IN THIS GUIDE · Interrogating the job-creation numbers behind an offering
Start with the EB-5 eligibility and application overview
Ten jobs per investor, counted a permitted way
Each investor must account for at least ten qualifying full-time positions. How they may be counted depends on the structure: a directly operated enterprise generally relies on actual employees, while a regional-center investment may use permitted indirect methods based on economic modelling. The two are not interchangeable, and a model's output is only as good as the expenditure and revenue assumptions feeding it. Establish which method applies here before reading any total.
Trace the total down to your own allocation
A project-wide figure means nothing until it is divided. Ask how many investors the offering will accept, how jobs are allocated among them, and what happens to allocation if the raise is only partly subscribed. Confirm whether the model counts construction expenditure, operating revenue, or both, and over what period. Then ask which parts of the budget are contracted and which remain estimates that a redesign could remove.
Capital and jobs are linked, but separate tests
As reviewed on 7 September 2026, the qualifying capital is US$1,050,000, or US$800,000 for investments qualifying as targeted employment area or infrastructure investments, with statutory adjustments beginning in 2027. Meeting the capital requirement does not answer the job question, and a strong job model does not cure a capital or source-of-funds problem. Keep the two analyses distinct so a weakness in one is not hidden by confidence in the other.
The proof lands years later
Job evidence matters most at the end, when conditions on residence are removed — a petition ordinarily filed in the ninety days before the second anniversary of conditional residence. Ask who will hold payroll records, expenditure verification and updated economic analysis at that point, and what the sponsor is contractually obliged to provide. A cushion described today is worth little if nobody is required to document the outcome later.
Ask what the cushion is made of and when it is spent
A generous-sounding jobs ratio is a fraction, and a fraction is only as reliable as the two numbers producing it. Take them one at a time. The numerator rests on assumptions — expenditure, timing, revenue, occupancy — each of which is a forecast rather than a fact, and several of which move together in the same direction when a project encounters difficulty. The denominator is the number of investors, which is not fixed either: a partially subscribed offering may fund a partially built project, and an expanded one needs a correspondingly larger total. Ask for the ratio recalculated under three states of the world: full subscription and the current budget, partial subscription with the corresponding reduction in spend, and a delay pushing a phase of expenditure beyond the period that matters. Then ask the separate question of how jobs are allocated among investors, since a total said to be sufficient in aggregate is not the same as a stated method attributing at least the required number to each. Keep in mind that the substantive requirement is proved years later, on evidence generated at the time rather than assembled at the end. Hypothetical example: an investor asked for those three recalculations and received two, and the sponsor's inability to produce the third became the most informative part of the diligence.
Sources reviewed 2026-09-07. This guide covers a preparation focus; it is not an individual eligibility assessment.