TL;DR
- The EB-5 October 2025 Visa Bulletin shows the largest forward movement in years, including a major advance for India’s final action date to 1 February 2021, enabling many investors to proceed to final processing now [DoS] [Murthy].
- China’s EB-5 unreserved cutoff remains stuck at 8 December 2015, signaling a continued multi‑year backlog for Chinese investors [Murthy] [DoS].
- All other countries and all EB‑5 set‑aside categories are current, meaning immediate visa availability for eligible investors (including those from Armenia) [Murthy] [DoS].
- USCIS has directed applicants to use the “Dates for Filing” chart in October, opening Adjustment of Status filing windows immediately for many in the U.S. [Gozel Law] [USCIS].
- The surge comes as FY2025’s unreserved EB‑5 visa limit was fully used, with new numbers released at the start of FY2026 [EB‑5 Updates] [DoS].
The EB-5 October 2025 Visa Bulletin matters—both for investors stuck in backlogs and for law firms managing time-sensitive filings. It delivers the biggest forward push in EB‑5 cutoff dates in years, notably for India, and opens immediate filing windows for thousands who can finally move their cases.
October 2025 EB-5 Visa Bulletin — headline takeaways
The U.S. Department of State’s October 2025 Visa Bulletin marks unusually large advances in EB‑5 cutoff dates. India’s EB‑5 unreserved “Final Action Date” (FAD) moves to 1 February 2021, the strongest jump in years, while China’s unreserved FAD holds at 8 December 2015. All other countries—and all EB‑5 set‑aside categories—are current, signaling immediate visa availability for eligible applicants [DoS] [Murthy].
At-a-glance: EB‑5 status, October 2025
| Country/Category | EB‑5 (Unreserved) Final Action Date | Status |
|---|---|---|
| India | 1 Feb 2021 | Advanced; many cases can finalize now [DoS] |
| China (Mainland-born) | 8 Dec 2015 | Backlogged [DoS] |
| All other countries (e.g., Armenia) | Current | Immediate availability [Murthy] |
| All EB‑5 set‑aside categories | Current | Immediate availability [Murthy] |
For firms: audit all client priority dates, triage Indian and long‑queued cases, and prepare to file Adjustment of Status (AOS) where eligible given USCIS’s instruction to use “Dates for Filing” in October [Gozel Law] [USCIS].
Why the bulletin moved: FY2025 unreserved EB-5 visas were exhausted and numbers rolled into FY2026
The sharp forward movement coincides with two dynamics:
- FY2025 unreserved EB‑5 usage was maxed out: The State Department reached the unreserved EB‑5 visa limit for FY2025 (approx. 11,229 numbers) by mid‑September, confirming exceptionally strong demand in the category [EB‑5 Updates].
- Fresh FY2026 allocation at start of fiscal year: With the new fiscal year (October) comes a new annual allocation of EB‑5 numbers, allowing the Department of State to advance cutoffs and re‑open pipelines for final action where demand and visa math permit [DoS].
In practice, this means many Indian investors with priority dates on or before 1 February 2021 can now expect final immigrant visa issuance (consular) or I‑485 approval (AOS), subject to case readiness and processing times.
Historic 14–15 month advance for India (final action date to Feb. 1 and who moves forward
India recorded a historic forward movement: the EB‑5 unreserved “Final Action Date” advanced to 1 February 2021, a jump of roughly 14–15 months compared with the prior cutoff—one of the largest month‑to‑month advances in recent memory [Gozel Law] [Murthy] [DoS].
Who moves forward now?
- Indian EB‑5 investors with priority dates on or before 1 Feb 2021 in the unreserved category can proceed to final action: immigrant visa issuance at the consulate or I‑485 approval in the U.S., subject to normal vetting and processing steps [DoS].
- Indian investors in set‑aside categories (e.g., rural, high‑unemployment, infrastructure) remain current, benefitting from reserved visa pools under the EB‑5 Reform and Integrity Act framework [Murthy].
Firms should anticipate heightened inquiry volume from India and consider clinic‑style sessions for clients whose cases now clear the FAD or the October “Dates for Filing” thresholds.
China’s EB‑5 cutoff remains Dec. 8 — continued multi‑year backlog for Chinese investors
By contrast, China’s EB‑5 unreserved cutoff remains at 8 December 2015, indicating a sustained multi‑year queue. While set‑aside categories are current, China‑born investors in unreserved EB‑5 should continue to plan for extended timelines or evaluate reserved options where appropriate [Murthy] [DoS].
