The published terms include unmarried children under 21, each with a separate gift and fee. Whether any age-protection rule applies to this program must be confirmed on the official page; if not, she may need her own application or a student status before turning 21.
Plan for the birthday rather than assume protection
The official FAQ, as checked on September 7, 2026, describes the individual Gold Card as covering the principal, a spouse and unmarried children under 21, with the processing fee per applicant and a gift per person. The daughter is within that definition today. The risk is timing: the vetting, the gift and then adjustment of status each take time, none of it guaranteed, and if she reaches 21 before residence is granted her eligibility as a child could lapse.
The Child Status Protection Act freezes or adjusts a child’s age for petition-based immigrant categories, but the Gold Card is an executive program, and whether a comparable protection applies should be confirmed with the official page and USCIS guidance rather than assumed. The prudent plan is to start promptly, and to prepare a fallback: if the process will not finish in time, the daughter could seek F-1 student status for her university studies, which she can hold independently, or the family could examine whether she can apply as a Gold Card principal in her own right, with the cost that entails.