IN THIS GUIDE · Two unrelated investors funding the same standalone United States company, with separate capital trails and separate job attribution
Start with the EB-5 eligibility and application overview
Ten qualifying jobs for each investor, not ten between you
The requirement is at least ten qualifying full-time positions attributable to each investor's own investment. Two investors in one company therefore need at least twenty in total, allocated so that no position supports both petitions. The investor, the investor's spouse and their children are excluded from the count. Permitted methods of counting differ between a direct investment and a regional center case.
Two capital trails through one company
Each investor must show a lawful source and a lawful path for their own capital at the qualifying amount, US$1,050,000 or US$800,000 where a targeted employment area or infrastructure basis applies. Statutory adjustments begin January 1, 2027. Pooling into one operating account without contribution records makes both trails harder to read, so the company's books should identify each subscription separately.
Corporate records that carry evidentiary weight
Subscription, ownership, decision, and payroll records can establish each contribution and attributable jobs. Other evidence, including personal bank confirmations, supplements those records. Agree on retention and access responsibilities, then verify the format required at each stage instead of universally requiring certified copies. Hypothetical example: two investors fund a basalt-fibre acoustic-panel plant, but a twelve-position payroll forecast assigns no jobs to either contribution. The review compares subscriptions, receipts, hiring schedules, and payroll descriptions. The decision is whether the plan supports separate job attribution or counts the same positions twice.
Two petitions, two independent outcomes
Each standalone investor files their own I-526, while the regional-center route uses I-526E. One approval does not guarantee the other's, but shared business facts can affect both cases. At-risk capital and sustainment requirements need assessment for each; no automatic two-year repayment is promised. The retention plan should identify which records will prove continued capital deployment and job creation at the later stage. That decision should be made before documents are scattered among the company, investors, and outside payroll providers.
Engagement in the enterprise and the two-year condition
A limited-partner interest with voting rights on policy matters is a recognized form of engagement in a regional-center structure; read the partnership agreement to confirm those rights exist. The qualifying amounts under the 2022 legislation are one million fifty thousand dollars generally and eight hundred thousand dollars for a targeted employment area or infrastructure project; those figures are subject to adjustment and should be verified against current official sources before any commitment. Where the investment is made through a designated regional centre, a defined portion of indirect and induced job creation may be counted using an accepted economic methodology, but the arithmetic still has to reach ten for every investor in the offering. The investor must also be engaged in the enterprise beyond simply handing over money, through management or policy formulation, which a limited partnership structure can satisfy but which cannot simply be absent.
Sources reviewed 2026-09-07. This guide covers a preparation focus; it is not an individual eligibility assessment.
