EB-5 Visa Backlog and Outlook as of 2025

5/21/2025 UPDATE: Please see the new version of this post based on more recent data: EB-5 Visa Backlog and Outlook as of 2025 — UPDATED

–ORIGINAL POST–

The EB-5 “investor visa” program obviously depends on visas. It’s tough to get a handle on the EB-5 visa outlook, considering spotty data, moving parts, and disincentives to recognize a threat. I keep working on analysis, because it’s so practically important for EB-5 issuers and investors to assess the visa incentive. I keep hesitating to publish, because conclusions are controversial and tough to fully qualify. But EB-5 is in a visa crisis that keeps getting more severe, and too dangerous not to address as best we can.

I’ve now updated the EB-5 Timing Page by publishing the current fruit of my on-going labor – a detailed Excel model that carefully patches together available facts, adds assumptions step by step, and builds a responsive model for assessing current backlogs and visa wait times. This article gives the tip of the analysis iceberg. For full detail you can download the EB-5 Visa Supply and Demand Analysis Excel model and make your way through it, following the sources and formulas and adjusting assumptions as needed to reach your own conclusions.  As time permits, I may put up additional articles to discuss portions of the analysis in detail. And my paid timing consultations are now available again for those who’d like to discuss one-on-one.

EB-5 already has more pipeline visa applicants than annual visas in the Unreserved, High Unemployment, and Rural categories. This means retrogression coming in each category. I dare say that every analysis of available data leads to that general conclusion. The debatable question is who will be affected, when, and to what extent.

Table 1 gives an estimate of the total pipeline backlog going into 2025, while Table 2 gives the timing predictions that result from one detailed comparison of the existing backlog with forthcoming visa supply. As a base case, I populated the model with assumptions that I consider conservative, and erring on the side of optimism regarding processing speed and retention rates.

TABLE 1: Estimated EB-5 backlog size compared with supply as of FY25	China visa applicants (qualified or in the pipeline as of 10/2024)	India	Rest of World	Estimated total qualified plus pipeline visa applicants as of 10/2024	Compare visas available in FY2025	Compare annual visas available in FY2026 and beyond
Unreserved	33,300	3,200	8,100	44,600	11,470	6,800
Rural	3,900	1,050	1,275	6,225	4,427	2,000
High Unemployment	3,970	1,490	3,160	8,620	2,214	1,000
Infrastructure	?	?	?	?	443	200
Total	41,170	5,740	12,535	59,445	18,554	10,000

Key assumptions behind Table 1 estimates: an average 2-to-1 ratio of visas to I-526/I-526E filings for post-RIA investors (assuming average 2.5 family size and 80% approval rate), accurate NVC records for pre-RIA investors, and minimal visa-stage attrition. “Pipeline backlog” means qualified visa-stage applicants plus future visa applicants coming up from I-526/I-526E processing. Key data behind Table 1 estimate: NVC wait list as of May 2024, pending I-485 as of October 2024, pre-RIA I-526 pending as of July 2024, recent I-526 denial rates and family sizes, post-RIA I-526 and I-526E filed through September 2024, post-RIA filings by country and category through July 2024.

