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U.S. Gold Card Program (2025): A Million-Dollar Path to U.S. Permanent Residence

Author: Orlando Ortega, Esq., U.S. Business Immigration Attorney

What Is the U.S. Gold Card Program?

The U.S. Gold Card Program is a new, donation-based pathway to U.S. permanent residence
introduced by the Trump administration in 2025. Under this framework, certain high-net-worth
individuals may qualify for a fast-track to a green card by making a substantial financial gift
to the U.S. government.

The program is being developed by the Department of Commerce in coordination with
USCIS (U.S. Citizenship and Immigration Services) and the Department of State.
While the executive framework has been announced, the detailed regulations have not yet been
finalised.

Donation Amounts and Required Financial Commitment

The executive order defines two donation thresholds:

  • US $1,000,000 for individual applicants; or
  • US $2,000,000 where a corporation donates on behalf of an individual beneficiary.

A separate USCIS filing fee – anticipated to be around US $15,000 per primary applicant –
is expected but has not yet been officially published.

At present, the donation appears to apply to the principal donor only. As in other U.S.
immigrant categories, it is expected (but not yet confirmed) that spouses and minor children
will be eligible as derivative beneficiaries without making their own donation.

How the Gold Card Fits Within the U.S. Immigration System

Rather than creating a brand-new visa category by statute, the Gold Card relies on existing
employment-based green card categories, particularly:

  • EB-1 – Persons of extraordinary ability; and
  • EB-2 National Interest Waiver (NIW).

A dedicated petition (currently described in draft form as Form I-140G) will be used to
demonstrate both immigration eligibility and the lawful source of the donated funds.

Gold Card vs. EB-5 Investor Green Card

The Gold Card is fundamentally different from the long-standing EB-5 Immigrant Investor Program.
Here are the key distinctions:

  • Purpose of funds: EB-5 requires investment into a U.S. business that creates jobs. The Gold Card involves an unrestricted gift to the U.S. government.
  • Risk profile: EB-5 funds are at risk in a commercial venture. Gold Card funds are a government donation with no project risk.
  • Documentation focus: EB-5 centres on business plans and job creation. Gold Card applications emphasise lawful source of funds and immigration eligibility.

Proposed Gold Card Application Process

Based on early government drafts, the process is expected to include:

  1. Application to the Department of Commerce expressing intent to donate.
  2. Payment of government processing fees and arrangement of the donation.
  3. Filing of the immigrant petition (e.g., Form I-140G) with USCIS, documenting:
    • lawful source and path of funds;
    • donation compliance; and
    • EB-1 or NIW eligibility.
  4. Consular processing or adjustment of status, depending on the applicant’s situation.

Each step will likely involve rigorous due diligence, security screening, and extensive documentation,
similar in complexity to existing high-end business immigration categories.

Who Should Consider the Gold Card?

The program may be suitable for individuals who:

  • can access US $1–2 million in liquid, well-documented funds for the gift alone;
  • prefer a direct, donation-based route rather than EB-5 investment risk;
  • want a potentially faster path to a green card; and
  • understand the legal and political uncertainties of a program created by executive order.

Current Status: Is the Gold Card Open Yet?

As of late 2025, the Gold Card is not yet accepting applications. USCIS has not released:

  • final regulations,
  • the official immigrant petition form, or
  • the definitive fee schedule.

Additional guidance from the Department of Commerce and USCIS is expected in the coming weeks.
Until then, all information remains subject to change.

Risks and Considerations

Because the Gold Card is based on an executive order rather than an act of Congress, it carries
inherent legal and political risks. Possible issues include:

  • future policy changes or program suspension;
  • legal challenges to the donation-for-residency model;
  • enhanced security and financial scrutiny;
  • processing delays as agencies develop internal procedures.

How We Can Help

Despite the apparent simplicity of a million-dollar gift, the Gold Card will involve
complex immigration, financial and documentary requirements. Our firm advises
clients on:

  • whether the Gold Card is the right option compared with EB-5 or other routes;
  • structuring a lawful, traceable source of funds for the donation;
  • preparing a strong EB-1 or NIW immigrant petition;
  • coordinating with tax and financial advisers; and
  • navigating consular processing or adjustment of status.

Contact Us

If you are considering the U.S. Gold Card Program as part of your global mobility
strategy, we welcome you to contact our team for a confidential consultation.
Visit our Contact page or email enquiries@ortega-medina.com.

This article is provided for general information only and does not constitute legal advice.
You should obtain advice tailored to your individual circumstances before taking any action.