The rules are also changing. In February 2026, the UAE began accepting mortgaged and partially paid property for its 10-year Golden Visa. By contrast, Caribbean citizenship-by-investment programs tightened escrow and payment requirements in 2024 and 2025, making financed transactions increasingly difficult to use.
The distinction matters because a financing structure that works in one jurisdiction may make an applicant ineligible elsewhere. The key question is not simply whether an investment is financed, but how the borrowed money enters the transaction.
Four Ways an Investment Can Be Financed
Borrowed funds can reach a qualifying investment through several different structures, and immigration rules do not necessarily treat them in the same way.
The most familiar arrangement is a mortgage secured against the qualifying property or investment itself. Another is a loan from a bank located in the destination country.
A third option involves borrowing abroad against an existing property or investment portfolio and transferring the proceeds into the applicant's own account. The fourth is seller or developer financing, where payment for an off-plan property is spread over time.
Many programs regulate only one or two of these arrangements. That can create an important distinction between a mortgage directly attached to the qualifying asset and borrowed money that reaches the investment only after passing through the applicant's foreign bank account.
Programs That Explicitly Allow Financing
UAE
The UAE Golden Visa is among the most permissive major programs when it comes to financed investment.
A policy circular dated February 20, 2026 removed the requirement for property investors to pay at least 50% of the property's value, or AED 1 million, upfront. The current test focuses on the total Dubai Land Department-certified value reaching AED 2 million, approximately $545,000, regardless of the outstanding mortgage or the stage of payment.
As a result, an investor with an 80% mortgage can qualify based on the property's full purchase price. The same applies to an off-plan purchaser who has paid only 10% of the contract once the pre-registration certificate, or Oqood, has been recorded.
There are still safeguards. Financed purchases require a no-objection certificate from the lender, and the investor is expected to contribute some equity. A transaction financed entirely with debt will not qualify. The shorter two-year Taskeen investor visa remains more restrictive and requires a completed title deed.
United States
The US EB-5 program permits borrowed funds to be used as investment capital, following litigation that ultimately led to a policy change.
In Zhang v. USCIS, a 2020 class action involving investors whose petitions had been rejected because they used unsecured loans, the court found that loan proceeds could qualify as cash capital. USCIS incorporated that ruling into its policy on July 22, 2021.
The investor must remain personally liable for the debt and must document the loan on commercially reasonable terms. The principal structure that remains prohibited is using the EB-5 investment itself as collateral.
Borrowing has consequently become a more established feature of EB-5 transactions. Common structures include home-equity lines, securities-backed credit facilities, loans secured against family property abroad, family loans and third-party financing used to cover the difference between an investor's liquid assets and the $800,000 minimum.
From an immigration-compliance perspective, the distinction between a bank and a non-bank lender can be more important than whether the loan is secured. Bank financing is generally easier to document because the investor does not need to establish the ultimate source of the bank's funds. A non-bank loan requires a much more extensive paper trail, potentially turning one source-of-funds exercise into two: the investor's own funds and the lender's source of the money provided.
Documentation gaps can be particularly problematic. USCIS has increasingly denied deficient applications outright rather than first requesting additional evidence. If the lender's records are incomplete when the application is filed, the deficiency may therefore be impossible to remedy later.
Malaysia
Malaysia's My Second Home (MM2H) program takes an unusually accommodating approach to property financing.
Local banks offer mortgages for the mandatory property purchase, with loan-to-value ratios reaching as high as 85% for eligible MM2H holders. Loan terms can also extend over several decades.
Japan
Japan's Business Manager Visa permits borrowed capital to be used for the qualifying business, provided the loan is genuine and the origin of the lender's funds can be established.
The financial threshold became substantially higher in October 2025, when the minimum capital requirement increased from ¥5 million to ¥30 million.
Panama
Panama's Qualified Investor visa takes a more limited approach.
