The April 2025 Visa Bulletin shows significant retrogression of over two years for EB-5 Unreserved Final Action Dates for China and India. The final action date for India retrogressed over two years from Jan. 1, 2022, in the March bulletin to Nov. 1, 2019, in the April Bulletin. The final action date for China retrogressed approximately two and a half years from July 15, 2016, in the March bulletin to Jan. 22, 2014, in the April 2025 bulletin.  

According to the bulletin commentary section, “Increased demand and number use by applicants chargeable to China and India in the EB-5 unreserved visa categories, combined with increased demand and number use across other countries, made it necessary to retrogress the final action dates to hold number use within the maximum allowed under the FY-2025 annual limits.”

While other EB-5 unreserved categories remained current in the April 2025 bulletin, the notes indicate that may change later in the year with global retrogression forewarned. The bulletin states, “Please note that it may become necessary to establish a final action date for applicants chargeable to all other countries if demand and number use continues to increase such that this category becomes oversubscribed.”

The April 2025 Visa Bulletin does not include corresponding commentary regarding the EB-5 Set-Aside categories, which remain current at this time across all categories. However, given the limited number of set-aside visa numbers available and the possibility of future retrogression, investors should consider moving forward while these categories remain available, especially those from high-demand countries such as China and India.