Australia's Significant Investor Visa is closed. Subclass 188C stopped accepting new applications on 31 July 2024, when Australia wound up its Business Innovation and Investment Program. The National Innovation visa that replaced it in December 2024 rewards demonstrated talent rather than capital, so no fixed sum buys a place. EB-5 stays open. Its price is $800,000 inside a Targeted Employment Area or $1,050,000 outside one, every investor must fund ten American jobs, and permanent residence covers the spouse and the children.
So the live comparison is between an American program you can still enter and an Australian one you cannot. The SIV is still worth setting out: existing 188C holders are deciding whether to add a US card on top, and the two designs price residence in opposite ways.
What the SIV asked for, and what it returned
AUD 5,000,000 was the entry price, held in a complying investment across the provisional period. Under the framework as it stood at the end, at least AUD 1,000,000 had to sit in venture capital and growth private equity funds. Another AUD 1,500,000 or more went into managed funds investing in emerging companies. The balancing investment of up to AUD 2,500,000 could spread across a wider set of permitted assets.
Physical presence was the selling point. A primary applicant needed roughly 40 days a year in Australia, averaged across the provisional visa, which is a fraction of what American permanent residence expects. Holders then applied for the subclass 888 permanent visa.
Nothing in the SIV required a single job to be created. Capital was the whole test.
Where the two programs actually differ
Price comes first. EB-5 asks $800,000 in a TEA against the SIV's AUD 5,000,000, a gap of several multiples at any exchange rate you care to use, and that gap ended the comparison quickly for most families.
Risk runs the other way. SIV money went into regulated, diversified funds where you kept ordinary market exposure. EB-5 capital usually goes into one project in one city, and 8 CFR 204.6 requires that capital to be genuinely at risk with no guaranteed repayment. Concentration is the price of the lower ticket. A project that stalls can take both your money and your green card, which is why the overview of investor visa options worldwide puts project selection ahead of program selection.
Returns differ as well. SIV investors earned whatever their funds earned. EB-5 investors typically receive a preferred return in the low single digits, and rural set-aside deals often pay close to nothing, because what you are really buying is the visa.
Then there is the job test. Ten full time positions per investor, proven on Form I-829 under 8 CFR 216.6, after two years of conditional residence. Australia never asked. A shortfall at that stage costs the green card even where the investor has done nothing wrong, which is why project selection dominates every other variable in this decision.
Citizenship: five years against four
Both roads reach a passport eventually. The American route requires five years as a permanent resident before filing Form N-400, with physical presence in the country for at least half that period, and the two conditional years count toward the total. Australia asks for four years of lawful residence including twelve months as a permanent resident.
Four beats five on paper. The catch is that the SIV's generous 40 day rule and the citizenship residence test pull in opposite directions, so an investor who used the concession to keep living in Shanghai or Jakarta stood nowhere near the four year threshold when the provisional period ended. Buying residence and earning citizenship were separate projects with separate bills.
EB-5 carries the same tension in milder form, since you have to genuinely live in the United States for the clock to run. Our comparison of EB-5 against the New Zealand investor visas shows how differently countries price that obligation.
Family members, and the children who age out
EB-5 covers the investor. A spouse and unmarried children under 21 travel on the same petition, while older children need a route of their own.
The Child Status Protection Act can subtract the time a petition spent pending from a child's age, which sometimes rescues a 21 or 22 year old. Do that calculation at the start of the process rather than the end. Concurrent filing is the other family advantage. An investor already lawfully inside the United States may file Form I-485 alongside the I-526E, provided a visa number is available for their country of birth, which puts work authorization and travel documents in a spouse's hands long before the petition is decided.
Tax is the real fork in the road
American citizenship and permanent residence both carry worldwide taxation regardless of where you actually live. The IRS rules on individual tax residency apply from the day of admission, and the substantial presence test catches many investors before they even hold a green card. Australia taxes its residents on worldwide income too, yet the obligation stops when residency stops.
Leaving is where the asymmetry bites. A long term US permanent resident who held the card in at least eight of the previous fifteen years can face expatriation tax on surrendering it. Nothing comparable applied to walking away from an Australian provisional visa. Model twenty years of tax before you pick a country, because the visa fee is the smallest number in that calculation by a wide margin.
If Australia was your first choice
Two lessons follow from the SIV's closure, plus one practical step.
Programs close without warning. Spain shut its golden visa, Australia shut the SIV, and the political reasoning in both capitals rhymed. Canada has form here as well, having suspended and reshaped its own investor routes more than once, as our comparison of EB-5 with the Quebec and start-up visa programs describes. Our page on why Spain ended its golden visa traces the same argument in Madrid.
Timing carries a price. Regional center authorization runs to 30 September 2027, petitions filed by 30 September 2026 are grandfathered against a lapse, and the first inflation adjustment to the $800,000 and $1,050,000 thresholds arrives on 1 January 2027. Treat an open window as finite, because Australia has just demonstrated what happens otherwise.
Check your own queue before anything else. Chargeability follows country of birth, and for investors born outside mainland China and India a visa is usually available without a long wait. Set-asides add further lanes, since rural projects hold 20 percent of the annual EB-5 visas and high unemployment areas hold 10 percent. Infrastructure takes another 2 percent. Current program mechanics are summarized on the USCIS EB-5 Immigrant Investor Program page.