The first $300,000 of qualifying real estate value must represent unencumbered equity, but financing can be used for the portion above that threshold. A $500,000 property carrying a $200,000 mortgage can therefore still meet the investment requirement.
New Zealand
New Zealand's Active Investor Plus category generally excludes borrowed funds, but there is an exception where the borrowing is secured against the applicant's own assets and selling those assets would be impractical.
The provision effectively allows an investor to borrow against an existing portfolio instead of liquidating it to fund the qualifying investment.
Where Financing Is Permitted With Conditions
Portugal
Portugal's rules focus on the source and location of the borrowing rather than on whether the capital was borrowed at all.
Borrowing the minimum investment amount from a Portuguese bank is prohibited. The restriction does not expressly extend to financing obtained abroad. Since the program moved to its €500,000 fund-investment route, financed subscription structures involving non-Portuguese lenders have therefore remained possible.
In practical terms, the rules examine where the money comes from rather than whether the investor ever borrowed it.
Greece
Greece follows a similar principle, although with tighter restrictions around the qualifying asset.
Depending on the investment category, the required amount may be €250,000, €400,000 or €800,000. The qualifying property itself cannot be mortgaged, and the investment funds must move from the applicant's own account into the seller's Greek account.
Foreign borrowing can nevertheless remain compatible with those requirements. Loans obtained from banks outside Greece have traditionally been treated as acceptable because the investment reaches Greece as funds held in the applicant's own account at a regulated institution.
The practical distinction is important. Once the money leaves the applicant's foreign account and reaches the seller's Greek account, the transaction may satisfy the program's requirements. The lawyer handling the transaction, however, is required to establish whether the funds represent the applicant's own savings or borrowed money.
Applicants also increasingly transfer funds directly from their foreign accounts to the seller rather than opening a Greek bank account. Domestic accounts were previously more relevant in transactions involving distressed properties, where funds had to be held in Greece to discharge an existing mortgage. That type of transaction has largely disappeared as developers have moved away from bank-financed construction.
Cyprus
Cyprus applies a comparable approach under Regulation 6(2) for permanent residency.
The qualifying investment of €300,000 plus VAT must be made using funds sourced from abroad, while borrowing from a Cypriot bank cannot be used to satisfy the threshold.
There is less consistency among advisers over how much must actually have been paid when the application is submitted, with figures of €200,000 and the full investment amount both being cited. The financing issue itself, however, is determined before the funds are transferred.
Turkey
Turkey falls into this category largely because of the distinction between the qualifying asset and the source of the money.
The $400,000 property investment must be free from mortgages and other liens. Installment payments are not accepted, while off-plan purchases require the entire amount to be paid upfront under a notarized contract.
The Turkish authorities may not see how the applicant originally obtained the funds held in the foreign account. As a result, borrowing secured against assets outside Turkey can remain the principal financing route.
Egypt
Egypt takes a different approach by allowing the qualifying contribution to be paid over time.
Under its citizenship program, the required contribution can be made in installments within one year of approval. Citizenship is finalized only after the entire amount has been paid, while property under construction can qualify under the real estate route.
Following preliminary approval, applicants receive a six-month temporary residence permit to complete the investment requirements. The $300,000 real estate investment can be paid in installments over a period of up to one year.
The government therefore extends the payment period rather than prohibiting staged funding. The final citizenship decision is simply withheld until the full investment has been completed.
Mauritius
Mauritius takes a middle-ground position for higher-value property purchases.
For properties costing more than US$750,000, the first US$750,000 must come from the buyer's own funds transferred from abroad. Local bank financing can then be used for the amount above that threshold.
A further consideration is the increase in registration duty for non-citizens, which doubled to 10% in July 2026 and affects the economics of financed purchases.
Programs With Hard Financing Restrictions
Caribbean citizenship-by-investment programs have taken the clearest position against financed transactions.
