Panama has taken an important step in the evolution of its Qualified Investor Program, reinforcing the country's framework for residence by investment while maintaining one of its most relevant real estate investment thresholds.
On September 16, 2026, Panama published Executive Decree No. 17 of September 8, 2026, replacing Executive Decree No. 722 of 2020 and its subsequent amendments. The new decree consolidates the rules governing permanent residence under the Qualified Investor category into an updated framework.
For international investors considering residency by investment in Panama, the decree brings greater clarity regarding qualifying investments, processing timelines, investment safeguards and family considerations.
For the real estate sector, one point is particularly significant: the minimum investment remains USD 300,000 for qualifying new, first-sale real estate.
USD 300,000 threshold maintained for qualifying new real estate
One of the most relevant aspects of Executive Decree No. 17 is the distinction it establishes between qualifying new, first-sale properties and properties acquired on the secondary market.
Under the new framework:
New, first-sale real estate: minimum qualifying investment of USD 300,000
Secondary-market real estate: minimum qualifying investment of USD 500,000
A qualifying first-sale property is generally a new, unoccupied property acquired from the developer, promoter or its successor that meets the conditions established in the decree.
The decree itself frames this differentiation as part of a policy intended to encourage investment in new inventory and stimulate Panama's construction sector, its local supply chain and related economic activity.
For international investors interested in combining a real estate investment with permanent residency in Panama, new real estate therefore remains the lowest-threshold real estate route under the Qualified Investor Program.
More defined processing timelines
Executive Decree No. 17 also introduces more clearly defined timelines for processing Qualified Investor applications. Once a complete investment certification file has been formally admitted, the Ministry of Commerce and Industries (MICI) has up to 15 business days to issue the investment certification.
Once the complete immigration file is formally received, the National Migration Service has up to 30 business days to resolve the permanent residence application, subject to legally applicable suspensions.
This provides investors and their advisers with a more structured administrative framework for navigating the process.
Greater flexibility for investor families
The updated framework also recognizes that an investor's family circumstances may change after obtaining permanent residence.
Under the new provisions, qualifying investors may subsequently incorporate certain new dependents, including children born or adopted after the original approval and a new spouse following a civil marriage entered into after the principal applicant obtained residence, provided the applicable requirements are met.
This gives families additional flexibility when considering Panama as part of a longer-term international mobility strategy.
Additional safeguards for real estate investments
The new decree also strengthens mechanisms for verifying the value of qualifying real estate.
Authorities may, under circumstances established by the decree, request an independent commercial appraisal to verify that the declared investment is supported by the property's market value. This is not an automatic requirement for every transaction.
When required, the appraisal must meet specific conditions regarding timing, professional qualifications and independence.
These measures reinforce the integrity of the program and seek to ensure that qualifying investments represent genuine economic value.
Greater clarity for projects under development
Another particularly relevant development for investors considering new construction projects is the treatment of investments made through a promise of sale agreement.
The decree allows qualifying real estate investments from USD 300,000 to be structured through a promise of sale, including a modality in which the investment is deposited into a trust administered by a bank or licensed trust company in Panama, subject to the requirements established in the decree.
This provides a defined regulatory structure for investors participating in eligible projects that are still under development.
A more structured administrative pathway toward naturalization
Executive Decree No. 17 also addresses the administrative process applicable to Qualified Investors who may later seek Panamanian citizenship.
Naturalization applications for qualifying investors are to be submitted through the specialized investment window of MICI. The provision applies in the context described by the decree to Qualified Investors and dependents who have completed five consecutive years of residence in Panama.
Importantly, this does not create automatic citizenship after five years, nor does investment itself guarantee naturalization.
Applicants remain subject to Panama's constitutional and legal requirements and the corresponding naturalization procedure. The change instead provides a more specialized administrative channel for submitting and processing such applications.
Investment must be maintained for five years
The decree maintains the requirement that the qualifying investment be held for a minimum of five years, with annual confirmation of the investment to MICI.
The updated framework also provides a mechanism for replacing a qualifying investment if it is sold, ceases or is substituted before the five-year period is completed.
In such circumstances, the investor must notify MICI within 30 calendar days and may receive up to 90 calendar days to document an eligible replacement investment, subject to the conditions established by the decree.
What does the new decree mean for Mercan Panama investors?
For Mercan Panama, this development is particularly relevant. Mercan's current Panama portfolio includes qualifying new, first-sale real estate projects, which fall within the USD 300,000 minimum investment threshold, subject to the individual investment and applicant meeting all applicable program requirements.
This includes opportunities within ALBOR at Santa María and Pullman Panama City, giving international investors access to real estate opportunities that can be structured within Panama's Qualified Investor Program.
The decree also expressly recognizes a promise-of-sale structure involving funds placed in a licensed trust as an eligible mechanism, subject to its specific requirements, an important consideration for qualifying projects under development.
Panama reinforces its long-term commitment to investment
Executive Decree No. 17 sends an important signal about the continued development of Panama's residence-by-investment framework.
By maintaining the USD 300,000 threshold for qualifying new real estate, introducing defined administrative timelines, strengthening investment safeguards and providing additional clarity for investors and their families, Panama is establishing a more structured framework for international investment.
For investors considering Panama residency through real estate investment, understanding both the opportunities and the requirements of the updated Qualified Investor Program will be essential.
Mercan Panama continues to support international investors and partners with real estate opportunities designed to align with the Qualified Investor Program and with guidance throughout the investment process.
This article is provided for general informational purposes only and does not constitute legal, immigration, tax or financial advice. Eligibility under the Qualified Investor Program is subject to applicable Panamanian laws, regulations, documentation requirements and individual circumstances.
Frequently Asked Questions
What is the minimum real estate investment required for Panama’s Qualified Investor Program in 2026?
Under Executive Decree No. 17, the minimum investment for qualifying new, first-sale real estate is USD 300,000. For qualifying real estate purchased on the secondary market, the minimum investment is USD 500,000.
Can I qualify for Panama residency by investing in a property that is still under development?
Yes, subject to the requirements of the program. The new framework recognizes qualifying real estate investments made through a promise of sale agreement, including a structure where the required investment is placed in a licensed trust. This provides a pathway for eligible investments in qualifying projects under development.
How long does the Qualified Investor residency process take in Panama?
Executive Decree No. 17 establishes defined administrative timelines. Once the investment certification file is formally admitted, the Ministry of Commerce and Industries (MICI) has up to 15 business days to issue the investment certification. Once the complete immigration file is received, the National Migration Service has up to 30 business days to issue the residence resolution, subject to the applicable requirements and procedures.
Do Mercan Panama projects qualify for the Qualified Investor Program?
Mercan Panama offers new, first-sale real estate investment opportunities designed to align with the Qualified Investor Program. Under the new framework, qualifying investments in this category may be eligible from USD 300,000, subject to the selected property, investment structure and the applicant meeting all applicable program requirements.
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