Comparing investor-residence programmes in the United States, Canada and Europe

The three models are not the same type

In Vietnamese, the phrase investment settlement is often used as an umbrella covering all avenues related to money. That name is convenient for conversation but causes serious confusion when readers enter the decision-making stage. The three most discussed programmes today operate on three separate legal principles, serving three different policy goals in three different jurisdictions.

The US EB-5 is an employment-based immigration programme. The policy focus is on creating jobs for American workers through capital investment in a new commercial enterprise. Canada's residency programme for startups is an entrepreneurial programme that revolves around a business idea with growth potential and requires a designated organisation to support it. The residency by investment or permanent residence by investment programme in Europe is more about direct exchange: A qualifying investment in exchange for residency.

A note on status, worth placing at the beginning so readers read the rest in context: Canada's the Start-Up Visa Program has temporarily stopped accepting new applications as of January 1, 2026, and Canada plans to introduce another pilot programme for immigrant entrepreneurs whose conditions have not been announced. The analysis of this area below is therefore for model comparison purposes, not a guide for an application submitted today.

As the three models differ in their original principles, they cannot be directly converted to each other. A profile that is strong in one criterion may be weak in another. This is why any reconciliation based solely on capital numbers leads to misleading conclusions.

Comparing investment settlement programmes starts from the nature of the capital

The first question when comparing investment immigration programmes is not how much money, but in what form that money exists. There are three basic types: Capital at risk in a real business, capital invested in a business run by the investor, and passively held assets.

In EB-5, the capital must be put into the new commercial enterprise and must actually bear the business risk. This is not a deposit or a refundable deposit. The United States Citizenship and Immigration Services (USCIS) evaluates investments tied to the commitment to create jobs for US workers, and the capital requirements vary depending on whether the project is located inside or outside the target employment area (TEA).

In the Start-Up Visa Program, cash flow is not a central condition in the way that EB-5 is. The deciding factor is the business idea and whether the idea is approved for support by a designated Canadian organisation. In the European investment residency programme, the investment is often about holding assets, and is less tied to operations. These three structures create three completely different risk profiles, and readers need to verify the specific numbers with the correct regulatory agency.

Executive role: Capital contributor or business builder

The second criterion is often overlooked but determines the actual experience of the whole family for many years. It is the level of executive involvement that the programme requires or allows.

EB-5 allows investors to participate at different levels depending on the project structure, but the essence is still an investment relationship linked to job creation results. the Start-Up Visa Program go in the opposite direction: The programme is designed for entrepreneurs, meaning readers are expected to directly build and operate a business in Canada, not watch from the sidelines. European residency by investment schemes are at the other end of the spectrum, where the primary obligation is to maintain a qualifying investment.

This difference has direct consequences. An investor who is running a business in Vietnam and does not intend to change his entire career focus will encounter difficulties in the entrepreneurial model. Conversely, someone looking to build a new career in their home country may find that the passive model does not deliver what they are looking for.

Dependents and actual residency requirements

For most Vietnamese families, the decision to settle down is not a personal decision. The range of dependents included and the conditions for maintaining their status are highly weighted variables, sometimes greater than costs.

Each programme has its own definition of spouse and dependent children, with age limits and marital status requirements for the children. The point to note is that the application processing time may affect the child's eligibility as the child approaches the age threshold during the waiting process. This is a technical risk that is often underestimated and should be checked directly with the respective regulatory authority.

Physical presence requirements also vary significantly. Some routes require relatively continuous residence to maintain and renew status, others set much lower presence thresholds. When comparing investment settlement programmes, readers should convert this requirement into the actual number of days they have to leave work and family in Vietnam each year.

Roadmap to permanent residence and citizenship

A fundamental difference that popular comparison tables often blur: Does the programme lead directly to permanent residence, or only grant temporary residency and leave the following steps open.

