In late 2025, U.S. immigration news introduced a new, highly controversial term — “Gold Card”. The program is designed to provide a pathway to U.S. lawful permanent residence (a green card) through a large donation to the U.S. government, rather than through employment, family sponsorship, or a traditional investment project.
On 19 September 2025, President Trump signed an Executive Order establishing the Gold Card visa program. The initiative is framed as a way to attract high-net-worth foreign nationals who are ready to make a significant, unrestricted financial gift to the U.S. in exchange for an expedited route to permanent residence.
It is critical to understand that as of the end of 2025 the Gold Card is still in the implementation phase. U.S. Citizenship and Immigration Services (USCIS) has sent a draft of Form I-140G to the Office of Management and Budget (OMB) for review. This form would be the main petition for the program. Until OMB approval and official publication, no one can file a real Gold Card case yet.
Why the Gold Card is being discussed right now
The current wave of attention is driven by several parallel developments:
- the Executive Order formally creating the Gold Card program and setting a tight implementation deadline;
- USCIS sending draft Form I-140G to OMB — a key procedural step toward launch;
- coverage by major law firms and global media detailing donation amounts, filing fees, and expected processing;
- rising filing fees and stricter rules in other routes (H-1B, EB-5, etc.), which makes a “fast, donation-based corridor” look attractive for some.
For Russian- and Ukrainian-speaking audiences, the Gold Card is still largely unexplained. At the same time, it potentially affects entrepreneurs, investors, and founders who are considering relocation to the U.S. but do not want — or cannot afford — a long process of building an EB-1A / EB-2 NIW case or structuring a full EB-5 project.
Key parameters of the Gold Card as of late 2025
The regulatory framework is still evolving, but based on the Executive Order and recent professional analyses, the following elements are publicly described:
- Non-refundable donation: US$1 million for individual petitioners and US$2 million when a corporation donates on behalf of an employee.
- Dedicated petition form I-140G: USCIS has sent draft Form I-140G to the Office of Management and Budget for federal review; OMB approval is required before the form can be used.
- Significant filing fee: current drafts and commentary reference an expected non-refundable filing fee of about US$15,000 per case.
- Recipient of the donation: funds are directed as an unrestricted gift to the U.S. Department of Commerce or a related fund, not to a private commercial project as in EB-5.
- Projected volume: USCIS estimates around 1,000 applicants per year, though final caps and country limits may still change.
The bars are schematic, but they show the basic idea: when the donation is made by a company on behalf of an employee, the entry price is roughly twice as high.
How the process is expected to work
Final instructions have not yet been published, but based on the draft I-140G process and public commentary, a typical sequence may look like this:
- Pre-screening and profiling. The prospective donor (or their representatives) completes an initial questionnaire and is screened for basic eligibility, including sanctions checks and minimum donation thresholds.
- Payment of the non-refundable filing fee. The fee is expected to be paid electronically (for example, via pay.gov) and is not returned even in case of denial.
- Filing Form I-140G with USCIS. USCIS reviews the petitioner’s eligibility, the lawfulness of the funds, and security concerns.
- Transfer of the donation. After preliminary approval, the donor makes the required payment to the designated government fund.
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Immigrant visa or status adjustment.
Once the petition is approved and the donation is confirmed, the beneficiary either:
- applies for an immigrant visa at a U.S. consulate abroad; or
- files for adjustment of status inside the U.S., if eligible.
Unlike EB-5, this is not an “at-risk investment” model. There is no requirement to create a specific number of jobs or to keep capital invested in a project. Instead, the donation is treated as an unrestricted gift to the U.S. government, combined with rigorous vetting of the donor and the source of funds.
Gold Card vs. EB-5, EB-1A and EB-2 NIW: what really changes
To understand who might realistically use the Gold Card, it helps to compare it with more familiar options: EB-5 (investor green card), EB-1A (extraordinary ability) and EB-2 NIW (National Interest Waiver).
| Parameter | Gold Card | EB-5 / EB-2 NIW (high-level) |
|---|---|---|
| Core basis | Non-refundable donation to the U.S. government (Department of Commerce) |
EB-5: investment into a project that must create jobs. EB-2 NIW: strong evidence that the applicant’s work benefits U.S. national interests. |
| Return of funds | No capital return; the donation is irrevocable. |
EB-5: capital may be returned if the project is successful (with risk). EB-2 NIW: no mandatory investment requirement. |
| Profile requirements | High net worth, clean and traceable source of funds, security and sanctions screening. |
EB-5: emphasis on investment funds and job creation. EB-2 NIW / EB-1A: emphasis on achievements, publications, impact in the field, and national benefit. |
| Regulatory / political risk | High: created by Executive Order, subject to future policy shifts and litigation. | Lower: categories are codified in statute; changes tend to be slower and more predictable. |
| Target group | Very narrow group of ultra-wealthy donors. | EB-2 NIW and EB-1A are accessible to a broader group of talented professionals. |
Gold Card: non-refundable donation to the U.S. government.
