EB-5 processing volumes fall in USCIS FY2025 Q1 data report
April 30, 2025 5 Comments
And now, the USCIS Immigration and Citizenship Data page has finally published performance data for the first quarter of FY2025 (October to December 2024). The data shows a strong start to implementing the new administration’s immigration agenda. Last time around, it took two years for USCIS staffing and policy changes to translate into sluggish EB-5 form processing. This time, IPO preemptively cut its processing productivity in half even before the inauguration. Maybe October to December was an aberration, with no political connection and no trend to worry about. But at least for the one quarter, every EB-5 form suffered. I had expected USCIS to start shifting more resources to I-526E, given the visa urgency and dwindling I-526 workload, but this did not happen through the end of last year. Meanwhile, as previewed in AIIA’s data by country and TEA category, I-526E filings continued to shoot up through the end of 2024.




The FY2025 Q1 report is notable for including, for the first time, median processing times for post-RIA I-526 and I-526E.

Be cautious in interpreting the Processing Time number, which is not necessarily predictive! Footnote 6 to the Processing Times column explains: “Processing times are defined as the number of months it took for an application, petition, or request to be processed from receipt to completion in a given time period. The number of months presented is the median which is the time it took to complete 50% of all the cases processed in the quarter.” I’m very happy for the 50% of recently-completed I-526E that experienced a processing time of less than 12 months. However, 50% of the 202 completions in FY25 Q1 is just 101 forms — barely 1% of the inventory. How long will it take to process the 6,922 I-526E that remained pending at the end of last quarter? If USCIS kept going at the FY25 Q1 processing pace, then it would take 6,922/202=34 quarters=8.6 years. In order to get through the pre-2025 I-526E inventory in 12 months from now, USCIS would have to increase quarterly I-526E processing volume to 6,922/4=1,730 completions. On the other hand, the reported median processing time of 19.2 months for I-829 may be reasonably predictive, so long as USCIS can keep processing the I-829 inventory (7,553 at last count) at a rate of at least 1,000 completions per quarter.
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The premise that the slow down is due to the new administration has NO base on reality.
Trump was voted mid November, that is, mid quarter. Seeing the productivity trend it would mean that IPO put down their pencils immediately after the election and processed nothing else.
Indeed, as I tried to emphasize in the post, the slowdown happened before the new administration even started. I wish I knew the full story behind it! If only the dip just means a Thanksgiving and Christmas well celebrated, to be followed by a flurry of renewed activity in 2025.
Ugh whats the point of this metric…?
We have to make as guesstimate regarding the number of I526Es that are not processable by USCIS. This could be primarily on account of 2 reasons.
1. Partial investment cases where the I 526Es have been filed, typically with a 6 – 12 month period declared in the petition for completion of the investment. Such cases would be parked off lane till the investment deadline mentioned has passed.
2. We are seeing high demand continuing from new EB5 investors. So obviously there needs to be a commensurate supply of RC projects. Looking at the pending approval 956F inventory in conjunction with the median processing time of 8.5 months, it would be a sad but realistic assumption that many investors with pending I 526E petitions are stuck in this off lane as well.
This would impact different investors differently as the earlier investors may not face as much of a visa number crunch due to high RoW demand, which has picked up significantly post March 24, to my understanding, and may be subject to the above factors.
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