Action checklist for China‑born EB‑5 investors
- Confirm whether you qualify under a set‑aside category (rural/high‑unemployment/infrastructure) that is current [Murthy].
- Reassess AOS vs. consular processing in light of your personal situation and travel plans [USCIS].
- Ensure source‑of‑funds and project documentation remain current and responsive for eventual visa issuance.
All other countries (including Armenia) are current — immediate visa availability and beneficiaries
For EB‑5 unreserved applicants from all other chargeability areas (including Armenia), the category is current—meaning visa numbers are immediately available for eligible cases ready to process [Murthy] [DoS].
Current status can materially accelerate outcomes for Armenian or regional investors ready to file. If you are exploring cross‑border structures or diversifying capital between Armenia and the U.S., align your immigration timeline with your corporate and tax strategy:
- Company setup and investment structuring in Armenia or abroad: see our guidance on business registration and investment.
- Coordinate personal and corporate tax planning across jurisdictions: review Armenia’s regime and cross‑border implications in taxes.
- For family mobility and contingency planning, consider Armenia residency options alongside U.S. EB‑5 timelines.
USCIS ‘Dates for Filing’ guidance for October 2025 and how it unlocks Adjustment of Status filings now
USCIS has confirmed that, for October 2025, applicants in both family‑ and employment‑based categories (including EB‑5) should use the “Dates for Filing” chart. This unlocks immediate AOS filings for those in the U.S. whose priority dates are current under the filing chart, even if the “Final Action Date” has not yet been reached [Gozel Law] [USCIS].
What this means in practice
- Adjustment of Status (AOS): If you are lawfully in the U.S. and your EB‑5 priority date is current under the October “Dates for Filing,” you can file the I‑485 now, securing benefits such as work authorization (EAD) and advance parole while you wait for final action [USCIS].
- Consular Processing: If you reside abroad, your case can move to National Visa Center (NVC) document qualification and consular interviews when your FAD is current (for many, immediately in October) [DoS].
Immediate steps for investors and counsel
- Audit priority dates: Identify all clients with PDs at or before the India FAD (1 Feb 2021) and those from non‑backlogged countries who are current [DoS].
- Decide AOS vs. consular strategy: For U.S.‑based clients, leverage October “Dates for Filing” to submit I‑485 packages promptly; for abroad clients, ready NVC and consular documentation [Gozel Law] [USCIS].
- Pre‑clear evidence: Refresh source‑of‑funds, project compliance, and job‑creation documentation to avoid RFEs at the finish line.
- Stage communications: Notify India‑born and “all other countries” clients who are newly eligible; prepare FAQs and webinars to manage expected inquiry spikes.
- Calendar fiscal‑year dynamics: Expect front‑loaded visa number availability early in the fiscal year; track monthly bulletins for any corrective slowdowns or retrogressions [DoS].
For clients weighing portfolio moves, immigration timing should align with asset deployment and tax efficiency. Coordinate EB‑5 steps with our cross‑border investment and tax planning support, and pre‑plan travel and status options via our visa desk.
Conclusion
The EB-5 October 2025 Visa Bulletin delivers rare, outsized progress—especially for India—while keeping China’s unreserved line long and all other countries current. With USCIS allowing “Dates for Filing” use in October, this is a filing opportunity that investors and firms should act on immediately. If you want a fast, audit‑driven review of eligibility, filing strategy, and documentation, contact our team today.
Talk to an attorney about the EB-5 October 2025 Visa Bulletin
FAQ
What changed for India in the EB‑5 October 2025 Visa Bulletin?
India’s EB‑5 unreserved Final Action Date advanced to 1 February 2021—roughly a 14–15 month jump—allowing many long‑queued cases to proceed to final adjudication [Gozel Law] [Murthy] [DoS].
Are EB‑5 set‑aside categories current in October 2025?
Yes. All EB‑5 set‑aside categories (such as rural, high‑unemployment, infrastructure) are current in October 2025, enabling immediate visa availability for eligible investors [Murthy].
Why is China’s EB‑5 unreserved category still backlogged?
Can I file Adjustment of Status in October 2025 if my “Dates for Filing” is current?
Yes. USCIS has instructed that in October 2025, applicants should use the “Dates for Filing” chart, allowing in‑US applicants to file I‑485s when the filing date is current, even if the Final Action Date is not yet current [Gozel Law] [USCIS].
What triggered the big movements in October?
The unreserved EB‑5 limit for FY2025 (approx. 11,229 numbers) was reached, and with the start of FY2026, new visa numbers became available, enabling DOS to advance cutoff dates significantly where demand and allocations allowed [EB‑5 Updates] [DoS].