September 2025 Visa Bulletin: FY2025 Marked by Volatile Unreserved EB-5 Movements and No Retrogression in Reserved Categories

This week, the U.S. Department of State released the September 2025 Visa Bulletin (see here), concluding FY2025 with no changes for either the Unreserved or Reserved EB-5 categories in the last month of the current fiscal year.

FY2025 has been a volatile year for pre-RIA EB-5 applicants from China and India. In October 2024, the first month of FY2025, the Unreserved EB-5 final action date advanced by 213 days for China-born applicants and 396 days for Indian-born applicants (see here). However, in April and May 2025, the cut-off dates retrogressed drastically, moving back 905 days for China and a total of 976 days for India (see here). In August, pre-RIA Chinese applicants saw a 685-day advancement in their cut-off date, while pre-RIA Indian applicants enjoyed a 198-day advancement (see here). Overall, compared to September 2024, the FY2025 cut-off date for Unreserved EB-5 applicants retrogressed by 7 days for China and moved back 382 days for India. The chart below illustrates the month-by-month changes in final action dates for Unreserved EB-5 applicants from China and India, showing the volatile movements in this fiscal year.

 

As anticipated, all Reserved EB-5 categories have remained “current” throughout FY2025. Our analysis found that since the implementation of the Reform and Integrity Act, USCIS has adjudicated only 1,620 I-526E and I-526 cases, approving fewer than 500 cases in the first half of FY2025 (see here). Consequently, only 9% of available visas in the Rural Area category and 8% in the High Unemployment Area category were issued through May 2025 (see here). Depending on the pace of visa usage through adjustment of status at USCIS, it is highly likely that a portion of carryover Reserved visas will go unused in FY2025.

 

 


 

EB-5 FINAL ACTION DATES (CHART A)

The September Visa Bulletin revealed the following final action dates for EB-5 visa applicants:

  • Unreserved EB-5 Visa Categories:

    • China: December 8, 2015 (unchanged from the August Visa Bulletin)
    • India: November 15, 2019 (unchanged from the August Visa Bulletin)
    • All Other Countries: “Current”
  • Reserved EB-5 Visa Categories:

    • All Countries: “Current”

(Chart A on the September 2025 Visa Bulletin)

EB-5 DATES FOR FILING (CHART B)

All Reserved EB-5 categories remain “current” across the board, confirming that there are no cutoff dates for applicants in these categories in September.

For the Unreserved EB-5 category, the Dates for Filing remain “current” for all applicants in the last month of FY2025, except for those born in China or India:

  • For Chinese applicants: October 1, 2016 (unchanged from the August Visa Bulletin);.
  • For Indian applicants: April 1, 2022 (unchanged from the August Visa Bulletin).

(Chart B on the September 2025 Visa Bulletin)

 

USCIS AOS Filing Charts for September 2025

According to USCIS, in September, the agency will continue to accept only Chart A (Final Action Dates) for employment-based adjustment of status (AOS) applications, meaning the window to use Chart B (Dates for Filing) will remain closed in the upcoming month. See below for USCIS’ announcement on its website:

Next Month’s Adjustment of Status Filing Charts

For Employment-Based Preference Filings:
For all employment-based preference categories, you must use the Final Action Dates chart in the Department of State Visa Bulletin for September 2025.

 

 

 

Have you explored IIUSA’s EB-5 Visa Data Dashboard? This powerful tool offers comprehensive insights into EB-5 visa usage, including:

  • Year-to-date issuances for Fiscal Year 2025,
  • Historical trends in visa number availability versus usage,
  • Country-specific statistics on EB-5 green card issuances, and
  • Much more.

Stay informed with the latest data to support your decision-making and analysis.

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