I-485 processing to September 2025

The November 2025 visa bulletin is out, with no changes to EB-5 dates and no warnings about future retrogression. We don’t know yet what’s happening with consular processing, since monthly visa issuance reports still haven’t been updated since May, but USCIS just published a report of I-485 pending as of September 2025.

Comparing the I-485 pending inventory as of September 2025 with the inventory as of October 2024 gives a hint at the volume and distribution of status adjustment visas issued in FY2025. Only a rough hint, since new receipts and denials also contribute to inventory change, the comparison misses change in intermediate months, and numbers <11 are redacted. But inventory report comparisons at least give some window into visa processing.

Looking at the I-485 inventory report comparisons for High Unemployment and Rural, I’m struck by the low volumes overall, exceptions to FIFO order, and timing differences by country. A wide range of priority date months show a handful of applicants disappear while dozens of others with the same PD remain pending. The lack of visa FIFO presumably originates in non-FIFO I-526/I-526E processing, since I-485 can’t be decided until the I-526/I-526E is approved or denied. I see that India-born applicants have lead the way both in terms of volume and dates for I-485 inventory changes. I assume this is because Indians have been most aggressive with I-526 mandamus actions. But volumes have been so low overall. I assume that the distribution of I-485 decisions will tighten as I-526/I-526E adjudication volumes increase.

For Unreserved, I’m particularly interested to notice a significant number of post-RIA Unreserved applicants. I doubt that many people have invested at the $1.05 million level, so assume that many/most of these post-2022 Unreserved applicants represent Rural or High Unemployment investors who chose to request Unreserved visas. I also note the number of India Unreserved I-485 pending as of September 2025. One would think, looking at the Visa Bulletin alone, that the India Unreserved backlog is on track to clear out this year. That seems less likely when one considers over 600 India Unreserved I-485 still pending as of September 2025, not to mention however many India-born applicants are still registered with NVC for consular processing.

Do you benefit from this analysis? Consider supporting all the work it requires by making a contribution to the blog.