EB-5 Retrogression in April 2025 Visa Bulletin
March 10, 2025 21 Comments
The April 2025 Visa Bulletin has retrogressed the EB5 Unreserved Final Action Dates for China and India, and concludes with a note indicating that Rest of the World Unreserved may also get a final action date this year.
E. RETROGRESSION OF EMPLOYMENT-BASED FIFTH PREFERENCE (EB-5) UNRESERVED FINAL ACTION DATES FOR CHINA AND INDIA
Increased demand and number use by China and India in the EB-5 unreserved visa categories, combined with increased Rest of World demand and number use, made it necessary to retrogress the final action dates to hold number use within the maximum allowed under the FY-2025 annual limits. Please note that it may also become necessary to establish a final action date for Rest of World countries if demand and number use continues to increase. This situation will be continually monitored, and any necessary adjustments will be made accordingly.
I read this announcement as good news for Unreserved visa wait times overall, since it means that the process is working efficiently. When I expected the process to work inefficiently, I thought that USCIS would slow-walk rest-of-world petition processing and consulates would slow-walk visa issuance, with the result that the visa bulletin would not need to move to add an extra constraint. Now I see that the visa bulletin is having to jump for Unreserved, which tells me that DOS has apparently already efficiently issued most EB-5 Unreserved visas available this year to China and India, while USCIS and NVC are maximizing the number of Rest of World applicants able to claim visas. ROW could only reach a limit this year if DOS manages to issue more ROW EB-5 visas this year than it ever has in the past. The more ROW visas issued this year, the fewer ROW applicants left for next year, so maxing out ROW visas this year would be good for ROW. However, high ROW visa demand directly corresponds to limits on China, so Chinese EB-5 applicants may receive thousands fewer visas this year than I had hoped.
As a reminder, I have estimated at least 8,100 pre-RIA ROW applicants in the pipeline for EB-5 Unreserved visas. This is greater than the number of visas remaining to ROW in FY2025 (given the 11,470 Unreserved visas available in FY2025, of which China has already absorbed over 2,500 and India can claim 803 under country caps). The ROW queue for Unreserved visas may also be expanded by post-RIA ROW investors fleeing from High Unemployment and Rural backlogs. Though this flight may be reversed, if and when ROW Unreserved gets a final action date while set-aside categories remain “Current.” (For earlier predictions of future visa bulletin movement for China and India, calculated as a function of demand/supply balance, see the “Pre-RIA China” and “Pre-RIA India” tabs in the EB-5 Visa Supply and Demand Analysis workbook linked to the EB-5 Timing page. I may now need to revise the Pre-RIA China tab with a more pessimistic estimate based on assuming more ROW visas/fewer China visas in FY2025.)
The April 2025 Visa Bulletin does not include a corresponding note for the EB-5 Set Aside categories, which suggests that USCIS and DOS are not working as efficiently to advance and issue visas to the High Unemployment and Rural backlogs.
I look forward to what the next Chatting with Charlie webinar has to say about the April Visa Bulletin.
(In other news, the spending bill to fund the government past March 15 appears to be not, after all, a potential vehicle for a new “Gold Card” or EB-5 changes. The House Appropriations Committee released a draft of the The Full-Year Continuing Appropriations and Extensions Act, 2025 on Friday, emphasizing that it contains “no poison pills or unrelated riders – the bill is simple: extend funding and certainty for the nation.”)
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This is very sad. Anyone in unreserved EB5 from India for year 2022 would now be stuck for Visa many years to come, I was expecting unreserved EB5 for India would be current by next month.
The visa bulletin simply reflects supply and demand balance month-by-month, quarter-by-quarter, and year-by-year — it’s not a tool for long-term projection because it does not account for visa availability in future periods. For projection, it’s necessary to look at backlog numbers. But indeed, backlog numbers have suggested that 2022 India priority dates have many more years to wait for visa availability.
My PD is Sep-2019(Pre RIA Indian) waiting for consular visa interview at UAE since october-24. With FAD of Nov-2019, does that imply that my visa shall be issued by sep-2025?
I suggest you to consider moving your case to Mumbai. Mumbai is doing much better IMO.
This retrogression seems strange. Does it reflect the actual current demand-supply for China and India EB5 applicants? I found it hard to believe that the priority date would fall back to what it was 9 years ago. Is it rather just a way for the USCIS to prioritize processing other EB-5 categories?
I assume the China EB-5 Unreserved date must just mean that Department of State has decided to stop issuing China visas for the fiscal year, given the number already issued to China and rest of world demand. To effectively stop China visa issuance, they have to retrogress the FAD so far back in time that no applicants could qualify within that date. It doesn’t mean reverting to issuing visas to such old dates.
