed-term deposit. Residency resting “solely on promise of sale contracts” cannot exceed “three (3) continuous or discontinuous years” in total. Past that limit, the decree provides for “the cancellation of the permit.”
Source of funds
Article 2 requires that applicants make the investment with their “own funds” and prove its “ownership and traceability.” Money that applicants receive “by way of donation, gift, liberality, or any other gratuitous transfer from third parties” does not count toward the minimum.
The decree also defines foreign-source funds for the first time. They include money that “entered the Panamanian financial system through international transfer,” along with deposits already in Panama that documents show “originated in a prior international transfer.”
Where several people hold an investment, “each principal applicant must individually prove the required minimum amount.” A principal applicant, spouse, and dependents in one application can still count a joint holding once, if its net value reaches the minimum.
Processing deadlines
Under Article 3, MICI’s Investment Certification, which the ministry sends to the National Migration Service (SNM), now carries “a validity of three (3) months” from issuance. It must remain valid when the complete application reaches SNM. Once SNM holds a complete file, the migration service keeps the 30-business-day limit that the old decree also set for its decision.
MICI now has 15 business days from admission to issue the certification. Applicants get 15 business days to fix incomplete files. Otherwise, MICI archives the application, and the applicant must begin “a new procedure from the beginning.”
Securities and deposits
Securities investors still need US$500,000, which they must hold through a licensed brokerage for at least five years. The old decree required securities of issuers “whose business has an impact on the national territory, through the Panama Stock Exchange.”
Article 8 drops that stock exchange reference and names three eligible classes. Private equity and venture capital funds, along with other registered investment funds, qualify explicitly. Their primary purpose must be “the injection of productive investment into operating companies, strategic infrastructure projects, or commercial ventures within the Republic of Panama.”
Debt that Panama issues or guarantees also counts, from sovereign bonds to treasury bills, whether investors buy it at primary auction or on the secondary market. A catch-all class covers other registered securities, such as shares, corporate debt, and real estate investment trusts.
Under Article 8, “market fluctuations not attributable to the investor shall not by themselves produce noncompliance with the minimum amount.” That protection holds as long as the investor avoids voluntary withdrawals, sales, or liens and restores the amount within 90 calendar days of MICI’s notice.
Fixed-term deposits now come at two prices. Investors need US$750,000 at “any private capital banking entity” with a general license. At Banco Nacional de Panamá or Caja de Ahorros de Panamá, the minimum drops to US$500,000, provided the deposit sits there “directly and solely.”
Article 9 calls this tier “a material incentive of state promotion.” Its goal is “to strengthen the Nation’s public and social financing capacity.” The decree’s preamble argues that the state-bank threshold “does not undermine the principles of free competition or free choice of the investor with respect to private banking.”
Deposits must run at least five years, free of any lien or pledge. Funds must arrive through “international SWIFT transfers from accounts in the name of the applicant” or through an entity he beneficially owns.
Annual verification
Investors must still hold the qualifying asset for five years. Under the old decree, MICI itself had to send SNM annual proof of the investment and could ask the investor for information.
Article 12 now adds an annual filing duty for the resident, “acting through his legal representative.” Filings go to MICI within the 30 calendar days before each anniversary of the immigration resolution. MICI still confirms the investment to SNM.
A resident who sells or substitutes the investment before the five-year mark, or whose investment ceases, must notify MICI within 30 calendar days. The ministry then grants “a peremptory term of up to ninety (90) calendar days” to reinvest, and any cancellation action pauses in the meantime.
Missing that window leads to “ex officio cancellation” of the residence permit. Panama’s 2020 text had ordered cancellation where an investment lapsed without reinvestment, with no deadline to reinvest.
Family and citizenship
Article 17 lets residents in good standing add a spouse they marry in a civil ceremony after approval, along with “new children (by birth or subsequent adoption),” as dependents. Each addition costs US$1,000 to the National Treasury and US$1,000 to SNM.
Dependency changes, such as divorce or a child reaching adulthood, require notice to SNM, and each dependent’s status then receives an individual, reasoned decision. Under the decree, “no automatic cancellation shall operate without a hearing of the affected party.”
The new framework, as Vilanova puts it, “recognizes that family circumstances can change after an investor has obtained residence.” He sees “additional flexibility for investors considering Panama as a long-term residence solution.”
Naturalization enters the program’s decree for the first time through Article 14. Qualified investors and their dependents may seek citizenship “once they have completed five (5) consecutive years of residence in the Republic of Panama.”
That provision routes applications through MICI’s investment window, where the file must include a certification that the investment “met the parameters that the Qualified Investor category requires.” The provision does not define how much physical presence “residence” demands. Arango had promoted a route requiring one visit every two years, and Expat Money CEO Mikkel Thorup warned that applicants following that advice would likely face rejection.
For Vilanova, routing these files through MICI’s window, “which already supports the Qualified Investor Program,” provides “greater institutional continuity between the residence-by-investment process and a subsequent naturalization application.” A more structured process, he adds, “responds to an important consideration for international investors seeking greater clarity regarding their long-term options in Panama.”
Vilanova points to a separate government initiative: Panama “is also implementing a specialized digital platform for naturalization procedures, extending beyond the Qualified Investor category.” That initiative, in his account, aims to “improve standardization, traceability, and administrative efficiency.” Naturalization, he stresses, “remains subject to Panama’s applicable constitutional and legal requirements” and is no “automatic consequence of investment or residence.”
Transition rules
Article 19 shields files already in motion. Applications that reached MICI or SNM before the decree took effect stay under “the requirements, conditions, and amounts in force at the time of their filing.” More favorable procedural rules apply to them immediately.
Investors whose investments or binding contracts predate the decree may also use the old regime, including its single US$300,000 property minimum. They must file “within a period of six (6) months from the entry into force of this Executive Decree.” Resale buyers with signed contracts have the most at stake.
Investment Certifications that MICI issued before the change “shall retain their effects until their term expires.” New appraisal rules will not apply retroactively “to disregard investments with prior certification, unless there are objective indications of falsity, simulation, fraud, or illicit origin of funds.” The grandfathering echoes Arango’s December 2025 assurance that rules would hold “no matter which government is in power.”
Applicants and permit holders under Panama’s Own Economic Solvency residence category get 12 months to switch into the Qualified Investor category if they meet the minimums. Investments that predate October 15, 2020, do not qualify.
