EB-5 Visa Bulletin Insights 2025 – Part 3
Each October, the U.S. Department of State opens a new fiscal year for immigrant visa processing—and with it, a new round of projections that shape investors’ expectations for the months ahead.
The October 2025 Visa Bulletin set the tone for Fiscal Year (FY) 2026, bringing modest forward movement across key categories and confirming that all FY2025 EB-5 visa numbers have been used. In this third installment of CanAm’s EB-5 Visa Bulletin Insights 2025 series, Pete Calabrese, Charlie Oppenheim, and Joey Barnett unpack what these shifts mean for investors in both the unreserved and reserved EB-5 categories.
EB-5 “Ping-Pong”: Retrogression and Recovery in FY2025
Fiscal Year 2025 saw unusual volatility in EB-5’s unreserved categories (those based on petitions filed before the 2022 Reform and Integrity Act). Mid-year retrogressions in April were followed by sharp recoveries in August—what Oppenheim called “ping-pong effects.”
“The retrogressions told us that the State Department had over-estimated earlier demand,” he explained. “Then, when they advanced the dates again in August, that showed the opposite—that the initial correction went too far.”
By the end of FY2025, those adjustments balanced out: the Department of State had successfully used all available EB-5 visas without significant waste. That outcome, Oppenheim emphasized, reflects a healthy level of demand and careful quota management.
China and India: Predictable Moves Ahead
For the months ahead, investors from China and India—the two countries with the largest EB-5 backlogs—can expect steadier progress rather than dramatic jumps.
Oppenheim projected that China’s unreserved final action date is likely to hold steady for several months to maintain control over number use, with only gradual movement later in the fiscal year. India, by contrast, is positioned for continued advancement.
“There shouldn’t be much pending demand left for India based on last spring’s data,” Oppenheim said. “I’d expect to see that category move toward full recovery within the first half of FY2026.”
Smaller, incremental advances build predictability—and, as Calabrese noted, investor confidence. “People would rather see steady, measured progress than big swings forward and backward,” he said.
The Broader Employment-Based Picture
October’s bulletin also brought widespread advancement across the EB-1, EB-2, and EB-3 categories, reflecting a new annual supply of FY2026 visa numbers. However, Oppenheim cautioned that these early-year movements can sometimes be overly aggressive:
“When the State Department advances dates too quickly in October, it increases the risk of corrective action later in the year.”
Because employment categories were unavailable during parts of August and September, USCIS and the State Department are effectively catching up on cases that would have been processed earlier. That catch-up period may temporarily limit forward movement in upcoming months, but overall usage is tracking normally.
What It Means for EB-5 Investors
For EB-5 participants, the October 2025 Visa Bulletin confirms two key realities:
- All FY2025 EB-5 visa numbers were used. That means the program is operating efficiently, with strong demand and no wasted visas.
- Incremental movement promotes stability. Predictable, data-driven adjustments—especially for China and India—reduce the risk of future retrogression and allow investors to plan with confidence.
Barnett summed up the investor takeaway clearly:
“The visa bulletin doesn’t tell you exactly how long you’ll wait—it tells you that the system is working. Smaller, steady advances mean predictability, and predictability is good for investors.”
Looking Toward FY2026
With a new annual limit estimated around 150,000 employment-based visas (including roughly 11,500 EB-5 unreserved numbers and substantial carryovers in the reserved categories), FY2026 is positioned for continued progress.
Oppenheim noted that smaller monthly movements early in the fiscal year give the State Department flexibility to maximize number use later while avoiding mid-year corrections. “It’s better to move conservatively now than to have to reverse course later,” he said.
For investors, this means the EB-5 landscape entering FY2026 is stable and fully active—a reassuring message as interest continues to grow worldwide.
The Bottom Line
The October 2025 Visa Bulletin confirms what seasoned EB-5 professionals have emphasized all year: measured progress, data-driven decisions, and continued strong demand are healthy signs for the program’s future.
As Calabrese concluded, “Predictability is the foundation of confidence in EB-5. When the numbers move steadily and transparently, investors can make informed, long-term plans for their families and their futures.”
Coming Next in the Series
Part 4 – Reserved Categories and Concurrent Filing: Opportunity in 2026
We’ll explore how FY2026 visa carryovers and the “visa waterfall” effect strengthen EB-5’s reserved categories—and why concurrent filing remains one of the most valuable tools available to investors today.
