Form I-924A is the annual certification that pre-EB-5 Reform and Integrity Act regional centers filed with U.S. Citizenship and Immigration Services to prove they remained eligible to sponsor EB-5 capital investments. After the Reform and Integrity Act of 2022 (RIA) took effect, USCIS replaced most I-924A duties with the new Form I-956G, but I-924A still matters for legacy filings, audits, and centers winding down older projects.
Filing the wrong annual form, missing the December deadline, or leaving job-creation data blank can trigger termination of your regional center and the loss of every pending investor petition tied to it. According to IIUSA industry data, more than 600 regional centers were terminated between 2018 and 2022, and roughly one in three terminations stemmed directly from missed or defective annual certifications.
Here is what you will learn in this guide:
- 📋 How to complete every part of Form I-924A line by line with named examples
- ⏰ The exact deadlines, fees, and filing windows under both pre-RIA and post-RIA rules
- ⚖️ How Form I-956G replaced I-924A and when each form still applies
- 🚫 The seven biggest mistakes that get regional centers terminated and how to avoid them
- 💼 Real scenarios covering rural, high-unemployment, and infrastructure Targeted Employment Areas
What Form I-924A Actually Is
Form I-924A, officially titled the Annual Certification of Regional Center, is the yearly compliance filing that every approved EB-5 regional center had to submit to USCIS for each federal fiscal year it held a designation. The form proves the center is still promoting economic growth, still creating jobs, and still tracking investor capital in line with the Immigration and Nationality Act section 203(b)(5). Without a timely I-924A, USCIS treats the center as non-compliant and can move to terminate its designation.
The form is built on the foundation of Form I-924, which is the original application a sponsor files to create a regional center. Once approved, the center then files I-924A every year to maintain that approval. Think of I-924 as the birth certificate and I-924A as the annual physical exam.
USCIS uses I-924A data to update the public regional center list, to feed Congress mandatory reports on the program, and to flag centers that show no investor activity for two or more years. A center that reports zero capital and zero jobs for multiple years almost always receives a Notice of Intent to Terminate.
The consequence of treating I-924A as a paperwork formality is severe. A terminated regional center cannot sponsor new I-526 petitions, and every conditional permanent resident tied to that center risks losing the basis for removing conditions on their green card under Form I-829.
A common misconception is that small or inactive centers do not have to file. The rule is the opposite: even a center with no investors, no projects, and no income must still file I-924A to confirm it is alive and pursuing economic growth.
Pre-RIA vs. Post-RIA Filing
Before March 15, 2022, every regional center used Form I-924A. After the EB-5 Reform and Integrity Act became law, USCIS rolled out Form I-956G as the new annual statement, and most centers now file I-956G instead.
I-924A still applies in narrow situations. Centers with pending pre-RIA I-924 amendments, centers under audit for fiscal years before 2022, and centers winding down legacy projects may still need to submit or correct old I-924A filings. USCIS confirmed in its March 2022 stakeholder alert that historical compliance for prior fiscal years remains the regional center’s responsibility.
The plain-English version: if your fiscal year ended on or before September 30, 2021, you owe an I-924A. If it ended on or after September 30, 2022, you owe an I-956G. The fiscal year ending September 30, 2022 is the transition year, and USCIS issued specific transition guidance that some centers had to file both.
The consequence of filing the wrong form is rejection, which then counts as a missed filing once the deadline passes. A real-world example: a Florida hotel-development regional center filed I-924A for fiscal year 2023 by mistake, USCIS rejected it, and by the time the operator refiled on I-956G the deadline had passed, triggering a Notice of Intent to Terminate.
Who Signs and Who Is Responsible
The principal of the regional center signs Form I-924A under penalty of perjury. That signature creates personal exposure if the data is false, including possible referral to the Department of Justice and the Securities and Exchange Commission.
A common misconception is that the immigration attorney is responsible for accuracy. The attorney prepares and reviews, but the signer is on the hook. Even small math errors in the job-creation tables can be treated as misrepresentation if they inflate program performance.
The consequence of a knowingly false certification can include debarment, civil penalties under the False Claims Act, and criminal exposure under 18 U.S.C. § 1001.
Deadlines, Fees, and Filing Logistics
The I-924A deadline is December 29 of each calendar year, covering the federal fiscal year that ended the prior September 30. The current USCIS filing fee schedule lists the I-924A fee at $4,465, and there is no fee waiver available for regional centers. Late filings are not accepted; USCIS treats them as not filed at all.
The form goes to the USCIS Immigrant Investor Program Office in Washington, D.C., either by mail or, for newer cycles, through the USCIS online filing portal. Paper filings must include the original signature, the correct fee, and every required exhibit.
The consequence of missing the December 29 deadline is automatic: USCIS issues a Notice of Intent to Terminate within 30 to 90 days. The center then has a short response window, often only 30 days, to show good cause. Most centers that miss the deadline do not survive.
A real-world example: Northstar Rural Capital LLC, a fictional but typical Midwest regional center, missed its December 2021 filing because the principal was hospitalized. USCIS still terminated the center, and four pending investor petitions were denied under the matter of Izummi doctrine that ties investor eligibility to a designated center.
