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United States: USCIS Takes Preliminary Step Toward Implementation of Gold Card Permanent Residence Program

November 19, 2025

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At a glance

  • A draft USCIS form that would be used to apply for the highly anticipated Gold Card program – under which a foreign national would be eligible for U.S. permanent residence after a donation of $1 million (for individual petitioners) or $2 million (for corporate petitioners) – is now under federal review, a necessary step toward opening the program to interested applicants.
  • USCIS anticipates that the Gold Card application fee would be $15,000 per applicant.
  • In September, President Trump ordered the Gold Card program to be fully implemented by December 18; further details on the program and process are expected in the coming weeks.

The issue

U.S. Citizenship and Immigration Services (USCIS) has sent a draft Form I-140G – a petition that would be used to seek permanent residence under President Trump’s highly anticipated Gold Card program – to the Office of Management and Budget (OMB) for federal review. OMB approval of the form is a necessary step toward implementing the program by December 18, the deadline imposed by President Trump in an executive order that officially announced the program in September.

Under the Gold Card program, interested individual petitioners and corporate sponsors could make a donation to the U.S. Treasury that would render a foreign national eligible for permanent residence under the EB-1 preference category for individuals of extraordinary ability or the EB-2 National Interest Waiver category. A donation of $1 million would be required of individual petitioners, while a donation of $2 million would be required where an employer is petitioning for a foreign beneficiary.

New details on the proposed Gold Card process

According to draft instructions to the proposed form, the government is planning a process that would entail (1) a Gold Card application filed with the Department of Commerce; (2) payment of a nonrefundable $15,000 fee per applicant through pay.gov; and (3) the filing of the now-draft Form I-140G petition with USCIS. USCIS would use Form I-140G to assess a beneficiary’s eligibility for the new immigrant visa category and to vet the donated funds on which the application is based to ensure that those funds originate from a lawful source. Once the I-140G petition is approved and when an immigrant visa number is available in the requested classification, the government says that an applicant “must complete consular processing with the U.S. Department of State at an embassy or consulate to get an immigrant visa and travel to the United States to be admitted as a lawful permanent resident.” The draft instructions do not address adjustment of status for Gold Card petition beneficiaries, though that option is expected to be available.

USCIS estimates that approximately 1,000 individuals will file the Form I-140G petition annually.

What’s next for the Gold Card program

Though the draft form is an important step toward implementation of the Gold Card program, the process has not been finalized and USCIS and the Department of Commerce are not yet accepting applications. Further details on the process are expected in the coming weeks as the implementing agencies work toward the December 18 deadline.

The government has not yet provided any details on a related Platinum Card program, which was not announced in President Trump’s September executive order but appears as an option on the Administration’s Gold Card website. According to the website, the Platinum Card program would allow a foreign national who makes a $5 million payment to the U.S. government (plus processing fee) to live in the United States for up to 270 days each year without being subject to U.S. taxes on non-US income.

This alert is for informational purposes only. If you have any questions, please contact the immigration professional with whom you work at Fragomen.

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