Hong Kong's New Capital Investment Entrant Scheme (CIES) has garnered significant attention from global high-net-worth individuals due to its flexible investment arrangements and relatively lenient residency requirements. Since its launch, the CIES program has continuously optimized its application conditions, fully unleashing policy benefits. The latest adjusted rules, known as the "2025 Optimization Measures," came into effect on March 1, 2025.
During the application process, which requires proof of assets worth "HKD 30 million," the approval of cases using cryptocurrency as asset proof has drawn considerable attention. In October 2024, Invest Hong Kong approved an applicant's use of Bitcoin (BTC) as asset proof. In February 2025, another applicant was approved using Ethereum (ETH) as asset proof. This article will analyze the key points and considerations for applying for Hong Kong investment immigration using cryptocurrency as asset proof, in light of the recent CIES optimization measures.
2025 Optimization Measures Bring Institutional Benefits and Potential Opportunities
The core application conditions of the CIES program include net asset requirements and investment requirements. The former mandates that the applicant must have absolutely and beneficially owned net assets or net capital with a market value of not less than HKD 30 million (or the equivalent in foreign currency) throughout a specific period before the date of the net asset review application under CIES. The latter requires the applicant to invest this amount in investment products specified by the Hong Kong government within a specific period. Based on this, the 2025 Optimization Measures shorten the net asset review period and relax holding structure restrictions, providing a favorable policy window for applicants considering using cryptocurrency assets to apply for the CIES program.
Significant Reduction in Asset Proof Duration
The 2025 Optimization Measures shorten the validity period of the HKD 30 million asset proof from two years to six months. This means applicants only need to provide stable net asset proof for over six months to meet the relevant application conditions. For holders of highly volatile cryptocurrencies, this reduces capital occupancy costs and balances asset liquidity requirements with identity planning arrangements.
Family Member Joint Assets Can Be Calculated by Share
Previously, CIES required that the "HKD 30 million net assets" be 100% held by the individual, meaning jointly owned assets, such as those held by spouses, could not be counted. The 2025 Optimization Measures explicitly state that the share absolutely and beneficially owned by the applicant in assets jointly owned by family members will also be considered. This allows applicants to include their beneficially owned share of family joint assets in the net asset review scope. Family members include spouses, parents, children, and other relatives, making net asset recognition more flexible.
Lenient Renewal Requirements (No Need to Reside or Work in Hong Kong)
After applicants receive formal approval from the Immigration Department through the CIES program, their stay in Hong Kong generally does not exceed two years. During this period, the CIES program imposes no mandatory requirements for residence or employment in Hong Kong. However, applicants must ensure that their investment arrangements continue to comply with CIES regulations, including investment amount and investment management requirements. Within three months before the expiration of the stay period, applicants must obtain a review certificate from Invest Hong Kong (the "Review Department") confirming that the relevant investments still comply with the investment provisions under CIES. They can then apply to the Hong Kong Immigration Department for an extension of their stay, generally for three years, resulting in a renewal pattern of 2+3+3. Currently, other talent import schemes in Hong Kong, such as the Top Talent Pass Scheme and Quality Migrant Admission Scheme, have varying degrees of requirements for working and residing in Hong Kong for renewal. In contrast, CIES offers significant advantages with its lenient renewal policies.
Unconditional Stay Visa as a Safety Net
If an applicant fails to meet the "continuous ordinary residence in Hong Kong for seven years" requirement for converting to Hong Kong permanent residency after holding a Hong Kong ID card for seven years under CIES, they can still apply for an "unconditional stay visa." This allows the applicant to enter and stay in Hong Kong without any conditions or restrictions, providing flexibility for identity planning—an advantage not available in other talent import schemes.
Exit Channels for Investments in Hong Kong
After the applicant's investment in Hong Kong has complied with CIES regulations for seven years, regardless of whether the applicant successfully converts to Hong Kong permanent residency or obtains an unconditional stay visa, the HKD 30 million investment required under the CIES program can theoretically be released, provided it does not conflict with relevant investment conditions. However, the specified HKD 3 million investment in government-approved areas (such as innovation and technology funds or startups) must comply with the exit mechanisms of the relevant projects (such as equity transfer or fund redemption) upon exit. The fund release arrangement also provides security for the exit of investments in Hong Kong.
Core Points and Challenges of Applying for CIES with Cryptocurrency Assets
The "net assets" requirement of HKD 30 million under CIES refers to the remaining amount after deducting any and all charges, liens, or encumbrances used as collateral or attached to any assets, properties, or capital. The broad expression of "any assets, properties, or capital" in this definition leaves institutional space for cryptocurrency as net asset proof. The two previously approved cases of using cryptocurrency assets to apply for CIES demonstrate the feasibility of this path.
However, in practice, the unique asset attributes of cryptocurrency, such as anonymity, decentralization, and high volatility, may lead to certain issues and difficulties during the CIES application stage. The review department pays particular attention to core issues such as the authenticity of ownership and actual value of cryptocurrency assets. After approval, requirements for the transfer of cryptocurrency and investment into permitted investment assets also need attention.
Verification of Authenticity of Cryptocurrency Asset Ownership
The anonymity and decentralization of cryptocurrency make the identification and confirmation of transaction parties exceptionally difficult. The primary issue is that the authenticity of cryptocurrency asset ownership is challenging to verify. On-chain transaction records are often fragmented (e.g., forked coins may involve ownership determination of the original and new chains). Early mining profits lack credentials, making it difficult to provide complete transaction records (e.g., cold wallet private key control declarations, exchange custody agreements). These issues create obstacles in determining that the assets are absolutely and beneficially owned by the applicant.