Under the 2024 Memorandum of Agreement among St. Kitts and Nevis, Dominica, Grenada and Antigua and Barbuda, the $200,000 minimum must represent funds actually received. The required escrow arrangements must be established in the relevant jurisdiction and cleared before an application is submitted.
St. Kitts and Nevis has also criminalized the practice of underselling qualifying property.
Developer financing, which was previously used in some real estate transactions, can now lead to revocation rather than providing a legitimate route around the investment requirement.
Several residence programs impose similarly strict restrictions.
Saudi Arabia's Premium Residency real estate route requires the SAR 4 million property, approximately $1.1 million, to be free of mortgages and financing.
Malta's permanent residence program requires personal funds. Italy's investor visa expressly excludes loans and mortgages, while Hong Kong's Capital Investment Entrant Scheme does not allow borrowed or leveraged assets to count toward its HK$30 million investment requirement.
What Financing Rules Mean for Applicants
For applicants with substantial wealth but limited liquidity, the choice of jurisdiction can determine whether borrowing is even possible.
Where financing flexibility is the priority, the UAE currently stands out because the qualifying property itself can remain mortgaged from the outset. EB-5 and Malaysia provide other examples in which borrowing is expressly accommodated rather than merely left unaddressed by the rules.
For applicants focused on Europe, the qualifying investment generally needs to arrive as the applicant's own funds. The origin of that cash can be a separate question. A properly documented loan secured against a home or investment portfolio abroad can, under the rules currently in place, provide funds that ultimately satisfy the requirements in Greece, Cyprus and Portugal.
The decisive issue is the documentation. The financing structure must leave a clear and defensible source-of-funds trail from the lender to the applicant and ultimately to the qualifying investment.
The position is fundamentally different in the Caribbean. Where a program has specifically tightened its rules to prevent financed transactions, accepting a developer-financing arrangement can expose the applicant to much more than a rejected application, including the possibility of losing citizenship already granted.
If you're planning to obtain a residence permit, invest in a foreign country, or purchase real estate abroad, I invite you to book an individual consultation with me.
During a personal online meeting, we'll discuss your situation in detail, answer your questions, and develop a clear, step-by-step action plan tailored to your goals.
The distinction matters because a financing structure that works in one jurisdiction may make an applicant ineligible elsewhere. The key question is not simply whether an investment is financed, but how the borrowed money enters the transaction.
Four Ways an Investment Can Be Financed
Borrowed funds can reach a qualifying investment through several different structures, and immigration rules do not necessarily treat them in the same way.
The most familiar arrangement is a mortgage secured against the qualifying property or investment itself. Another is a loan from a bank located in the destination country.
A third option involves borrowing abroad against an existing property or investment portfolio and transferring the proceeds into the applicant's own account. The fourth is seller or developer financing, where payment for an off-plan property is spread over time.
Many programs regulate only one or two of these arrangements. That can create an important distinction between a mortgage directly attached to the qualifying asset and borrowed money that reaches the investment only after passing through the applicant's foreign bank account.
Programs That Explicitly Allow Financing
UAE
The UAE Golden Visa is among the most permissive major programs when it comes to financed investment.
A policy circular dated February 20, 2026 removed the requirement for property investors to pay at least 50% of the property's value, or AED 1 million, upfront. The current test focuses on the total Dubai Land Department-certified value reaching AED 2 million, approximately $545,000, regardless of the outstanding mortgage or the stage of payment.
As a result, an investor with an 80% mortgage can qualify based on the property's full purchase price. The same applies to an off-plan purchaser who has paid only 10% of the contract once the pre-registration certificate, or Oqood, has been recorded.
There are still safeguards. Financed purchases require a no-objection certificate from the lender, and the investor is expected to contribute some equity. A transaction financed entirely with debt will not qualify. The shorter two-year Taskeen investor visa remains more restrictive and requires a completed title deed.
United States
The US EB-5 program permits borrowed funds to be used as investment capital, following litigation that ultimately led to a policy change.
