Choosing between Direct vs Regional Center EB-5 financing

Last Updated: October 12, 2025

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AIIA has curated a list of the top professionals from attorneys, investment specialists, to business plan writers to support all all EB-5 stakeholders

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The EB-5 program is actually two programs in one: investors can invest directly into a business (this is referred to as a “direct EB-5” investment) or can invest in a project that is sponsored by a regional center (known as an “indirect EB-5 investment).

Direct EB-5

Direct EB-5 projects can only accept investment from one EB-5 investor, totalling $800,000-$1.05 million. Jobs must be created and maintained directly by the business into which the capital is invested. Direct jobs are synonymous with W-2 employees. The business is required to create 10 new, full-time W-2 jobs within two years.

Full time is defined as 35 hours per week or more. Contractor positions and/or positions created by affiliated entities do not count toward the minimum job creation requirement. As such, the direct EB-5 avenue is well-suited for businesses that have a high labor need and have low turnover.

It is common for foreign entrepreneurs to invest amounts greater than the minimum investment amount and build businesses (such as tech companies) to meet the EB-5 requirements. However, only a small percentage of EB-5 investors (2%) actually choose the direct EB-5 route because of the risk involved in small business financing.

Regional Center Projects

The EB-5 Regional Center Program is separate from the direct program and allows projects to pool capital into a single fund from multiple investors. This is a common model for large projects which require high capital raises to construct or redevelop. Typically, the pooled capital from EB-5 investors is a source of supplementary funding in a larger capital stack, enabling the project to move forward.

The ceiling for investment is determined by the projected job creation of the project. For example, if a project will create 500 jobs, the maximum number of EB-5 investors it could support would be 50, merely because the project cannot facilitate a larger number of employees(500 jobs / 10 jobs per investor). Therefore, the project could raise $40 million from EB-5 investors if it is located in a TEA ($800,000 in capital investment per investor x 50 investors). In contrast to the direct model, regional center projects can count indirect and induced jobs, in addition to direct jobs, which allows for the capital raises to be higher due to a greater degree of economic impact.

EB-5 investment routes
	Direct	Regional Center Program
Investment amount required	$800,000 (TEA) $1,050,000 (Non TEA)	$800,000 (TEA) $1,050,000 (Non TEA)
Number of Investors Per Project/Business	1	, Limited only by job creation capacity
Typical Businesses/Project Types	Singular enterprises raising capital for startup or growth plans. Seeking less investment capital.	Larger projects with large capex or development budgets. Seeking more investment capital.
Minimum Job Creation Requirements per Investor	At least 10 full time	At least 10 full time (+ buffer/ cushion of extra jobs)
Qualifying “new” Job Types	Direct employment only	Direct, indirect, and induced employment with a minimum of 10% being direct
Supporting Documentation Required to Demonstrate Job Creation	Credible business plan with research-backed projections and job creation timeline	Economic impact analysis informed by a project budget and pro forma, credible business plan that backs projections
Sponsorship	None required	Project must be sponsored by a designated regional center
Record Keeping and Reporting	Managed by the business	Managed by the regional center

For Developers, Business Owners, and Governments

More Resources

EB-5 Program Logistics: Direct vs Regional Center

EB-5 investments are direct or regional center types; regional centers pool funds and count indirect jobs, while direct requires active management and counts direct jobs only.

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