New I-526E Data to January 2025
April 28, 2025 10 Comments
And now, we finally know what’s been happening with EB-5 demand and I-526/I-526E adjudications since mid 2024. See AIIA FOIA Series: Updated I-526E Inventory Statistics for January 2025. Thank you to AIIA, Galati Law, and the Freedom of Information Act! USCIS has not published any EB-5 data since September 2024, so we welcome this trove of new information about I-526 and I-526E receipts, approvals, and denials by country and TEA category through January 2025.
I will shortly revise my backlog analysis to incorporate this new information. My previous analysis made optimistic wait time estimates based on optimistic assumptions: that future EB-5 demand would remain at the level documented as of mid 2024, and that USCIS and Department of State processing would allow issuing available visas. My revised analysis must now downgrade these estimates. We now know that in fact, EB-5 demand shot up through the beginning of 2025, while processing volumes remained quite low.
The AIIA FOIA showed that “only 351 HUA and 1,126 rural petitions have been approved as of January 2025.” That’s likely too low for a year with 2,200 HUA and 4,400 rural visas available, and considering that visa interviews take months to schedule. If there aren’t enough applicants to claim available FY2025 set-aside visas, that means that the visa bulletin gets to stay “current” for a longer time (good news for concurrent filing), but some set-aside numbers will be permanently lost, Rest of World applicants will get more time to accumulate and crowd out China/India applicants, and expected visa wait times will lengthen.
Meanwhile, the AIIA FOIA showed the count of filed investor petitions reaching 5,191 High Unemployment and 4,329 Rural by the end of January 2025. That’s conservatively 10-11x annual HU visa availability and 4-5x annual Rural visa availability (considering that these investors may get I-526E approval and be joined by spouses and/or children to claim visas). Those are fearsome queues to enter the back of, for a new investor today. If a 2025 High Unemployment investor gets a visa in less than 10 years or a Rural investor gets a visa in less than 5 years, it will be thanks to country caps (allowing minority country investors to move ahead of earlier priority dates from China and India) and the possibility of category-switching (with Unreserved being an alternate lane as congestion builds in the TEA lanes.) I’m now anxious to get updated information on the pre-RIA backlog for Unreserved visas, to better assess Unreserved visas as a potential fallback for new HU and Rural investors.
Regional Centers will want to grapple with the fact that the coming 10+ years of HU visas and 4+ years of Rural visas have already been sold, even as a significant Unreserved backlog remains. Unless and until visa relief is possible, what’s left to offer is a chance for Rest-of-World EB-5 investors to cut the queue in front of earlier but cap-limited China-born and India-born investors. Keeping the “immigrant” in “immigrant investment” will require hard work for visa relief.
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For ROW investors, the size of this 10 year backlog in HUA will depend on what percentage of investors are from country-capped areas… correct? Is there data on the origin of investors? Say I’m thinking if 50% are ROW then assuming no country inside the ROW gets country-capped, it is still approximately a huge 5 year backlog (minus unreserved when those become available, plus 7%*2 of the 2 country capped places, plus visa wastages at the end of the fiscal year, etc)
Yes, the AIIA data is broken down by country. There are 1,928 ROW HUA investors as of January 2025, which could translate into 4,000+ ROW HUA applicants. That would mean a 4.5-year backlog for ROW in the HUA category, if ROW HUA investors stay in their lane to take HUA visas. However, the pre-RIA ROW Unreserved backlog should be clear in 2026 or 2027. So I assume that any ROW HUA investor today will end up requesting an Unreserved visa as the fastest option.
Thanks for the response! In practice, does that mean sometime in 2026 or 2027, it is somewhat likely we will see visa bulletins where the action dates will reflect a backlog in ROW HUA, with priority dates earlier (longer wait) than ROW unreserved?
Yes, ROW HUA final action dates are certain — unless and until the 4,000+ HUA ROW pipeline applicants decide to compete for one of 5,000+ annual Unreserved visa slots theoretically open to ROW, rather than one of <1,000 annual HUA slots. The Unreserved lane is crowded too at the moment, including with ROW, but should clear in in the next year or so. Having 6x more visas than HUA makes a difference.
how about ROW rural, would it be possible at some point in near future, there would be a backlog for ROW so some ROW applicants would switch to the unreserved queue? also, if that happens, would even some existing ROW rural investor(with 2024 or early 2025 PD) switch to get a visa earlier?
Hi Suzanne,
Thanks for the article. Do you predict that chart B will advance and if so, how much?
Edit: I meant: will chart B advance for Chinese investor at the beginning of the new fiscal year (ie. Oct 2025)? And if so, how much?
What does this mean for folks (from India) who have an approved i526e in a Rural Project? We got our 526e approved in Jan’25 and are waiting on the i485 to be adjudicated.
Hi Suzanne , great analysis,as always.
What does this mean for the Indian Pre- RIA investor with approved I-526 with priority date of October 2019 who has filed for Adjustment of Status? When can he expect the green card?
Thank you
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