In Zhang v. USCIS, a 2020 class action involving investors whose petitions had been rejected because they used unsecured loans, the court found that loan proceeds could qualify as cash capital. USCIS incorporated that ruling into its policy on July 22, 2021.
The investor must remain personally liable for the debt and must document the loan on commercially reasonable terms. The principal structure that remains prohibited is using the EB-5 investment itself as collateral.
Borrowing has consequently become a more established feature of EB-5 transactions. Common structures include home-equity lines, securities-backed credit facilities, loans secured against family property abroad, family loans and third-party financing used to cover the difference between an investor's liquid assets and the $800,000 minimum.
From an immigration-compliance perspective, the distinction between a bank and a non-bank lender can be more important than whether the loan is secured. Bank financing is generally easier to document because the investor does not need to establish the ultimate source of the bank's funds. A non-bank loan requires a much more extensive paper trail, potentially turning one source-of-funds exercise into two: the investor's own funds and the lender's source of the money provided.
Documentation gaps can be particularly problematic. USCIS has increasingly denied deficient applications outright rather than first requesting additional evidence. If the lender's records are incomplete when the application is filed, the deficiency may therefore be impossible to remedy later.
Malaysia
Malaysia's My Second Home (MM2H) program takes an unusually accommodating approach to property financing.
Local banks offer mortgages for the mandatory property purchase, with loan-to-value ratios reaching as high as 85% for eligible MM2H holders. Loan terms can also extend over several decades.
Japan
Japan's Business Manager Visa permits borrowed capital to be used for the qualifying business, provided the loan is genuine and the origin of the lender's funds can be established.
The financial threshold became substantially higher in October 2025, when the minimum capital requirement increased from ¥5 million to ¥30 million.
Panama
Panama's Qualified Investor visa takes a more limited approach.
The first $300,000 of qualifying real estate value must represent unencumbered equity, but financing can be used for the portion above that threshold. A $500,000 property carrying a $200,000 mortgage can therefore still meet the investment requirement.
New Zealand
New Zealand's Active Investor Plus category generally excludes borrowed funds, but there is an exception where the borrowing is secured against the applicant's own assets and selling those assets would be impractical.
The provision effectively allows an investor to borrow against an existing portfolio instead of liquidating it to fund the qualifying investment.
Where Financing Is Permitted With Conditions
Portugal
Portugal's rules focus on the source and location of the borrowing rather than on whether the capital was borrowed at all.
Borrowing the minimum investment amount from a Portuguese bank is prohibited. The restriction does not expressly extend to financing obtained abroad. Since the program moved to its €500,000 fund-investment route, financed subscription structures involving non-Portuguese lenders have therefore remained possible.
In practical terms, the rules examine where the money comes from rather than whether the investor ever borrowed it.
Greece
Greece follows a similar principle, although with tighter restrictions around the qualifying asset.
Depending on the investment category, the required amount may be €250,000, €400,000 or €800,000. The qualifying property itself cannot be mortgaged, and the investment funds must move from the applicant's own account into the seller's Greek account.
Foreign borrowing can nevertheless remain compatible with those requirements. Loans obtained from banks outside Greece have traditionally been treated as acceptable because the investment reaches Greece as funds held in the applicant's own account at a regulated institution.
The practical distinction is important. Once the money leaves the applicant's foreign account and reaches the seller's Greek account, the transaction may satisfy the program's requirements. The lawyer handling the transaction, however, is required to establish whether the funds represent the applicant's own savings or borrowed money.
Applicants also increasingly transfer funds directly from their foreign accounts to the seller rather than opening a Greek bank account. Domestic accounts were previously more relevant in transactions involving distressed properties, where funds had to be held in Greece to discharge an existing mortgage. That type of transaction has largely disappeared as developers have moved away from bank-financed construction.
Cyprus
Cyprus applies a comparable approach under Regulation 6(2) for permanent residency.
