The United Kingdom no longer sells residence for passive capital. Its Tier 1 (Investor) visa, the old two million pound route, closed to new applicants in February 2022 and was never replaced, so anyone who wants a UK immigration outcome today has to build a business through the Innovator Founder route and convince an approved endorsing body that the idea is genuinely new and the plan is viable. EB-5 asks for something different: $800,000 in a Targeted Employment Area or $1,050,000 outside one, plus 10 full-time American jobs. Nothing in it requires you to manage a business day to day. These are two products aimed at two very different people.
What the UK actually offers an investor now
Innovator Founder replaced the earlier Innovator and Start-up categories in April 2023. There is no fixed capital minimum, which sounds generous until you read what stands in its place. An endorsing body assesses your business, confirms that innovation sits at the core of it, and then stays involved through checkpoint reviews while you hold the visa.
The visa runs for three years and can lead to settlement, although the UK has been consulting on longer qualifying periods for permanent status, so anyone planning around a fixed number of years should check the rules in force rather than an old article. English at CEFR level B2 is required. A maintenance funds test applies as well.
Passive money buys nothing there. You could fund a British company with five million pounds and still be refused because a committee was unconvinced by the plan.
EB-5 in one paragraph, for comparison
The USCIS page for the EB-5 Immigrant Investor Program sets out the bargain. Invest $800,000 in a project inside a Targeted Employment Area, or $1,050,000 outside one. Prove the money was lawfully earned. Create or preserve 10 full-time jobs for qualifying US workers. Most people go through a regional center and file a Form I-526E petition, taking a limited partner position with no operational duty attached. Approval brings two years of conditional residence for the investor and for a spouse and unmarried children under 21.
No English test. No age limit. No business plan you personally have to execute.
Money: a fixed price against an open question
EB-5 gives you a number before you commit. Eight hundred thousand dollars into the enterprise, plus an administrative fee that commonly runs into the five figures, plus legal costs. That capital is genuinely at risk and can be lost, which is a real hazard rather than a paperwork formality, but the size of the check is knowable in advance.
Innovator Founder gives you no number at all. The Home Office removed the old fifty thousand pound threshold, and the endorsing body now decides whether your funding is adequate for the plan you brought it. A software business might be endorsed on modest capital. A manufacturing plan might need several million pounds and still fail on the innovation test.
One cost the comparison usually misses is the founder's own time. Running a British company for three years while an endorsing body reviews it twice is a full occupation with an opportunity cost attached. EB-5 asks for a wire transfer and a very thorough document file.
Job creation versus endorsement
American job creation is arithmetic. Ten jobs per investor, counted directly in a direct investment or through an economic input-output model in a regional center project, with the methodology described in Volume 6, Part G of the USCIS Policy Manual. Construction expenditure and operating revenue both feed the model. You either reach the number or you do not.
UK endorsement is judgement. A panel decides whether your business counts as innovative, and reasonable people disagree about that constantly. Challenging a negative endorsement decision is not straightforward.
Which standard suits you has as much to do with temperament as with money. An operator with a genuinely novel product may find the UK route quicker and far cheaper. A retiree or a passive family office investor will get nowhere with an endorsing body. So will a founder whose business is excellent yet entirely unremarkable, and EB-5 would take all of them without a second glance.
How long until you can stop worrying?
Neither answer is short. EB-5 timing is dominated by USCIS adjudication and, for investors born in mainland China or India, by visa backlogs that can add years to the wait. The rural set-aside of 20 percent of annual EB-5 visas carries statutory priority processing and, so far, much shorter queues, which explains why rural projects have absorbed so much demand since the 2022 reform.
UK settlement has historically been available after three years on Innovator Founder for founders whose business met the additional criteria, and after five years otherwise. That qualifying period is under active review.
A green card also carries a maintenance burden the UK route does not impose in the same way. You have to actually live in the United States, or at least keep a genuine home there. Long absences put the status in danger.
Family, tax and the things nobody quotes you
EB-5 covers a family in one filing. A spouse and unmarried children under 21 are included in the single $800,000 investment, which is why a family with two or three teenagers often finds EB-5 cheaper per head than any European golden visa ever was. Our page on EB-5 for multiple family members works through the age-out arithmetic, which is where these plans most often go wrong.
Tax is where the two routes diverge hardest. A US permanent resident is taxed on worldwide income from the day the status begins, and the IRS guidance on determining tax residency status deserves a careful read before the visa interview rather than after it. British tax residence turns on days present under the statutory residence test, and the UK has moved away from its old domicile based system toward a residence based one.
Model this properly with a cross-border adviser. Over a decade the tax difference can dwarf the visa cost.
Which one suits which person
Choose EB-5 if you want permanent residence for a whole family and can commit $800,000 you could genuinely afford to lose. It suits people with no appetite for running a company in an unfamiliar market, and it suits anyone whose children are approaching 21 and who cannot wait for a business to prove itself.
Choose the UK if you are a founder with a defensible product and would rather be in London than Miami. You will be judged on the idea. The balance in your bank account matters far less than the plan behind it.
One wrinkle worth knowing: British citizens qualify for the US E-2 treaty investor visa, which is much cheaper than EB-5 and can be running within months, though it never turns into a green card by itself. Our comparison of EB-5 against the E-2 treaty investor visa explains why so many families use E-2 as a bridge and then file EB-5 later.
Anyone still weighing several countries at once should read our overview of global investor visa options alongside the case of Spain and its closed golden visa. The steady closure of European programs since 2022 is the strongest practical argument for using a route while it still exists.