Thank you so much for your insight. That is reassuring to hear. My PD is Sept 26th, 2016. I feel it will take until the FY2027?
Will China’s priority date advance for this year?
this is unbelievable for priority date to retrogress for 2.5 years
China’s final action date will advance as soon as Department of State has more visas to issue to China. At latest, this will happen in October 2025 when FY2026 visas will become available. (In October 2025, I guess that the China FAD would move back to July 2016 to resume visa issuance.) The China FAD will only advance earlier if Rest of World claims fewer visas than anticipated this year. (China already got over 7% of FY2025 visas just in the first three months of FY2025. So for the remainder of FY2025, China can only count on picking up any visas left unused by rest of world. And the April visa bulletin is telling us that Department of State has a lot of ROW applicants — enough to take all visas available to ROW this year and leave nothing behind.)
India’s retrogression shook me hard. I thought we were almost there! We are PD Oct 2021 and waiting for the interview. How many Indians are yet to receive GC with PD Nov 2019? Will there be good progress when the new fiscal year starts since the number of applicants is less in 2020 and 2021?
See the Pre-RIA India tab in the EB-5 Visa Supply and Demand Analysis workbook on this page https://blog.lucidtext.com/eb-5-timing/. The tab compiles available data for the number of Indian applicants still in progress by priority date, and matches that demand with forthcoming visa supply to estimate timing.
Hello Suzanne, do you have any data for I-829 backlog and what is current PD? Thank you!
You can find I-829 info on the Processing Data page https://blog.lucidtext.com/processing-data/. Increasing I-829 adjudication volume means that processing times are falling. There’s a wide range of dates being adjudicated, but the median processing time is down to 17.1 months per USCIS report https://egov.uscis.gov/processing-times/historic-pt
Hi Suzanne Thank you very much! This data is very helpful as always. I noticed it’s up to September 2024. Do you have any updated data after that? Thanks!
hi Suzanne,
is it possible that some of the set aside visas will still rollover to unreserved visa pool in fy26?
Hi Suzanne,
Thank you for such helpful data and analysis as always. Could you please comment the Chart B trend in the coming months and in FY2026? Thanks!
Could you predict how many visas China will receive in FY2026? Thank you very much！
Hi Susan, I just finished uploading all my paperwork for the DS260 and realsied the india has retrogressed to nov 1 2019 in march. my pd is nov 12, 19. I wanted to know if i read your supply demand analysis correctly. are you saying that it is likely that i will get the visa only on FY 2028? I am Pre RIA. Did I get the reading right.
also what happes to aging out of kids during the times the visa queue is in retrogression after I 526 approval.
and my last question to you is do you think the final action dates of india will move from nov 1, 2019 soon ?
VP, My Excel file estimates that India-born applicants with priority dates in October 2019 to December 2019 will start getting visas in 2026 and finish getting visas in 2028. That calculation is based the number of people apparently in the queue with PD up through November 2019, and the number of annual visas available to India. I do not expect the visa bulletin date to move from November 1, 2019 soon, given that India has already (apparently, from the visa bulletin) maximized visa issuance in FY2025, and that there are likely over 800 Indian applicants with PD before October 1, 2019 still waiting, and likely just about 500 Unreserved visas available to India in FY2026. I will update my calculations when NVC finally publishes an updated wait list.
Confirm with your lawyer about the age-out question, but my understanding is that child age out is no longer a risk for your family. It’s my understanding that the age of your kids has been frozen since you completed your DS-260/paid the fee bill, because those actions count as “seeking to acquire” a visa.
See https://www.uscis.gov/policy-manual/volume-7-part-a-chapter-7
1. Satisfying the Sought to Acquire Requirement
An adjustment applicant may satisfy the sought to acquire requirement by any one of the following:
Properly filing an Application to Register Permanent Residence or Adjust Status (Form I-485);[41]
Submitting a completed Immigrant Visa Electronic Application (Form DS-260), Part I to the DOS;[42]
Paying the immigrant visa fee to DOS;[43]…
Dear Suzanne, Good Morning
Happy reading your blog, they are very useful and informative with figures.
we have priority date of 4 December 24, applied for EB5 site a side HU; my son age is 18 years and 7 Months, what are the probability for getting him the Green card ? can we do anything to expediate the case ? Indian born.
Hi Suzanne,
Thank you for your detailed information.
We have question on potential impact, if any, of priority date retrogression on travel to USA after the immigration visa issuance. We recently had successful EB5 immigration visa interview in Mar 2025, we received our passport back with the visa, and a note on it ‘ Upon endorsement serves as I-551’. Our priority date is Jun 2021 which was current during our interview in March 2025 but it retrogressed to Nov 2019 in April 2025. Since our priority date is not current as of now, we wanted to check if it may have any bearing at the port of entry especially on getting an endorsement on I-551.