How Are Jobs Calculated For EB-5?
- Nathan Patel
- Jul 23
- 4 min read
Breaking down the numbers behind your green card eligibility
At EB5-USA, we often say: the EB-5 program is about investment—but it's really about jobs. To qualify for a U.S. green card through the EB-5 Immigrant Investor Program, each investor must prove that their capital created at least 10 full-time U.S. jobs. But how are those jobs counted? And does every EB-5 project create jobs in the same way?
In this guide, we’ll explain how job creation is measured in EB-5, how different models apply, and what investors need to know to protect their green card.
1. The EB-5 Job Creation Requirement
Under U.S. immigration law, every EB-5 investor must show that their investment created 10 or more full-time positions for qualifying U.S. workers. These jobs must:
Be full-time (35+ hours/week)
Last for at least two years
Be based in the United States
But beyond this general rule, how those jobs are defined and counted depends on whether you invest through a Direct EB-5 project or a Regional Center.
2. Direct Jobs vs. Indirect Jobs vs. Induced Jobs
There are three main types of jobs in EB-5:
Direct Jobs
These are W-2 employees hired by the business receiving the EB-5 investment. For example, if you invest in a restaurant and that business hires 10 full-time staff, those are direct jobs.
Direct EB-5 projects can only count these.
Indirect Jobs
These are jobs created as a result of the project’s economic impact—such as construction suppliers, vendors, or nearby businesses benefiting from increased activity.
Regional Center projects capture indirect and direct jobs using economic models.
Induced Jobs
These come from new household spending—when workers spend their salaries locally (on groceries, entertainment, housing, etc.).
Also used in Regional Center projects, under certain conditions.
3. Direct EB-5 vs. Regional Center Projects
Your job calculation depends on your investment path:
Most investors today choose Regional Center projects because they allow more flexibility in how jobs are calculated and often include a “job creation buffer” (more on that soon).
4. How Are Jobs Counted in Regional Center Projects?
In Regional Center projects, job creation is modeled using government-approved economic analysis tools, like:
RIMS II (Regional Input-Output Modeling System)
IMPLAN (Impact Analysis for Planning)
REDYN (Regional Dynamic Modeling)
These models calculate how much economic activity (spending, construction, hiring) results from an investment and how many jobs that creates across the economy.
Example: A $100M hotel development may generate:
150 direct construction jobs
220 indirect supplier jobs
130 induced jobs from spending
Total: 500+ jobs → 50 EB-5 investors can be supported
5. Construction Jobs: Special Rules Apply
If a project is primarily construction-based, such as building a multifamily property or hospital, jobs can be counted, but only if:
The construction period lasts 2 years or more, OR
There’s a mix of construction and operations jobs
These jobs are often modeled, not directly hired. USCIS allows this as long as the methodology is valid and reviewed by a third-party economist.
6. Bridge Financing & Advanced Expenditures
What happens if a project starts before your investment goes in? That’s where bridge financing comes in.
If the project already began using temporary funds (like a short-term loan), and your EB-5 capital replaces that financing soon after, you can still get credit for the jobs created. This is common and acceptable—provided it’s documented properly.
7. What Changed Under the EB-5 Reform and Integrity Act (RIA)?
The RIA of 2022 introduced some limits:
Only 90% of total job creation can come from indirect jobs
At least 10% must be direct or W-2 jobs
USCIS now closely audits job methodology and economic assumptions
This means project sponsors must structure their job models carefully—and investors should always ask to see the economic impact report.
8. Why Job Buffers Matter
Let’s say you invest in a project that claims to create 10.1 jobs per investor. That’s cutting it close.
Most quality projects today include a job buffer—creating 30–50% more jobs than required. That way, even if economic conditions change (e.g., inflation, construction delays), your eligibility stays protected.
At EB5-USA, we typically only work with projects that provide a 130–150% job creation buffer per investor, based on third-party verified models.
Final Thoughts: Don’t Just Count Jobs. Protect Them.
Job creation isn’t just a number—it’s the foundation of your EB-5 green card. Whether you’re investing in a hotel, multifamily building, or infrastructure project, make sure:
✔ The job methodology is sound✔ There’s a clear economic impact report✔ A strong buffer exists✔ The Regional Center is experienced in handling USCIS scrutiny
"Too many investors focus on the dollar amount—but the real key to EB-5 is the job count. Understanding how jobs are modeled, buffered, and verified is the smartest way to protect your green card."
— Delo Baker, Managing Director, EB5-USA
If you’re not sure how your project calculates jobs—or how many jobs are really backing your investment—we can help you break it down.
Because your green card shouldn’t take a lifetime.
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