EB-5 is in the US immigrant visa system, meaning the design destination is permanent residence, with conditions and deconditioning steps according to USCIS regulations. Canada's the Start-Up Visa Program is also a route towards permanent economic residency. Meanwhile, most European residence-by-investment programmes grant a residence permit for a limited period of time, and the transition to long-term permanent residence or naturalization depends on the host country's law, often with conditions on residence time, language and integration.

The gap between residence and citizenship is a gap of many years and many conditions. In Portugal, the relevant regulations are administered by the Immigration and Asylum Agency (AIMA) and are updated according to legislative changes. Readers should consider all information about the roadmap as subject to change, and verify at official sources before committing capital.

Risk of backlog of documents and time factor

Time is the variable most often treated without seriousness. Many investors plan based on the assumption that qualified applications will be processed within a predictable time frame. The reality is more complicated.

With EB-5, progress depends not only on the quality of the application but also on the backlog and availability of visas. The U.S. Department of State publishes a monthly Visa Bulletin, reflecting visa availability by category and by country of birth. This means that two applications that are identical in quality can still have different timelines simply because of the applicant's place of birth.

In Canada and Europe, the time factor takes on a different form. Policy changes, adjustments to qualifying investment portfolios, or regulatory reforms could all alter established expectations. The general lesson is that you should not base your child's financial plan or education plan on an assumed timeline. Build a plan that can tolerate delays.

It should be made clear that waiting time is not simply a delay, but a real risk. Children may exceed the age of dependency, regulations may be amended midway, and study or business plans may have to be redone from scratch. This cost does not appear on any quote, but is often the most expensive cost of the entire process.

Six criteria framework for readers to compare for themselves

Instead of finding a general answer, a more sustainable approach is to build a framework of criteria and then individually grade each programme according to its own circumstances. Below are six axes that we consider to be the minimum when comparing investment immigration programmes.

• Nature of the capital: Is the capital actually subject to business risks, or is it a held asset; What are the conditions for capital withdrawal and maintenance period?
• Executive role: Readers are capital contributors, or people who must directly build and operate a business in the host country.
• Dependent: Definition of spouse and dependent children, age limit, and risk of child exceeding the age threshold during the waiting period.
• Actual residence requirement: Minimum number of days of presence to maintain and renew status, converted to impact on current job.
• Pathway to permanent residence and citizenship: Program leading directly to permanent residence or only granting temporary residence, and conditions for the next steps.
• Backlog risks and policy changes: Dependence on quotas, backlog of documents, and the possibility of regulations being amended mid-stream.

When grading, readers should assign weights according to their own family's priorities. A family with children approaching the age of dependency will place very high weight on the time axis. An investor who is still attached to domestic business activities will place high weight on the axis of residency requirements and executive roles. There is no right set of weights for everyone.

The most common mistake is reducing everything to one number. When comparing the investment settlement programme using only the capital threshold, readers are juxtaposing two quantities that are not in the same unit: An amount of capital at risk in a business is not equivalent to an asset held, even if the nominal number is the same. The six-axis framework above exists precisely to avoid that foreshortening trap.

Conclusion: There is no general answer

The three programmes discussed here cannot be ranked as better or worse, because they answer three different questions. EB-5 is suitable for people who accept to put capital into the business at risk and accept time factors beyond their control. The Start-Up Visa Program is aimed at people who really want to build a business and have an idea that is convincing to a designated organisation — although as noted, this stream is currently closed to new applications. European residency by investment programmes are suitable for those who prioritize flexibility and low operational involvement.

The only common point is that every choice should start from the family situation, not from the product. When comparing investment settlement programmes, the right question is not which programme is best, but which programme is suitable for your family's asset structure, career role, age of children and ability to tolerate delays.

The final mistake to avoid is believing in intermediate information without checking the source. Immigration regulations change frequently and marketing materials are rarely kept up to date. For all the important numbers, including capital thresholds, job creation requirements, processing times, eligible portfolios, and fees, readers should check with the regulators themselves: USCIS for EB-5, the Government of Canada's portal for the Start-Up Visa Program, and AIMA for procedures in Portugal. All intermediate interpretations, including this article, are just maps, not topography.