TABLE 2: EB-5 timing estimates	Who may get a visa in FY2025? (optimistic best-case scenario for China and India)	Estimate for when an investor with a 2025 priority date might expect a visa number in this category
Unreserved China	Priority dates up to September 2016 (best case for China assuming ROW visas are limited by processing constraints)	After 2033 (considering the existing pre-RIA backlog and assuming that ROW demand continues neither much higher nor much lower than in 2024)
Unreserved India	Priority dates up to July 2019 (assuming FIFO order)	After 2030 (considering existing pre-RIA backlog)
Unreserved ROW	Up to 9,800 applicants in theory, but likely about 4,000 due to processing constraints	After 2026 (considering existing pre-RIA backlog)
Rural China	Priority dates up to March 2024 (best case if maximum FY25 visas issued, and no visa bulletin limit until year-end)	2032 (assuming maximum FY25 visas issued, and that ROW demand continues as in 2024)
Rural India	Priority dates up to March 2024 (best case if maximum FY25 visas issued, and no visa bulletin limit until year-end)	2029 (assuming maximum FY25 visas issued, and that ROW demand continues as in 2024)
Rural ROW	Whichever priority dates can get processed in time to claim a FY25 visa	As soon as processing times permit
High Unemployment China	Priority dates up to April 2023 (Best case if maximum FY25 visas issued, and no visa bulletin limit until year-end. November 2022 would be worse case if ROW visas can be maximized.)	After 2033, when pre-RIA Unreserved backlog clears making Unreserved visas also available to post-RIA applicants (theoretical worst-case if HU investors limited to HU visas: 2102)
High Unemployment India	Priority dates up to April 2023 (Best case if maximum FY25 visas issued, and no visa bulletin limit until year-end. November 2022 would be worse case if ROW visas can be maximized.)	After 2030, when pre-RIA Unreserved backlog clears making Unreserved visas also available to post-RIA applicants (theoretical worst-case if HU investors limited to HU visas: 2053)
High Unemployment ROW	Priority dates up to May 2023 (Scenario if F25 visas are FIFO with no visa bulletin limit on China/India. January 2024 would be best case for ROW if swift processing allows maximizing ROW visas in FY25)	After 2026, when pre-RIA Unreserved backlog clears making Unreserved visas also available to post-RIA applicants (worst-case if limited to HU visas is 2030)
Infrastructure	Unknown	Unknown

Key assumptions behind Table 2 base estimates: That all available FY2025 visas will be issued, with no limits imposed yet on China or India Rural or High Unemployment in FY2025. (In the likely event that this optimistic assumption is not realized, worse visa wait times would result for China and India.) That the backlog entering FY2025 is as described in Table 1 (and as detailed by priority date in the supporting Excel). That new EB-5 demand in 2025 and future years will mirror the volume and TEA/category distribution of EB-5 demand in FY2024. (To the extent that this proves not true, actual wait times for China Unreserved, China Rural, and India Rural could be less than estimated in Table 2.) That qualified Rest-of-World High Unemployment and Rural applicants are likely to take High Unemployment and Rural visas at least in 2025 (considering that they are first-in-line for Rural and HU visas while thousands of earlier pre-RIA ROW applicants still stand in the way of access to an Unreserved visa), but that Rural and High Unemployment investors from all countries are likely to request/be assigned Unreserved visas as soon as the pre-RIA Unreserved visa backlog clears for their country. That visas are generally assigned in priority date order. (As discussed in the previous post, exceptions to this general rule mean that individual experience can turn out to be faster or more delayed than the average, even assuming that the times in Table 2 are on-target as averages.)

Table 3. Potential annual additions to the EB-5 pipeline backlog (if current/future years mirror the number of I-526/I-526E filings in FY2024)	China	India	ROW	Total estimated new pipeline visa applicants resulting from one year of investments (FY2024)	Compare annual visas available in FY2026 and beyond
Unreserved/Other	100	50	150	300	6,800
Rural	2,600	700	1,000	4,300	2,000
High Unemployment	2,200	800	1,800	4,800	1,000
Infrastructure	?	?	?	?	200
Total	4,900	1,550	2,950	9,400	10,000

Tables 1 and 3 highlight the basic EB-5 visa predicament: that we’re in a deep and rapidly deepening visa hole. EB-5 entered 2025 with about five times more pipeline visa applicants than base annual visas. 2024 alone brought in 2.3x as many Rural investors and nearly 5x as many High Unemployment investors as can reasonably get visas in a year with their families in a normal year under category limits.

Table 2 summarizes attempts to quantify when investors could dig out of that hole and secure visas. (See individual tabs in the Excel model for sources and derivations for the estimates in this table. And you can use the worksheets to try the effect of different assumptions.) 

Table 2 is a reminder that if something doesn’t give, the only new EB-5 investors in 2025 who can expect to get a green card this decade may be Unreserved and Rural investors from “Rest of World” countries, and possibly Rural investors from India. The supply/demand imbalance in High Unemployment is already large enough to create retrogression for applicants from every country in 2026 (or earlier if USCIS increases processing volume), and to measure theoretical wait times for China and India in lifetimes (though less in practice assuming Unreserved visas can be allocated to post-RIA investors as soon as the pre-RIA Unreserved backlog clears).

