The apartment visa is priced in pesos. The dollar moved anyway.

Cancillería does not quote the investor-in-real-estate visa in dollars. Resolución 5477 de 2022, article 79, asks for a property titled only in your name worth at least 350 monthly legal minimum wages (SMLMV) on the filing date, plus Banco de la República registration of the foreign direct investment used to buy it.

The SMLMV is a government number. The dollar is a market number. They do not call each other.

I still see files built as if the TRM were 4,000 forever. That was a comfortable round figure in 2024. It is not how the visa, or the tax return, is measured.

The 23 percent jump in the 2026 minimum is the first squeeze. The second is the peso: fewer pesos per dollar means you need more dollars to reach the same peso floor.

If the TRM had stayed near 4,050, that 2026 floor would be about USD 151,000. The extra tens of thousands of dollars are the exchange rate, not a new visa category.

A unit that cleared 350 wages when you bought in 2024 may sit under the 2026 floor. You can often keep an M visa already granted if you still hold the investment the way article 79 requires. The next buyer cannot treat your 2024 price as their 2026 threshold.

The street board at the casa de cambio is not the TRM.

The Junta Directiva of the Banco de la República sets the rule in Resolución Externa 1 de 2018, article 40: an amount-weighted average of same-day (T+0) purchases and sales of US dollars for Colombian pesos, done by Intermediarios del Mercado Cambiario in the window BanRep fixes.

The Superintendencia Financiera de Colombia calculates and certifies that rate every business day, using BanRep's circular (DOAM-146 / the old DODM-146). In plain terms: interbank and similar trades between about 7:30 a.m. and 1:00 p.m., with other SFC-supervised entities and the Nación–Ministerio de Hacienda. Derivatives are out. Your Western Union receipt is out.

The figure certified from today's trades is the TRM for the next day. Weekends and Colombian holidays keep the last certified rate. If Superfinanciera cannot compute it, the last certified TRM stays.

Annual averages for 2024 (about $4,071) and 2025 (about $4,053) come from that daily series. 2026 has no full-year average yet. BanRep's end-June 2026 observation was $3,443.59. Late August sat near $3,200. Use a dated TRM when you run the numbers. Do not freeze 4,000 in a spreadsheet and call it law.

Two clocks start on the deed.

Visa clock. A later M-investor application has to show you kept the investment or the property for the whole term of the previous visa (article 79). Selling to take a dollar profit can end that path. That is a Cancillería problem, not a DIAN problem.

Tax clock. Estatuto Tributario article 300: if the property was a fixed asset (activo fijo) held for two years or more, the profit is ganancia ocasional (occasional gain). If you sell even a few days short of two years, the same peso profit is ordinary income (renta).

DIAN does not tax your dollar P&L. It taxes sale price in pesos minus fiscal cost in pesos. A strong peso can make the sale look fat in USD while the tax base is still Colombian.

The notary withholds 1 percent of the sale price (article 398) as an advance. That is not the final tax.

National-source gain on Colombian real estate is taxable whether or not you are a tax resident. Non-residents generally do not get the casa de habitación exemption in article 311-1. Residents who sell their actual home may exempt the first 5,000 UVT of qualifying gain (UVT 2026: $52,374; 5,000 UVT = $261,870,000) if they meet the statute's conditions on where the money goes. A pied-à-terre you rent on Airbnb is a weak candidate for that exemption.

A sale of registered foreign investment also has Banco de la República / DIAN paperwork. Treat that as part of closing, not an afterthought.

Hypothetical. Not a client file.

You deeded a Medellín apartment on 15 January 2024 for COP 500 million (above the 2024 350-wage floor of 455 million). No improvements in the example. You sell for COP 620 million. Fiscal cost stays 500 million. Peso profit: 120 million.

A. Deed of sale 20 January 2026 (two years and five days).
Fixed asset, two years or more → ganancia ocasional. Ley 2277 de 2022 put the general rate at 15 percent for residents and non-residents (articles 313–314 and 316). Tax: COP 18 million. Notary withholding: 1% of 620 million = COP 6.2 million, credited against the 18 million when you file.

B. Deed of sale 10 January 2026 (five days short).
Same 120 million is ordinary income. A non-resident natural person faces the general non-resident rate on that Colombian-source income (35 percent under article 247, unless a treaty says otherwise): COP 42 million. A tax resident stacks it in the ordinary schedule, which can run up to 39 percent. The 1 percent withholding is still only 6.2 million. The rest is due on the return.

The two-year line, in this cartoon, is about COP 24 million of tax. It is also the line between a 15 percent bucket and a progressive or 35 percent bucket.

USD aside, at TRM $3,203 the 620 million sale is about USD 194,000. At your old 4,000 budget, 500 million was USD 125,000. The peso revaluation inflates the dollar headline. DIAN still wants 15 or 35 percent of 120 million pesos, not of your Wise balance.

If you sell at 500 million (no peso gain), Colombian occasional-gain tax on the property is zero even if the stronger peso gives you more dollars than in 2024. The visa floor for the buyer is still 612.8 million in 2026.

Informational. Colombian rules move: minimum wage, TRM, and the Estatuto Tributario. Your deed date, fiscal cost, tax residence, treaties, and whether the unit is inventory or a home all change the result. Confirm the current text of Resolución 5477, the decrees on SMLMV, BanRep's TRM circular, and the ET articles above for your facts.

If you need a written legal concept on a purchase or a sale, we start with a 45-minute consultation (USD 55, Google Meet). The Concepto Jurídico and a quote follow within three business days.