The qualifying investment of €300,000 plus VAT must be made using funds sourced from abroad, while borrowing from a Cypriot bank cannot be used to satisfy the threshold.
There is less consistency among advisers over how much must actually have been paid when the application is submitted, with figures of €200,000 and the full investment amount both being cited. The financing issue itself, however, is determined before the funds are transferred.
Turkey
Turkey falls into this category largely because of the distinction between the qualifying asset and the source of the money.
The $400,000 property investment must be free from mortgages and other liens. Installment payments are not accepted, while off-plan purchases require the entire amount to be paid upfront under a notarized contract.
The Turkish authorities may not see how the applicant originally obtained the funds held in the foreign account. As a result, borrowing secured against assets outside Turkey can remain the principal financing route.
Egypt
Egypt takes a different approach by allowing the qualifying contribution to be paid over time.
Under its citizenship program, the required contribution can be made in installments within one year of approval. Citizenship is finalized only after the entire amount has been paid, while property under construction can qualify under the real estate route.
Following preliminary approval, applicants receive a six-month temporary residence permit to complete the investment requirements. The $300,000 real estate investment can be paid in installments over a period of up to one year.
The government therefore extends the payment period rather than prohibiting staged funding. The final citizenship decision is simply withheld until the full investment has been completed.
Mauritius
Mauritius takes a middle-ground position for higher-value property purchases.
For properties costing more than US$750,000, the first US$750,000 must come from the buyer's own funds transferred from abroad. Local bank financing can then be used for the amount above that threshold.
A further consideration is the increase in registration duty for non-citizens, which doubled to 10% in July 2026 and affects the economics of financed purchases.
Programs With Hard Financing Restrictions
Caribbean citizenship-by-investment programs have taken the clearest position against financed transactions.
Under the 2024 Memorandum of Agreement among St. Kitts and Nevis, Dominica, Grenada and Antigua and Barbuda, the $200,000 minimum must represent funds actually received. The required escrow arrangements must be established in the relevant jurisdiction and cleared before an application is submitted.
St. Kitts and Nevis has also criminalized the practice of underselling qualifying property.
Developer financing, which was previously used in some real estate transactions, can now lead to revocation rather than providing a legitimate route around the investment requirement.
Several residence programs impose similarly strict restrictions.
Saudi Arabia's Premium Residency real estate route requires the SAR 4 million property, approximately $1.1 million, to be free of mortgages and financing.
Malta's permanent residence program requires personal funds. Italy's investor visa expressly excludes loans and mortgages, while Hong Kong's Capital Investment Entrant Scheme does not allow borrowed or leveraged assets to count toward its HK$30 million investment requirement.
What Financing Rules Mean for Applicants
For applicants with substantial wealth but limited liquidity, the choice of jurisdiction can determine whether borrowing is even possible.
Where financing flexibility is the priority, the UAE currently stands out because the qualifying property itself can remain mortgaged from the outset. EB-5 and Malaysia provide other examples in which borrowing is expressly accommodated rather than merely left unaddressed by the rules.
For applicants focused on Europe, the qualifying investment generally needs to arrive as the applicant's own funds. The origin of that cash can be a separate question. A properly documented loan secured against a home or investment portfolio abroad can, under the rules currently in place, provide funds that ultimately satisfy the requirements in Greece, Cyprus and Portugal.
The decisive issue is the documentation. The financing structure must leave a clear and defensible source-of-funds trail from the lender to the applicant and ultimately to the qualifying investment.
The position is fundamentally different in the Caribbean. Where a program has specifically tightened its rules to prevent financed transactions, accepting a developer-financing arrangement can expose the applicant to much more than a rejected application, including the possibility of losing citizenship already granted.
If you're planning to obtain a residence permit, invest in a foreign country, or purchase real estate abroad, I invite you to book an individual consultation with me.
During a personal online meeting, we'll discuss your situation in detail, answer your questions, and develop a clear, step-by-step action plan tailored to your goals.