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Analysis

Four routes, eighteen attributes, one table

The differences that matter are rarely the headline thresholds. They are the ongoing obligations, the rejection risk and how much of the capital you can ever get back.

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AttributeTechnology & InnovationR$150,000Business InvestmentR$500,000Executive / DirectorR$600,000Real EstateR$1,000,000
Minimum qualifying capitalCapitalR$150,000R$500,000R$600,000 per executive, or R$150,000 with a job commitmentR$1,000,000 — R$700,000 in the North and Northeast
Legal basisCapitalResolução Normativa CNIg nº 13/2017, art. 3Resolução Normativa CNIg nº 13/2017Resolução Normativa CNIg nº 11/2017Resolução Normativa CNIg nº 36/2018
Form the capital takesCapitalPaid-in capital plus an innovation planPaid-in capital of a Brazilian LTDAPaid-in capital of the Brazilian entity that appoints youRegistered urban property in your name
Is the investment recoverableCapitalPartly — recoverable only through the businessPartly — recoverable only through the businessPartly — through the entity, not personallyYes — an asset that can be sold, subject to capital gains
Capital maintenance periodObligationsTwo to three yearsTwo to three yearsFor the duration of the appointmentNo fixed period, but disposal before naturalisation invites review
Aggregation of multiple assetsCapitalSingle entitySingle entitySingle entityPermitted across several registered properties
Typical total timelineProcess11–14 months10–13 months9–12 months8–11 months
Business plan requiredProcessYes, an innovation plan assessed closelyYes, assessed on substanceYes, where the R$150,000 job-commitment variant is usedNo
Job creation expectationObligationsNot fixed; substance of the venture governsApproximately ten roles, applied flexiblyTen roles within two years on the R$150,000 variantNone
Ongoing accounting burdenObligationsHigh — plus reporting against the innovation planHigh — payroll, monthly filings, annual accountsHigh — corporate filings and payroll for the entityLow — IPTU, condominium, annual declaration
Physical presence required to qualifyProcessBiometrics in person, plus credible active managementBiometrics in person; director acts may require attendanceGenuine and exercised presence in the roleBiometrics in person; the rest can proceed by power of attorney
Family inclusionProcessSpouse and dependants includedSpouse and dependants includedSpouse and dependants includedSpouse and dependants included on the principal application
Rejection riskRiskHighest of the four routesModerate — plan substance is the usual failure pointModerate — the appointment must be genuineLow, where title and funds are clean
Most common failure modeRiskNo demonstrable innovation, or absentee managementA plan that reads as a residency vehicle rather than a businessA nominal appointment with no exercised authorityRegistration not completed, or a defective matrícula
Sensitivity to source-of-funds scrutinyRiskHigh — smaller sums attract closer questioning, not lessHigh — capital registration is examinedHigh — corporate and personal chains must both holdHigh — the notary and the registry both examine the chain
Suits the applicant whoProcessIs building a genuine technology venture at low costIntends to trade in Brazil and employ peopleIs being posted or appointed by an existing groupWants an asset, not an operation
Path to naturalisationObligationsFour years of permanent residencyFour years of permanent residencyFour years of permanent residencyFour years of permanent residency
Language requirement to enterProcessNone to enter; Portuguese required at naturalisationNone to enter; Portuguese required at naturalisationNone to enter; Portuguese required at naturalisationNone to enter; Portuguese required at naturalisation