Panama has updated the regime applicable to the Permanent Resident subcategory as a Qualified Investor through Executive Decree No. 17 of September 8, 2026, published in Official Gazette No. 30613 and effective as of September 16, 2026.

The new regulations replace the regime established under Executive Decree No. 722 of 2020 and its amendments, introducing relevant changes to the investment modalities, the criteria applicable to real estate investments, the accreditation of funds, and the maintenance of the investment.

Beyond changes to the required investment amounts, the new framework requires greater precision in how the investment is structured and documented. The investment must originate from abroad, be maintained for a minimum period of five years, and may be made in the applicant’s personal capacity or through a domestic or foreign legal entity.

1. Investment in Completed Real Estate

The minimum investment will depend on the type of property:

Type of Property	Minimum Investment
First sale	B/.300,000
Secondary market	B/.500,000

For purposes of a first sale, the Decree refers to the initial acquisition of a new and previously unoccupied property transferred by the developer, promoter, or their successor in title.

By contrast, the secondary market category covers properties that have previously been marketed, occupied, leased, or transferred to unrelated third parties.

This distinction changes the way a real estate investment intended to support a residency application should be evaluated.

The Decree establishes specific rules for determining the net qualifying value of the real estate investment.

This value will be the lower of the price actually paid and the reasonably substantiated market value, less the outstanding balance of any liens or encumbrances affecting the property.

2. Investment in Real Estate Under Construction or Pre-Sale

Type of Property	Minimum Investment
First sale	B/.300,000

The new regime maintains mechanisms involving trusts and includes bank guarantees for certain construction-stage investment structures.

Accordingly, before entering into a purchase agreement, an investor should review not only the property and the developer, but also:

• the contractual structure;

• the payment structure and schedule;

• the protection of the funds;

• the guarantees available;

• the conditions for registration of the property; and

• the documentation required to evidence the investment.

3. Investment in the Securities Market

Investments in the securities market remain available, with a minimum investment of B/.500,000.

These investments must be made through a Securities House (Casa de Valores) licensed by the Superintendency of the Securities Market of Panama.

Eligible instruments include:

• Private Equity and Structural Risk Funds;

• Bonds and financial instruments issued by the Government of Panama; and

• Other registered corporate securities.

4. Fixed-Term Deposit with a Bank Holding a General License in Panama

The minimum investment remains at B/.750,000 for certain deposits with private banks, with an alternative investment threshold of B/.500,000 when the deposit is established with Banco Nacional de Panamá or Caja de Ahorros, subject to the applicable conditions.

What Happens to Those Who Had Already Started an Investment?

The Decree contains provisions applicable to certain investments and binding agreements existing prior to its entry into force.

This may be particularly relevant for individuals who had signed agreements, made payments, or initiated transactions before September 16, 2026.

However, the application of the transitional regime depends on the specific characteristics of each transaction and compliance with the applicable deadlines and requirements.

Accordingly, any pre-existing transaction should be reviewed on an individual basis before assuming that it automatically remains subject to the conditions of the previous regime.

Recommendations

Before committing capital, investors should verify:

1. Investment modality. Determine which of the alternatives available under the regime best aligns with the investor’s objectives.

2. Qualifying investment amount. Confirm that the amount actually qualifying under the applicable rules meets the required minimum.

3. Nature of the asset. For real estate investments, determine whether the transaction qualifies as a first sale or a secondary-market acquisition.

4. Ownership structure. Review whether the investment will be made directly or through a company or foundation.

5. Source and traceability of funds. Prepare the corresponding banking and documentary evidence in advance.

6. Contracts and guarantees. This is particularly relevant for pre-construction transactions.

7. Maintenance of the investment. Assess the applicable holding requirements and the consequences of any potential sale, substitution, or modification of the investment.

At FABREGA MOLINO, we assist international investors and families in the legal structuring of their investments and the planning of their residency processes, integrating the immigration, corporate, real estate, and wealth-planning aspects of each transaction.