No. The qualifying capital amount is the investment itself; escrow charges, administrative or subscription fees, and professional costs sit on top of it. Ask which fees are payable at signing, which at release, and whether any are returned if the petition is withdrawn or denied. Get the answer in the documents, not in conversation.
Price the whole sequence, not the wire
Beyond the fees attached to the offering, budget for legal work on the petition, responses to any request for evidence, translations of financial records, medical examinations, and consular or adjustment steps for each family member. Government fees change over time, so verify current amounts close to filing. Keep a contingency for a second round of document gathering, which is common where source-of-funds records span several countries.
Build the budget as a sequence of payments with dates rather than a single figure. Escrow and administrative charges, subscription fees, legal work on the petition, translations of financial records spanning several countries, medical examinations, and the consular or adjustment steps for each family member all fall at different points. Ask which fees are payable at signing, which at release, and which are refundable if the petition is withdrawn or denied, and require the answer from the documents rather than from a conversation.
Add a contingency for a second round of document gathering, which is common where source-of-funds records reach back many years. Government charges change, so verify current amounts close to the filing date.