Visa Bulletin Update: What the April 2025 Regression Means for EB-5 Investors

April Visa Bulletin Update

Just a few months ago, the October 2024 Visa Bulletin delivered a welcome surprise: Final Action Dates advanced for both China and India in the unreserved EB-5 category, fueling optimism across the EB-5 community. But the April 2025 Visa Bulletin brought a different kind of headline—this time, a sharp regression that left many stakeholders wondering: What happened?

In the weeks since, leading EB-5 experts have weighed in, offering data-driven analyses, historical context, and forward-looking insights. At CanAm, we’ve been following the developments closely and have compiled the key takeaways to help investors and partners navigate what this change means—and what to expect in the months ahead.

See Here: Visa Bulletin for April 2025

Why Did Final Action Dates for China and India Regress?

There are several factors driving this change, and while the shift may be jarring, it reflects both progress in visa issuance and increased demand for EB-5.

  1. Visa Issuance Has Accelerated Significantly

One of the biggest differences in this fiscal year has been the improved pace of visa issuance by the U.S. Department of State (DOS). After years of pandemic-related delays and operational slowdowns, U.S. Consulate Offices worldwide appear to be operating at pre-COVID efficiency levels—comparable to 2017.

In fact, between October 2024 and January 2025 alone, more than 5,300 consular-based Unreserved EB-5 visas were issued. That’s 46% of the total annual visa allocation in just the first four months. For context, EB-5 receives approximately 10,000 visas annually—so nearly half of the available visas were utilized in record time.

This kind of progress is encouraging, particularly after years of underutilization and wasted carryover visas. But it also means that available visas are being used up more quickly, accelerating the timeline for when cut-off dates may need to be introduced or adjusted.

  1. More Demand from Rest of World (ROW) Pre-RIA Applicants

Another factor is that the DOS may be anticipating higher usage of unreserved visas from Rest of World (ROW) pre-RIA applicants. As more I-526 petitions from the pre-RIA period are being adjudicated—many of which are being approved—it stands to reason that more investors from outside the traditionally high-demand countries will begin claiming their visas.

This increased demand from ROW applicants means fewer “otherwise unused” visas are left over to be reallocated to China and India, which have long faced the steepest backlogs.

While this development contributes to the regression, it also signals a positive trend: pre-RIA adjudications are moving forward, creating momentum in the pipeline.

What Happens Next?

The good news: that this setback may only be temporary.

As seen in previous years, new visa allocations are made on October 1st, marking the start of the next fiscal year. Once that happens, we can expect the Final Action Dates for China and India to advance again, just as they did in October 2024.

It’s important for investors to remember that the EB-5 program functions within an annual visa cycle. When demand increases and adjudication timelines speed up, we may see short-term retrogressions, but the long-term trajectory remains intact.

Reserved Categories Remain a Bright Spot

DATES FOR FILING OF EMPLOYMENT-BASED VISA APPLICATIONS

While the April 2025 Visa Bulletin brought some disappointing news for unreserved categories, there was no change to the Reserved EB-5 categories. According to the bulletin, all Reserved EB-5 categories remain “Current.”

That means eligible investors in the Rural, High Unemployment, and Infrastructure subcategories can still move forward without delay.

It’s also worth noting that while DOS has not yet introduced cut-off dates for Reserved categories, that could change later in the year—especially if demand continues to increase at the current pace. As always, timing is crucial.

Bottom Line: Act While Reserved Categories Are Still Open

The current visa environment is dynamic, and while regressions like the one in April can cause uncertainty, they also highlight an important reality: EB-5 demand is back.

For investors, especially those considering the Reserved categories, the window of opportunity remains open—but may not stay that way for long.

At CanAm, we continue to emphasize proactive planning. Reserved EB-5 categories not only offer strong immigration benefits but also represent a time-sensitive opportunity in today’s market. Acting now could be the difference between securing a spot or facing longer wait times down the line.

If you have questions about how the latest Visa Bulletin may affect your EB-5 journey—or if you’re considering beginning the process—our team is here to help.

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