Monday 15 December 2025

On 10 December 2025, the US government officially launched President Trump’s new “Gold Card” initiative, an immigration program established by executive order in September to enable foreign nationals to apply for permanent residency through large financial contributions to the US Treasury. According to the administration’s official website, TrumpCard.gov, the program is designed to deliver decisions in “record time.”

Program overview

The Gold Card program allows both individual applicants and employer sponsors to pursue permanent residency under the existing EB-1 Extraordinary Ability and EB-2 National Interest Waiver (NIW) categories. Allegedly, the program does not seek to replace or modify these statutory pathways but directs the US government to treat qualifying financial contributions as additional evidence that may support eligibility within these categories.

As background, traditionally under the EB-1 Extraordinary Ability and EB-2 NIW classifications, applicants are required to demonstrate eligibility through professional accomplishments, academic credentials, publications, recognition in their field, and evidence of contributions to the national interest. Under the Gold Card framework, the Department of Homeland Security (DHS) is meant to continue applying these statutory standards but may consider the required donations as part of the overall evidentiary showing when adjudicating EB-1 Extraordinary Ability and EB-2 NIW petitions.

Required donations and fees

Fees for individual applicants including spouses and children under 21 (each):

• A $15,000 nonrefundable DHS processing fee; and
• A $1 million donation to the US Treasury.

Fees for employer sponsors under the corporate program (per application):

• A $15,000 DHS processing fee; and
• A $2 million donation.

Additionally, the following annual fees will apply under the corporate program:

• A 1% annual maintenance fee on the $2 million donation (approximately $20,000 per year). Importantly, for beneficiaries from heavily backlogged countries, these fees may accrue for multiple years; and
• A 5% transfer fee (approximately $100,000) if an employer reassigns its donation to a different foreign national employee.

This fee rollout on the official website represents the government’s first formal confirmation that derivative beneficiaries are subject to the full donation and fee structure and marks the first indication of recurring and transfer-related costs under the corporate program.

Application process
Current government guidance outlines the following steps:

1. Gold Card Application – Applicants or sponsoring employers begin by submitting personal and biographical information through TrumpCard.gov.
2. Payment of DHS Fees – The nonrefundable $15,000 DHS fee must be submitted via Pay.gov for each applicant and derivative beneficiary.
3. Online Filing of Form I-140G – Applicants must create a USCIS online account if they do not already have one and file Form I-140G. This form will be used to verify that donation funds originate from a lawful source. Paper filings will not be accepted.
4. Treasury Donation – After preliminary vetting, applicants will receive instructions for submitting the required donation via ACH or wire transfer. Form I-140G approval will follow confirmation of payment.
5. Consular Processing – Once a visa number is available, applicants will complete consular processing using Form DS-260G and attend an in-person interview at a US consulate. Successful applicants will be admitted to the United States as lawful permanent residents.

The government has not yet clarified whether applicants already in the United States will be permitted to adjust status domestically instead of undergoing consular processing abroad.

Processing times and regulatory outlook
Although the Gold Card program promises an expedited route to permanent residency, current government statements offer only vague indications of processing speed. The administration’s website notes that once the Gold Card application and DHS fee are submitted, processing “should take weeks.” However, it is unclear whether this estimate applies to the Gold Card application itself, the adjudication of Form I-140G, or only the donation-verification stage.

Moreover, the final consular interview phase typically requires several months, and applicants and beneficiaries may still be subject to standard visa-number availability under the Visa Bulletin. As such, for foreign nationals from heavily backlogged countries, the overall timeline may not differ significantly from traditional permanent residency pathways.

Conclusion
This policy rollout comes amid broader efforts by the Trump administration to reshape the immigration system through unconventional mechanisms, including the recently announced “Trump Platinum Card,” which would allow foreign nationals to remain in the United States for up to 270 days per year without US taxation on foreign-sourced income in exchange for a $5 million contribution. Overall, the Gold Card program injects financial-contribution-based benefits into immigration categories long defined by merit, which creates serious questions about legal authority and regulatory consistency. As such, this unprecedented approach is likely to face legal scrutiny that could jeopardize the program’s long-term viability.

We will continue to closely monitor the Gold Card program and provide updates as new developments emerge.

If you have any questions, please contact your Laura Devine Immigration attorney or email enquiries@lauradevine.com.