No automatic conclusion follows from headcount alone. Assess the actual managerial or executive role, the operation and the support that performs nonmanagerial work.
Explain what the restructuring changes
Identify the applicant’s responsibilities after the change, including execution work newly assigned to them. Qualifying company relationships and foreign employment remain separate requirements. A title retained during restructuring does not establish all of them.
Document the reason for the reduced headcount, whether functions were automated, consolidated under another qualifying entity or simply eliminated, since the explanation shapes whether the remaining structure still supports managerial work rather than requiring the applicant to step into delivery tasks personally. Prepare a current organizational chart alongside the one used before the change and mark which positions were removed, merged or left vacant. Identify precisely which tasks the applicant absorbed as a direct result of the restructuring and which duties continue to be delegated to remaining staff or contractors under the applicant's ongoing direction.
Confirm whether any outside vendor or shared-service arrangement now performs work that subordinates previously handled, because that shift can preserve a managerial role even with fewer direct reports. Ask whether the remaining team members are themselves managers, supervisors or professionals, since the composition of a smaller group, not merely its size, determines whether the applicant still primarily manages rather than personally performs the underlying work day to day.