EB-5 / EB-2 NIW: EB-5 requires an investment that creates jobs; NIW is based on the applicant’s contribution to U.S. national interests.
Gold Card: donation is irrevocable; no capital is returned.
EB-5: investment may be returned but is exposed to business risk.
EB-2 NIW: no major investment required by default.
Gold Card: high political and legal uncertainty, narrow target audience of ultra-rich applicants.
EB-1A / EB-2 NIW: more stable legally, but require a strong track record of achievements instead of a seven-figure donation.
Where the Gold Card may look attractive — and where it does not
Potential advantages for some applicants:
- no need to design and run a complex EB-5 project with job-creation metrics;
- no need to build a detailed portfolio of publications, awards and citations as for EB-1A / EB-2 NIW;
- marketing from proponents frames it as a faster, more “predictable” route once the donation is confirmed.
Major downsides:
- purely non-refundable: the donor permanently loses US$1–2 million;
- political and legal uncertainty: the program may face lawsuits, congressional pressure or a policy reversal;
- reputational and compliance risks: heavy media scrutiny and strict anti-money-laundering (AML) checks.
In other words, the Gold Card is designed for people who do not want to gamble on EB-5 projects and do not wish to spend years building an EB-1A / EB-2 NIW record — but for whom a seven-figure donation is acceptable from a family wealth perspective.
Who, in practical terms, might consider the Gold Card
Based on the donation levels and current policy descriptions, the Gold Card clearly targets ultra-high-net-worth individuals. Typical profiles might include:
- Founders of large technology companies and high-growth startups who want a stable base in the U.S. but do not want to wait for a full EB-1A / EB-2 NIW record or build an EB-5 project.
- Investors and family-office principals for whom a US$1–2 million donation is acceptable as a “price of entry” to permanent residence.
- Entrepreneurs with complex cross-border structures who find it hard to fit their cash flows into EB-5 project requirements but can document a clean, lawful source of funds for a donation.
By contrast, for most highly skilled professionals — software engineers, researchers, product managers, doctors, senior managers — categories like EB-2 NIW, EB-1A, O-1, or carefully planned work visas will usually be more sensible in terms of cost-to-benefit ratio, even with rising filing fees.
Key risk clusters: from politics to fraud
The main risk areas around the Gold Card can be grouped roughly into three levels:
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Political risk.
The program is based on an Executive Order and active administrative policy. If political winds shift,
authorities may:
- change donation thresholds or tighten eligibility criteria;
- impose additional country-specific restrictions;
- slow down or suspend the program, or even attempt to roll it back.
-
Legal and compliance risk.
At this scale, applicants should expect very strict scrutiny of:
- source of funds (tax returns, banking records, AML checks, crypto holdings);
- sanctions exposure and politically exposed person (PEP) status;
- links to sensitive sectors such as defense or sanctioned jurisdictions.
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Fraud risk.
Any high-ticket immigration product inevitably attracts:
- “consultants” selling fake “priority slots” or “pre-approval” before launch;
- unauthorized platforms collecting “Gold Card deposits” outside official channels;
- schemes promising to secretly refund part of the donation.
How the Gold Card fits into your immigration strategy
As a founder with a scalable business, you typically have at least three realistic paths: EB-2 NIW (impact of your venture on the U.S. economy), EB-1A (your personal achievements), and L-1A → EB-1C (if you run a qualifying foreign company and open a U.S. affiliate).
In this context, the Gold Card should be seen as a complement, not a replacement. If your venture needs time to mature but your capital is already substantial, a donation-based route might “buy time” by securing status while your business metrics catch up — but only if the cost is acceptable relative to your total assets.
For investors and family-office principals, the Gold Card competes directly with EB-5. In simple terms, you are choosing between:
- a pure donation with a relatively simple legal structure; or
- an EB-5 investment with job-creation requirements and business risk, but some chance of recovering capital.
Here, the question is less about immigration law and more about risk, liquidity, and long-term wealth planning. No decision should be made without coordinated tax, financial, and legal advice.