Therefore, if applicants plan to apply for the CIES program using cryptocurrency assets, they must prioritize obtaining documents such as compliant operational qualifications of exchanges, proof of holdings, and private key control declarations as essential proof of cryptocurrency ownership. These should be accompanied by transaction records of the cryptocurrency to demonstrate the legality of the fund source. This comprehensively addresses the review department's concerns across multiple dimensions: authenticity of asset ownership, compliant storage of assets, and legality of fund sources. Given that the asset proof period has been significantly shortened to six months under the 2025 Optimization Measures, and the current focus of CIES review is the legal holding status of current assets without requiring追溯审查 of initial fund sources, interested applicants can consider gradually adopting a "progressive compliance" method for compliant disposal of assets and pay attention to the collection and provision of relevant proof documents.
A further issue is that if applicants need to include cryptocurrency assets under family members' names in their net asset scope, they must clarify the applicant's beneficially owned share therein. If there is no written agreement among family members (such as a joint ownership declaration or marital property agreement), the application may be rejected due to ambiguous ownership. In such cases, applicants should consider using effective agreements to clarify the asset division ratio among family members and supplement it with ownership proof (on-chain address control declarations) for explanation.
Judgment of Actual Value of Cryptocurrency Assets
The uncertainty of cryptocurrency asset value and the diversification of value judgment standards make it difficult to determine its actual value. Therefore, obtaining a valuation report issued by a qualified entity recognized by the review department is a crucial step in applying for CIES using cryptocurrency.
Additionally, the stability of the actual value of cryptocurrency is lower compared to traditional financial assets. The high volatility of value creates high uncertainty in continuously meeting the CIES application threshold over a period. Although the CIES program has shortened the net asset review holding period to six months during the approval process, applicants must still pay attention to the continuous management of the value of cryptocurrency assets during this period, ensuring that their total value continuously meets the HKD 30 million threshold requirement for the six months before submitting the CIES application.
Subsequent Arrangements for Converting Cryptocurrency into Permitted Investment Assets
After applicants successfully obtain in-principle approval from the Hong Kong Immigration Department using cryptocurrency assets, they must enter Hong Kong as visitors and complete the specified investment within 180 days to obtain formal approval and a two-year stay visa. Thereafter, they must annually submit proof documents demonstrating continuous compliance with investment management regulations. Therefore, to meet the Hong Kong identity planning requirements under CIES, cryptocurrency assets need to be converted into permitted investment assets and continuously satisfy the regulatory requirements of the review department.
Permitted investment assets include not less than HKD 27 million in permitted financial assets and real estate, and HKD 3 million in the Capital Investment Entrant Scheme Investment Portfolio (hereinafter referred to as the "Investment Portfolio"). According to the restrictions on the scope of permitted investment assets under the CIES program, applicants cannot directly invest in over-the-counter or virtual currencies from other countries or regions after obtaining in-principle approval for the CIES program. However, they can invest in virtual currency ETFs from licensed exchanges in Hong Kong recognized by the review department, as the aforementioned permitted financial assets also include specific open-ended fund company Bitcoin ETFs and Ethereum ETFs.
Benefits and Prospects of Hong Kong's Cryptocurrency Policy Certainty
Hong Kong has established a compliant trading ecosystem for cryptocurrency through policies such as the "Policy Declaration on the Development of Virtual Assets" and the list of qualified financial products, explicitly covering crypto asset spot/futures ETFs and supporting compliant custody and fiat currency exchange through licensed exchanges. CIES also accepts applicants using cryptocurrency to apply for investment immigration, which is recognition of crypto assets as a legal form of wealth in Hong Kong. This series of breakthrough policies demonstrates Hong Kong's leading position in global cryptocurrency regulation and application.
A compliant trading environment and friendly identity policies will help cryptocurrency investors simultaneously achieve identity planning and diversified asset allocation. Furthermore, investors can enjoy the advantages of Hong Kong's tax system and financial convenience based on their Hong Kong identity. Therefore, for cryptocurrency investors interested in Hong Kong, applying for Hong Kong identity through CIES is a viable path worth full attention.
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Frequently Asked Questions
What is the minimum net asset requirement for the CIES program?
The applicant must demonstrate absolute beneficial ownership of net assets or net capital with a market value of not less than HKD 30 million (or equivalent in foreign currency) throughout a specific period before the application date.
Can cryptocurrency be used as proof of assets for CIES?
Yes, Hong Kong has approved cases where Bitcoin and Ethereum were used as asset proof. However, applicants must provide sufficient documentation, such as exchange compliance proof, holding statements, and private key control declarations, to verify ownership and value.
How long must I hold the assets before applying?
After the 2025 optimization, the asset proof duration has been shortened to six months. Applicants need to show that their net assets have met the HKD 30 million threshold consistently for the six months preceding the application.
What are the investment options after receiving in-principle approval?
Applicants must invest HKD 30 million in permitted investment assets, which include at least HKD 27 million in financial assets and real estate and HKD 3 million in a government-approved investment portfolio. This can include certain cryptocurrency ETFs from licensed exchanges.
Are there residency requirements for renewing the stay visa under CIES?
No, one of the key advantages of CIES is that there are no mandatory residency or employment requirements in Hong Kong for renewing the stay visa. The focus is on maintaining the investment as per regulations.
What happens if I don't qualify for permanent residency after seven years?
If you do not meet the continuous ordinary residence requirement for permanent residency after seven years, you can still apply for an unconditional stay visa, allowing you to remain in Hong Kong without any restrictions.