Tracking Job Creation in EB-5 Projects: A Complete Investor’s Guide

The EB-5 Immigrant Investor Program provides a route to U.S. permanent residency by allowing international investors to contribute capital that spurs job creation for U.S. workers. But the engine powering the whole system is job creation—and investors must understand not only how projected jobs are measured, but how they are ultimately verified and challenged.

Below is a deeper dive into how job creation is estimated, documented, and scrutinized in EB-5 projects.

Why Job Creation Matters in EB-5

● Under EB-5 rules, each investor must show that the capital investment leads to at least 10 new full-time jobs for qualifying U.S. workers. These jobs must be sustained for a minimum of two years.

● The initial estimate of job creation is part of the I-526E (or I-526) petition, meant to show that the project meets EB-5 standards.

●  Later, at the I-829 (removal of conditions) stage, investors must provide proof that the required jobs were in fact created and sustained.

●Thus, job creation is not a secondary or promotional metric—it is the requirement that links the investment to immigration eligibility.

Direct, Indirect & Induced Jobs: The Categories That Count

Projects (especially those through regional centers) often rely on a mix of job types. But it’s essential to know which ones USCIS allows and how they are defined.

1. Direct jobs:

● These are jobs employed directly within the EB-5 project’s enterprise or its subsidiaries. They appear on payrolls or employment records.

● Easiest to document and verify using payroll, W-2s, tax records, etc.

2. Indirect jobs:

●Jobs created in the supply chain or supporting industries—e.g. vendors, materials suppliers, subcontractors.

● These require estimation via economic modeling because they are not directly employed by the project.

3. Induced jobs:

● Jobs resulting from the increased spending of workers employed by the project (e.g. retail, services).

●  Also estimated via modeling; shows the ripple effect of wages spent in the local economy.

In a direct investment EB-5 (not via regional center), only direct jobs may be credited. Meanwhile, regional center projects may incorporate indirect and induced jobs via accepted economic models.

USCIS allows reasonable methodologies such as multiplier tables, feasibility studies, or input-output models to estimate indirect/induced job creation

Economic Models: Estimating Indirect & Induced Jobs

Because indirect and induced jobs don’t appear on payroll records of the project, economists use input-output models to estimate them. Two of the most widely used are IMPLAN and RIMS II. 

● IMPLAN (Impact Analysis for Planning): A private modeling system with detailed multipliers. It draws on industry data, regional demographics, and household spending profiles to simulate ripple effects. It produces separate estimates for direct, indirect, and induced impacts.

●  RIMS II (Regional Input-Output Modeling System): Developed by the U.S. Bureau of Economic Analysis, RIMS II uses standardized multipliers to estimate how spending in one sector affects jobs in the region. It is less customizable than IMPLAN, but is accepted by USCIS and is often used for simpler capital structures.

Selecting and Applying Models

●  The input assumptions must be conservative, transparent, and regionally appropriate.

●  After the EB-5 Reform & Integrity Act (RIA) 2022, new rules govern how many indirect/induced jobs can count. 

○  Indirect + induced jobs may not exceed 90% of total jobs (i.e. direct jobs must constitute at least 10%).

○  For projects with construction periods under 24 months, only up to 75% of the job requirement may be satisfied via indirect/induced jobs.

○  Direct construction jobs in that case may need adjustment in proportion to the actual duration relative to a full 24 months.

Verifying Job Creation at the I-829 Stage

Estimations matter early, but actual job formation is what counts later. At the I-829 stage, USCIS expects documentary evidence that matches or supports the initial projections.

Common forms of evidence include:

●  Payroll and tax records, employment verification, W-2s, 1099s

●  Bank statements and capital deployment records showing funds were used

● Construction invoices, budgets, and contracts

● Operational records, revenue statements, expense ledgers

● Business activity documentation (leases, vendor contracts, utility bills, etc.)

If job creation falls short of the projections, USCIS may issue a Request for Evidence (RFE) or possibly deny the petition. Thus many projects include a job buffer—i.e. planning to create more than the minimum 10 jobs per investor to allow for shortfalls or attrition.

Key Takeaways for EB-5 Investors

● EB-5 approval depends on verifiable job creation—10 full-time U.S. positions per investor.

● Regional center projects can count indirect and induced jobs if modeled correctly.

● IMPLAN and RIMS II are the industry standards, but accuracy and documentation are critical.

● Investors should favor projects with conservative modeling, experienced economists, and a job cushion for safety.

At EB-5 USA, we guide investors through every step of the EB-5 process—from project selection to job creation verification and final I-829 approval. Whether you’re exploring your first EB-5 investment or preparing to file your I-829, we’re here to help ensure your path to U.S. residency is both secure and successful.

Because your Green Card shouldn't take a lifetime!