If your main asset is your professional track record — as a scientist, engineer, creative professional, or executive — and not a spare US$1–2 million, then categories like EB-1A, EB-2 NIW, O-1, or structured work visas will almost always be more rational.
In such cases, the Gold Card only makes sense if a seven-figure donation does not materially affect your family’s financial security, and if speed and predictability truly matter more than the money itself.
This strategy helper is not legal advice, but it highlights the questions you should raise with your attorney: how the Gold Card changes your time horizon, what alternatives remain open, and what happens if the program is modified or challenged in court in several years.
Gold Card and existing EB-2 NIW, EB-1A, EB-5 and work-visa plans
For many prospective applicants, the Gold Card appears after other plans have already been set in motion — EB-2 NIW, EB-1A, EB-5, O-1, L-1, or family-based petitions. A natural question follows:
“If I am already pursuing EB-2 NIW / EB-1A / EB-5, should I abandon that plan in favor of the Gold Card?”
There is no one-size-fits-all answer, but several principles are helpful:
- Do not throw away a strong, lawful route for the sake of a program that is not yet operational. Until Form I-140G is fully approved and the program is functioning, the Gold Card remains a work in progress.
- Treat the Gold Card as an additional option, not an automatic replacement. If you have a solid EB-2 NIW or EB-1A profile in development, it usually makes sense to keep strengthening it while monitoring the Gold Card’s progress.
- Align the donation with your long-term financial plan. A US$1 million gift may be minor for a billionaire, but it can dramatically change the risk profile for a family with US$3–5 million of total assets.
- Factor in family structure. You need clarity on how the Gold Card status would extend to spouses and children, what age cut-offs apply, and whether dependent benefits mirror those in other employment-based categories.
At the same time, broader immigration policy changes are happening in parallel: higher H-1B fees, potential EB-5 adjustments, and more aggressive public-charge and tax-benefit rules. All of this influences whether the Gold Card evolves into a mainstream option for the ultra-wealthy, or stays a niche route with uncertain longevity.
— ongoing work on EB-1A / EB-2 NIW credentials,
— evaluation of EB-5 or other investment routes,
— and, where appropriate, a careful cost–benefit analysis of the Gold Card, taking into account tax, family, and country-of-origin risks.
Primary sources on the U.S. Gold Card program
The key figures and timelines in this article are based on the following English-language materials. For real-world planning, always check the most up-to-date versions of these documents.
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Executive Order and official description of the Gold Card program.
Executive Order on the Gold Card (AILA summary of EO 14351)
Reproduces the text of Executive Order 14351, which directs agencies to create the Gold Card visa program and sets donation thresholds of US$1 million for individuals and US$2 million for corporate sponsors. -
Detailed analysis of the Executive Order and launch timeline from KPMG.
United States: Executive Order Establishes Gold Card Program
Explains the purpose of the Gold Card, donation amounts, the role of the Department of Commerce, and the expedited processing objective, as well as the initial 90-day implementation window. -
Fragomen insight on USCIS sending draft Form I-140G to OMB.
USCIS Takes Preliminary Step Toward Implementation of Gold Card Program
Describes draft Form I-140G, why OMB approval is required, and how this step fits into the administration’s plan to launch the Gold Card by the December 18, 2025 deadline. -
Times of India coverage of donation amounts and application structure.
USCIS takes first step towards launch of the Gold Card program
Confirms proposed donation levels of US$1 million for individuals and US$2 million for corporations, notes an expected US$15,000 filing fee, and outlines a three-step process involving the Department of Commerce, payment and filing of Form I-140G. -
WR Immigration news digest on USCIS progress.
WR Immigration News Digest: Gold Card Program Update
Summarizes USCIS steps toward implementing the Gold Card, emphasizing the significance of the I-140G draft submission and discussing potential impacts on the broader investor-visa landscape. -
Practical guide from Herman Legal Group (Lawfirm4Immigrants) on Gold Card I-140G.
Gold Card I-140G: $1M Donation Green Card Program Guide
Provides a practitioner-level overview of donation amounts, expected filing fees, who is most affected, and how the Gold Card may interact with EB-5, EB-1 and EB-2 NIW, while stressing that the program is not yet active and carries substantial litigation risk.
Because the regulatory framework for the Gold Card is evolving, any serious strategy discussion should be based on the latest official USCIS, Federal Register and Executive Order documents, complemented by current analysis from reputable immigration law firms — not on media headlines alone.
