Investors · EB-5 · Guide
Job creation for data center campuses
How EB-5 jobs are counted for a construction-heavy, long-lived asset: the ten-job rule, direct, indirect and induced jobs, economic models and timing. A general guide based on USCIS guidance. No offering is being made on this website.
The rule
Ten jobs for every investor
The EB-5 program exists to create jobs. Each investor’s investment must create or preserve at least ten full-time jobs for qualifying workers in the United States. That number is the center of every EB-5 job analysis, and the questions are how the jobs are counted, when they exist and who proves it.
This page explains the counting rules in plain language and what changes when the project is a data center campus with its own power plant. It states no job counts for any PacinfraX project. Those belong in a project’s offering documents, with the analysis behind them.
Counting
Direct, indirect and induced jobs
A single construction contract supports work well beyond the site fence. Economists sort that work into three groups.
Photo: field engineer at a substation
The Act’s rules on how direct jobs are defined are being put into regulation. See the Federal Register, DHS proposed rule 2026-13392 (July 2, 2026) for the proposal and ask counsel which version applies to a given petition.
Show the three kinds of jobs
| Kind | What it means | Examples |
|---|---|---|
| Direct jobs | Positions on the payroll of the job-creating entity, such as the staff who operate a campus. Under the Act, as counsel advises, the definition for regional center investors is wider than the payroll alone. | Facility technicians, electrical and controls operators, security and administration. |
| Indirect jobs | Positions at suppliers and contractors that exist because of the project’s spending. | Steel and concrete suppliers, electrical equipment makers, trucking and skilled trades. |
| Induced jobs | Positions created when direct and indirect workers spend their wages in the local economy. USCIS groups these with indirect jobs. | Restaurants, housing, retail, health care and other local services. |
Two routes
Regional center counting and direct counting
There are two ways to count. In a direct investment, only jobs on the payroll of the commercial enterprise count. In a regional center project, the investor can also rely on indirect and induced jobs, because the regional center’s economic analysis shows how the project’s spending creates them.
Why the route matters for a campus
This is why most large infrastructure projects use the regional center route. A campus that is built by many contractors creates many more jobs outside the owner’s payroll than inside it. Under the Act, as counsel advises, indirect jobs can account for only part of the total for a regional center project. The share and the treatment of construction jobs that last under two years, described below, are matters for your counsel to explain for your case.
For more on the sponsoring organization, see the regional center model.
Models
Input-output models, in plain words
Photo: engineers reviewing drawings
An input-output model is a table of how industries buy from each other. Spend on one thing and the model shows how much extra activity, and how many jobs, follow in other industries in the same region. The result depends on three inputs: the amounts spent, the type of spending and the region.
Show the three common models
Three models are commonly used in public economist practice:
- RIMS II, a regional multiplier set produced by the Bureau of Economic Analysis, a US government statistical agency.
- IMPLAN, a commercial model that builds regional tables from federal data.
- REDYN, a commercial model that adds change over time.
Each model has its own method, and the same project can produce different numbers under different models, regions or assumptions. USCIS reviews the methodology as well as the result. That is why an investor should ask which model was used, which counties it covered and what spending it assumed.
Construction
Construction spending and the two-year consideration
A data center campus is a construction-heavy asset. Most of the early jobs come from building the shell, the electrical systems, the cooling plant and, where there is one, the on-site power plant. Construction employment is temporary by nature, so the way it is counted matters.
Under the Act, as counsel advises, construction jobs expected to last under two years are prorated. A position that exists for one year counts as a share of a full job, not as a whole one. A build in several phases can support employment across a longer period than a single build, and the economist’s schedule of spending by period is what shows this.
The timing of when jobs exist is also part of the analysis. USCIS looks for the jobs when the investor files Form I-829. Counsel can explain how the filing date relates to the construction and operations schedule of the project the investor is considering.
Operations
Operations jobs at a campus with on-site power
After construction, a campus runs for decades. The jobs that remain are different in kind from the construction ones. Types of roles include:
Show the five types of roles
- Data hall and facility operations: technicians, shift engineers and monitoring staff.
- Electrical and mechanical maintenance: technicians for switchgear, cooling and backup systems.
- On-site power plant: plant operators, instrument and controls technicians and maintenance crews.
- Safety, environmental and security: compliance staff and site guards.
- Administration and logistics: procurement, warehousing, finance and human resources.
This page gives no counts for any of these. Counts depend on the size of the campus, on the stage of its build and on how the economist classifies each role.
Evidence
Why an economist’s report belongs in offering documents, not on a website
A job-creation figure is the output of a method. Taken out of the report and placed on a web page, it loses its assumptions, its region, its model and its dates. A reader then sees a number and cannot test it.
Securities law and the proposed immigration rules both treat statements about future outcomes with care. A projection needs a stated basis and meaningful cautionary language, and a statement can mislead through what it leaves out. PacinfraX therefore publishes no job figures here. A project’s economist report would sit in the confidential offering documents, where an investor and counsel can read it in full.
Reading the numbers
How investors read a job-creation table
When an economist’s table reaches you, read the methodology section first. Then work through this list.
Open the reading checklist
- Region. Which counties or states does the model cover, and why?
- Model and version. RIMS II, IMPLAN, REDYN or another, and the data year.
- Spending. What categories of spending are assumed, in what amounts and in which periods?
- Split. How many jobs are direct, indirect and induced?
- Job-years or jobs. Does a count describe positions that last, or work that lasts one year?
- Construction proration. How are construction jobs of under two years treated?
- Cushion. How far does the total exceed ten jobs for every investor in the project?
- Authorship. Who prepared the report, and are they independent of the project?
Next step
Questions for your counsel
Use these questions with your own immigration counsel. They are general and do not replace advice on your facts.
Show the questions
- Which jobs will be counted as direct, indirect and induced for this project, and under which definition?
- What share of the total do indirect jobs represent under the Act, and how does the project’s analysis treat that share?
- Which model and region did the economist use, and would a different choice change the result?
- How are construction jobs of under two years prorated, and how does the build schedule affect the count?
- When must the jobs exist for my Form I-829, and how does the project schedule line up with that date?
- How much room is there above ten jobs for each investor in the project, and what happens if the project is delayed?
- Who prepared the economist’s report, and is that person independent of the sponsor?
Short answers
Frequently asked questions
How many jobs does each EB-5 investor have to create?
The investor’s investment must create or preserve at least ten full-time jobs for qualifying workers. In a regional center project, indirect and induced jobs can count toward that number under the Act, as counsel advises.
Do construction jobs count?
Yes, they can count, as direct, indirect or induced jobs. Under the Act, as counsel advises, construction jobs expected to last under two years are prorated, so the timing and phasing of the build matter.
Which economic model does USCIS require?
USCIS reviews the methodology of the economist’s report and does not require one named model. RIMS II, IMPLAN and REDYN are commonly used in public economist practice. What matters is that the method fits the project and is explained.
Does PacinfraX state job numbers on this website?
No. Job figures come from an economist’s report for a specific project, and they belong in the confidential offering documents with their methods and assumptions. This site explains how jobs are counted and states no counts.
Questions about how EB-5 jobs are counted?
Register interest or write to [email protected]. We never ask for funds through this website or by message.