On September 19, 2025, U.S. President Donald J. Trump signed an Executive Order (“the Order”) establishing the “Gold Card” visa program.1, 2  The initiative is designed to allow expedited immigration processing for foreign nationals who provide significant financial contributions to the United States.  Under the program, immigrant visas may be granted to individuals who gift US$1 million.  Companies may fast-track visas for sponsored workers by gifting US$2 million.  (For prior coverage of the Gold Card visa program see the following issues of GMS Flash Alert: 2025-054 (March 7, 2025) and 2025-048 (March 3, 2025).)

      The program is designed to attract wealthy individuals and businesses to the United States.  The Gold Card visa program marks a notable shift in U.S. immigration policy, prioritizing financial contributions and economic benefit.  The stated purpose of the program is to recognize financial contributions as a form of business capability and public benefit, while ensuring compliance with existing legal and security standards.  There is concern that the program will replace the current EB-1 and EB-2 immigrant visa programs for exceptional ability, national interest, and merit individuals.

      The secretary of commerce, in coordination with the secretaries of state and homeland security, is tasked with developing the program.  The Order requires the creation of application procedures, fee structures, and an evaluation of whether similar provisions could apply to other visa categories in the next 90 days. 


      WHY THIS MATTERS

      The Gold Card visa program introduces a change to U.S. immigration policy by prioritizing individuals who make substantial financial contributions.  The program is expected to generate revenue for the federal government and provide an expedited immigration pathway for entrepreneurs, investors, and business professionals.

      Entities and organizations that plan to avail of this new pathway to entry may need to revise recruitment and compliance procedures to align with the new visa category and its requirements.

      While the program may simplify immigration steps for eligible individuals, it could also introduce complexities in reporting and due diligence for both the applicants and institutions involved.  

      If the Gold Card visa program becomes a substitute for the current EB-1 and EB-2 programs, individuals who currently qualify under these programs may be left without a path to a U.S. green card.  These programs have long been critical tools for American employers to access the skilled talent needed to fuel growth, innovation, and job creation.


      Additional Details 

      Comments from Secretary of Commerce

      Commerce Secretary Howard Lutnick stated that the Gold Card visa will replace the EB-1 and EB-2 programs, targeting individuals of exceptional value to the United States.3

      He emphasized that the program is designed to attract top-tier talent and investment, projecting it could generate US$100 billion in revenue.  Also, he noted that 80,000 Gold Cards will be issued initially, with potential expansion and the phasing out of other visa categories.

      Furthermore, Secretary Lutnick described the program as a shift away from lower-skilled immigration, stating the U.S. will prioritize “extraordinary people at the very top.”  The Gold Card will function similarly to a green card, with holders subject to global taxation.  The cost is set at US$1 million per individual, US$2 million for corporate sponsorship, plus a US$15,000 vetting fee.  He also clarified that the proposed Trump Platinum Card is not currently under consideration and would require Congressional approval.


      KPMG INSIGHTS

      Organizations may wish to review their talent acquisition strategies to identify candidates who may qualify for the Gold Card program, and they may wish to assess the impact of these changes on existing immigration programs and adjust internal policies.  Moreover, they may also wish to work with their immigration advisers and/or HR/global mobility professionals to begin the process of identifying candidates who, if these categories are replaced, may no longer qualify for the current EB-1 and EB-2 exceptional ability, national interest, and merit categories, and explore options for these individuals.

      Legal and compliance teams should monitor the development of application procedures and make sure that all processes adhere to new regulatory requirements.

      What’s Next?

      KPMG Law LLP in Canada will continue to monitor this development, and endeavor to inform readers of GMS Flash Alert if anything important occurs.  Questions about eligibility and applications, as well as the impact of this new program on individuals and organizations, should be directed to a qualified immigration adviser or a member of the immigration team with KPMG Law LLP in Canada (see the Contacts section).


      FOOTNOTES:
      1. The White House, “Fact Sheet: President Donald J. Trump Launches the Gold Card Program,” (September 19, 2025).
      2. American Immigration Lawyers Association, “Executive Order on the Gold Card (9/24/25  AILA Doc. No. 25091903), published on the AILA websitePlease note that by clicking on this link, you are leaving the KPMG website for an external site (non-governmental, non-KPMG), that KPMG is not affiliated with nor does KPMG endorse its content.  The use of the external site and its content may be subject to the terms of use and/or privacy policies of its owner or operator
      3. As reported in:

      Please note that by clicking on the above-noted links, you are leaving the KPMG website for an external site (non-governmental, non-KPMG), that KPMG is not affiliated with nor does KPMG endorse its content.  The use of the external site and its content may be subject to the terms of use and/or privacy policies of its owner or operator.

      Contacts

      Kirsten Kelly

      Partner, Immigration Law

      KPMG in Canada

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      GMS Flash Alert reports on recent global mobility-themed developments from around the world to help you better understand what has changed and what that means for you.


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      * Please note the KPMG International member firm in the United States does not provide immigration or labour law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.

      The information contained in this newsletter was submitted by the KPMG International member firm in Canada.

      GMS Flash Alert is a Global Mobility Services publication of the KPMG LLP Washington National Tax practice. The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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