Trump Gold Card: How the $1 Million Visa Works

The Gold Card program was announced by President Donald Trump in February 2025 as a proposed fast-track route to permanent residency in the United States for high-net-worth foreign nationals. After months of regulatory uncertainty, the Executive Order Restoring American Investment, signed on September 19, 2025, established the program’s operational framework and set the official contribution amounts.

Despite the robust announcement and the launch of the official website trumpcard.gov, the Gold Card remains in partial implementation as of this writing. This analysis covers what has been effectively regulated, what remains open, a comparison with the existing EB-5 program, and the main anticipated legal challenges.

What the Gold Card Is

The Gold Card is a new expedited-processing immigrant visa category designed for individuals willing to make a substantial financial contribution — formally referred to as a gift in official documents — to the U.S. government. Its structural premise differs from that of the EB-5 Immigrant Investor Program: while the EB-5 requires an at-risk investment in a commercial enterprise that creates at least ten American jobs, the Gold Card converts residency into a purchasable benefit through a direct donation to the Department of Commerce.

Official Amounts and Sponsorship Structure

The September 2025 Executive Order established two contribution tiers:

• Individual sponsorship: $1 million for the applicant donating in their own name.
• Corporate sponsorship: $2 million for a company or similar entity donating on behalf of a designated individual.

The $5 million figure mentioned in February 2025 reflected Trump’s initial verbal proposal and was subsequently reduced by the Executive Order. Additionally, there is a non-refundable processing and vetting fee of $15,000, confirmed by a statement from Commerce Secretary Howard Lutnick.

The Platinum Card and Tax Residency

Alongside the Gold Card, the administration proposed the Platinum Card, with a $5 million contribution. The Platinum’s key differentiator is not residency itself, but the option for the holder to spend up to 270 days per year in the United States without being treated as a U.S. tax resident on foreign-source income, under the Internal Revenue Code rules applicable to non-immigrants. This structure has parallels with selective tax residency programs used in jurisdictions such as Portugal and Italy.

How the Gold Card Aims to Replace the EB-5

Secretary Lutnick stated in an interview that the Gold Card will replace the EB-1 and EB-2 programs for individuals of exceptional value to the United States. Technically, however, the EB-5 is codified in federal statute — sections 203(b)(5) and 216A of the Immigration and Nationality Act — and its revocation would require an act of Congress, not merely an executive order.

As of this writing, the EB-5 remains operational with the same parameters of $800,000 (TEA) and $1,050,000 (standard area) established by the EB-5 Reform and Integrity Act of 2022, valid through September 2027. Investors in the process of filing I-526E or I-829 are not affected by the Gold Card.

Expanded Eligibility Criteria

The Executive Order defines the payment of the contribution as evidence of:

• Extraordinary ability in sciences, arts, education, business, or athletics (a standard historically associated with the EB-1A).
• Exceptional ability in business.
• Eligibility for a National Interest Waiver.

In practice, this eliminates the need for robust documentary proof of the usual criteria — awards, peer-reviewed publications, citations, original contributions — replacing that evidence with financial capacity.

Application and Timeline

The Executive Order set a 90-day deadline for the Secretaries of Commerce, State, and Homeland Security to implement a clear process, with a target date of December 18, 2025. The detailed final rule has not yet been published in the Federal Register as of this writing, and the trumpcard.gov website maintains only a waitlist registration mechanism.

When published, the regulation is expected to address three key points:

• The application procedure and expedited adjudication of petitions.
• Consular issuance of the visa and the adjustment of status process for those already in the U.S.
• The effective start date for receiving financial contributions.

Transferability of Corporate Sponsorship

A novel feature of the Gold Card is its transfer mechanism. If a company-sponsored beneficiary abandons the status — through voluntary departure, termination, or return to their home country — the company may designate a new individual to receive the benefit originally tied to the initial contribution.

The new beneficiary must still pass all standard admissibility screenings, and maintenance and transfer fees will be charged separately. This design resembles transferable quota mechanisms found in corporate immigration programs in the United Kingdom and Australia.

Path to Citizenship

The Executive Order does not define an explicit route to naturalization, but the general rules applicable to green card holders remain in effect: five years of lawful, continuous permanent residency with physical presence for at least half of that period, residence in a USCIS district for three months prior to filing, basic knowledge of English and American history and civics, and good moral character. The petition is filed via Form N-400.

The Executive Order contains no provision for expedited naturalization processing for Gold Card holders. The standard N-400 process currently takes between 8 and 14 months, depending on the field office.

Critical Analysis and Legal Challenges

The Gold Card program faces considerable legal risks. The central question is whether the Executive Branch can create a new immigrant visa category — or redirect existing categories — without legislative action. The Constitution grants Congress the power to establish uniform rules of naturalization (Article I, Section 8, Clause 4), and courts have historically held that the Executive administers but does not substantively create immigration categories.

Constitutional and immigration law experts anticipate declaratory actions filed by civil society organizations, opposing state governments, and potentially aggrieved EB-5 investors. There is an expectation of injunctive relief that could freeze the program before contributions actually begin. A final judicial decision could take years and reach the Supreme Court.

Comparative Overview

Outlook for Investors

For foreign investors considering U.S. permanent residency, the prudent recommendation is to treat the Gold Card as a future possibility rather than an immediate pathway. The EB-5 with investment in a Targeted Employment Area remains operational, with consolidated regulation, established administrative precedent, and a known processing queue.

Multinational companies needing to mobilize executives may wait for the final Gold Card corporate sponsorship regulation, but should keep parallel routes such as L-1A, EB-1C, and O-1 active in their talent planning. The program’s legal volatility makes any financial commitment of $1 million or $2 million premature until the final rule is published and the initial legal challenges are resolved.

Victoria Harper

Editor-in-Chief

Meet the author

Leading journalism and editorial content at Visto n’ Visa, Victoria helps make immigration topics clear, trustworthy, and easy to understand. Her focus is on delivering useful, human, and relevant content for people exploring new paths abroad.