October 2025 I-485 report and December 2025 Visa Bulletin

USCIS has published another pending I-485 inventory report as of October 2, 2025. The December 2025 Visa Bulletin is out, with forward movement for EB-5 Unreserved and no notes about forthcoming Reserved dates. Department of State continues to not publish monthly visa issuance reports, not publish the FY2026 visa limit, and not publish the NVC waitlist. What can we learn? I look for insights into what happened with EB-5 visa issuance in FY2025, and hints for Rural, High Unemployment, and Unreserved outlook this fiscal year.

Rural and HUA Visa Issuance in FY2025

Rural and High Unemployment visa issuance through adjustment of status in FY2025 looks higher than I expected. Drilling down to month-by-month changes in I-485 inventory reports throughout the year, it appears that over 600 HUA and over 1,200 Rural AOS visas could have been issued between October 3, 2024 and October 2, 2025. With these numbers in AOS alone, it’s possible that DOS ultimately managed to issue at least the 1,150 HUA and 2,300 Rural carryover visas available in FY2025. If so, that would mean no transfer of unused FY25 carryovers to Unreserved in FY26 (and no net loss to Reserved, since FY25’s new-issue Reserved visas stay with Reserved in FY26).

Comparing monthly I-485 inventory reports merely shows changes, which aren’t all caused by approvals/issued visas. But the pattern continues to suggest that AOS visa issuance is far from orderly by priority date, and that Indian applicants have enjoyed an outsize percentage of I-485 processing activity. (Thank you to the reader who sent me his spreadsheet with data from each monthly I-485 report entered in tandem, facilitating a more granular analysis than my previous bookend-month comparison approach.)  

Rural and HUA Visa Issuance in FY2026

It appears that the pace of Rural and High Unemployment visa issuance through consular processing must remain low in FY2026 to date. Considering the pace of I-526E approvals, there are probably 4,000+ Rural applicants and quite possibly 2,000+ High Unemployment applicants currently qualified and waiting for visas. But three months into FY2026, the Visa Bulletin is not yet warning about forthcoming Rural or HUA cut-off dates. I conclude that slow consulates have been organically controlling the crowd with low-volume interview scheduling, such that DOS currently still doubts the operational feasibility of issuing 2,000 HUA or 4,000 Rural visas this year. Slow-walking the Reserved visa backlogs is good for new U.S.-based investors who can keep using the concurrent filing window. It’s good for any salesmen who rely on lying that backlogs don’t exist until flagged in the Visa Bulletin. The consulate slow walk is bad for EB-5 investors abroad who fall behind U.S.-based applicants, and bad for wait times overall as the backlog can’t advance and dissipate on schedule.

Rural and HUA Demand Trends

Since I-485 are concurrently filed with I-526E, we can get a sense of recent I-526E trends by looking at priority dates in the I-485 inventory. No surprise, the numbers for July to September 2025 priority dates suggest that India-born Rural investors continue to drive U.S.-based EB-5 demand.   

India Unreserved Backlog and Outlook

When will pre-2022 India Unreserved applicants finish getting visas? People keep thinking “in about a year” because the Visa Bulletin has been a tease. The India Unreserved Final Action Date moved to 2020 two years ago, and to 2022 last year, only to retrogress back and forth. The history shows that one can’t look at any given final action date and conclude “everyone with priority dates within this final action date can expect to get visas shortly.”

The December 2025 Visa Bulletin moved the Indian Unreserved FAD to July 1, 2021. Does this now mean that all Indians with priority dates before July 2021 could get visas shortly? Consider that FY2026 has a minimum of 470 and possibly up to 600 visas for India Unreserved (with the upside depending on as-yet unknown rollover/carryover visas) — and this allocation has to cover consular processing as well as status adjustment. The October 2025 I-485 pending report shows 475 pending I-485 for Indians with pre-July 2021 priority dates. DOS hasn’t published a recent NVC wait list, but it’s likely not empty. (For the record, 2,019 India Unreserved applicants were reported registered at NVC as of May 2024, and likely <1,200 India Unreserved visas have been issued through consulates since May 2024.)

With over 700 Indians still waiting in the U.S. for Unreserved visas, the pre-RIA India backlog could hardly clear this year even if India Unreserved applicants abroad had disappeared. Considering backlog numbers I think it’s safe to expect that the India FAD will retrogress again to 2019 shortly (November 2019 is the major hurdle to pass), and not permanently progress past 2022 for another couple years. This is a controversial question — if you have a different take, please explain it!

China Unreserved

When will pre-RIA China Unreserved applicants finish getting visas? The December 2025 Visa Bulletin moved the China Unreserved Final Action Date to July 14, 2016 – a leap forward from last month, but only returning to where the Visa Bulletin was a year ago for China. The pending I-485 report does not add much insight for China, since most China-born applicants get visas through consular processing. I will copy in for reference the last available breakdown of NVC applicants awaiting consular processing (as of May 2024).

As illustrated, 2016 priority date are a crowd to work through. (And the table captured only the subset of applicants at NVC, not including applicants on I-485 or I-526 pending at USCIS.) I look forward to the publication of an updated NVC waitlist (which should be significantly reduced following FY25 visa issuance and DOS efforts to cull inactive applicants) and recent numbers for visa issuance in Guangzhou (which might be higher than expected, given Visa Bulletin movement). And I copy for reference my comparison of USCIS I-485 inventory reports for China Unreserved from the beginning and end of FY2025 (though I’m not sure what to conclude from it).

Rest of World Unreserved

For countries other than China and India, when will pre-2022 applicants finish getting Unreserved visas? And are new investors choosing to request Unreserved visas? The I-485 inventory reports reflect what happened with status adjustment in FY2025. As usual, I puzzle over the question of order, and why some recent priority dates leave the inventory while older applicants remain pending. I also notice a small but increasing trend of post-RIA priority dates in the Unreserved I-485 inventory. I assume that the trend reflects Rural and HUA investors who decide to bet that an Unreserved visa might get issued first, considering the Rural and HUA crowds and the low rate of Reserved visa issuance to date. (Or some ROW applicants may be kindly requesting Unreserved to leave space for more Chinese and Indian investors to share the small Rural and HUA allocation). I expect the trend of ROW applicants requesting Unreserved visas to continue to increase, especially once enough HUA I-526E get approved to trigger Visa Bulletin cut-off dates for all countries in HUA.

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