Could actual wait times be even worse than the Table 2 estimate? Theoretically yes, if low-volume I-526/I-526E processing continues to hinder visa issuance, if on-going Rest-of-World visa demand increased from 2024 levels, and if family sizes and/or approval rates beat historical averages.

Actual visa wait times could also turn out less than estimated in Table 2, so long as visa demand proves less or supply proves greater than modeled in the Excel workbook. Maybe thousands of the pre-RIA China and India applicants registered at the National Visa Center have withdrawn or will give up or get denied, thus hastening the day when post-RIA applicants can start to access Unreserved as well as set-aside visas. (Visa Bulletin dates may signal this possibility for India – I’ll be interested to see the forthcoming updated NVC waitlist.) Maybe recent applicants will prove to have a high rate of project and/or evolutionary failure, resulting in a visas-to-I-526E ratio of much less than 2.0 for Rural and High Unemployment. Maybe the EB-5 market will shortly collapse over uncertainty around visas, sustainment, and reauthorization, thus stemming the incoming tide of Rest-of-World demand that would otherwise limit future visa supply to China and India. Or maybe politicians will realize that they love the visa category that has given the U.S. innumerable jobs, measurable economic growth, and immigrants such as Elon Musk, and decide to allocate more visa numbers to EB-5.

As illustrated in Tables 1 and 3, stabilizing the EB-5 visa situation could require a one-time infusion of around 40,000 visas to clear the existing backlog, or alternatively about 2.3x more rural visas and 4.9x more high unemployment visas on an annual basis to support ongoing demand potential. There were just under 5,000 EB-5 investments made in 2024, which could be nearly sustainable for a program with 10,000 annual visas — if not for the EB-5 backlog blocking paths for new investors and blocking access to 68% of those visas.  Alternatively, wait times could stabilize at a tolerable level (for those few who can persist) if the EB-5 market contracts by at least half, and/or about half of past Unreserved and High Unemployment investors give up.

Something is certain to give, when theoretical wait times become intolerably long. Consider this exercise: “100 people arrive for breakfast at a restaurant that can serve 20 customers per hour. How long will customer #101 wait for breakfast?” The real-life answer is not “100/20=5 hours” but rather “however long she/others are willing to wait for breakfast before giving up and going to eat somewhere else.” Ideally the restaurant owner is smart enough to rustle up more staff and tables in time to accommodate the profitable crowd, and to avoid discouraging new customers.

In cell D42 of the HU tab of the model, you’ll find a formula 5,252/70=75. The China high unemployment pipeline backlog is on track to be 75x greater this year than annual HU visa supply under country caps. But of course, no Chinese HU investor will wait anywhere near 75 years for a visa. The gap between demand and supply will inevitably close somehow, to reduce wait times to tolerable levels. I sincerely hope that supply-side relief is what ultimately closes the gap, making many more visas available across categories such that HU investors from all countries can get timely access to a HU or Unreserved visa. But for now, please “mind the gap” or risk unexpected failure.

As time permits, I may write additional posts to discuss the methods and thinking baked into the Excel model behind this post, and to walk through using and modifying the model. As time permits, I may redo the model when Department of State publishes the November 2024 NVC Waitlist and the 2024 Report of the Visa Office, and as new processing reports from USCIS and DOS help clarify possible visa issuance this year. If you benefit from the considerable effort that I’ve put into this otherwise thankless analysis, please consider making a contribution to support the work. If you’d like to pay for a consultation to discuss the model and your EB-5/timing questions individually, please book a meeting here.

I would like to thank Lee Li of IIUSA, Connor Chen of EB5 Sir, and Joey Barnett and Charlie Oppenheim of WR Immigration for responding to my requests for advance review of this analysis. And I welcome any additional corrections and feedback to the EB-5 Visa Supply and Demand Analysis model. You can email me at suzanne@lucidtext.com.