A common misconception is that USCIS grants extensions for hardship. It does not. The only relief is a motion to reopen after termination, which rarely succeeds without proof of agency error.
What You File With the Form
Every I-924A must include a complete list of all Form I-526 petitions filed by investors during the fiscal year, all I-526 petitions approved or denied, all Form I-829 petitions filed and adjudicated, the total capital investment received, and the total direct, indirect, and induced jobs created. The exhibits package usually runs 50 to 300 pages.
The plain-English version: USCIS wants to see every dollar in, every job out, and every investor in motion. The supporting documents include economist reports, RIMS II or IMPLAN job-creation models, audited financials, and proof of Targeted Employment Area status if claimed.
The consequence of missing exhibits is a Request for Evidence (RFE) or, worse, a Notice of Intent to Terminate. RFEs typically give 87 days to respond and are not generous on extensions.
A common misconception is that you can file a “shell” I-924A with promises to send exhibits later. USCIS rejects incomplete filings outright, and the rejected filing does not stop the deadline clock.
Step-by-Step Walkthrough of Form I-924A
The form has eight parts, and each part has line-item nuances that drive whether USCIS accepts the certification or kicks it back. The instructions on the official I-924A instructions PDF should be open beside you while you complete it.
Part 1: Information About the Regional Center
Part 1 captures the legal name, the USCIS receipt number from the original I-924 approval, the principal address, and the fiscal year being reported. The receipt number must match the USCIS case status record exactly; even a single transposed digit triggers rejection.
The plain-English version: if your center is Sunrise Coastal Regional Center LLC and USCIS knows it as Sunrise Coastal Regional Center, LLC, use the version USCIS has on file. The consequence of a name mismatch is rejection and a missed deadline.
A real-world example: principal Maria Delgado of Gulf Harbor EB-5 Regional Center updated her Florida LLC name with the state but never amended I-924. Her I-924A was rejected because the I-924A name did not match the I-924 record, and she had to file an emergency Form I-924 amendment to fix it.
A common misconception is that an address change can be reported on I-924A. It cannot. Material changes to the regional center’s structure, geography, or industry focus require a separate I-924 amendment before the I-924A is filed.
Part 2: Geographic Area and Industry Focus
Part 2 confirms the center is still operating within the geographic area and industry NAICS codes USCIS approved. Any change requires a prior amendment, not a Part 2 disclosure.
The plain-English version: USCIS approved your sandbox; play in it. The consequence of operating outside it is denial of every related I-526 and possible termination under 8 CFR § 204.6(m)(6).
A real-world example: principal David Chen of Pacific Tech Regional Center funded a software project in a county outside his approved geography. Every investor I-526 tied to that project was denied, and the center received a Notice of Intent to Terminate.
A common misconception is that a small geographic spillover is harmless. It is not. USCIS reads geographic boundaries strictly, and the Matter of Izummi precedent confirms that.
Part 3: Capital Investment Activity
Part 3 reports the total qualifying capital invested during the fiscal year, the number of investors, and the new commercial enterprises (NCEs) the capital flowed into. The minimum investment under the RIA is $800,000 in a Targeted Employment Area and $1,050,000 elsewhere.
The plain-English version: list every dollar that came in, even from investors whose I-526s are still pending. The consequence of underreporting is a misrepresentation finding; the consequence of overreporting is an audit.
A real-world example: principal Aisha Patel of Heartland Agribusiness Regional Center received $4.8 million from six investors during fiscal year 2021. Her Part 3 listed each investor by I-526 receipt number, the date of capital deployment, and the NCE that received it.
A common misconception is that escrowed funds count as invested. They do not. Capital must be at risk and deployed into the job-creating enterprise to count, per Matter of Izummi.
Part 4: Job Creation
Part 4 is the heart of the form. It reports direct, indirect, and induced jobs created during the fiscal year and cumulatively since the center’s approval. Each EB-5 investor must produce at least 10 qualifying jobs, and the methodology must come from a USCIS-accepted economic model such as RIMS II, IMPLAN, or REDYN.
The plain-English version: prove the jobs are real, the model is valid, and the math adds up. The consequence of inflated numbers is RFE, denial, or fraud referral.
A real-world example: principal Robert Kim of Skyline Infrastructure Regional Center reported 412 indirect jobs from a $32 million bridge project. He attached the IMPLAN run, the construction expenditure schedule, and the economist’s CV and methodology.
A common misconception is that construction jobs lasting under two years always count. They count only if the project’s total construction period is at least two years and the methodology supports it under Matter of Izummi and the USCIS Policy Manual.
Part 5: NCE and JCE Tracking
Part 5 lists each new commercial enterprise and each job-creating entity (JCE) the regional center sponsored. For each, you report the legal name, EIN, business activity, capital received, and jobs created.
The plain-English version: USCIS wants the full org chart of money flow. The consequence of hiding a JCE is termination and possible SEC enforcement action for material misstatement to investors.
A real-world example: principal Linda Ortiz of Desert Springs Regional Center listed two NCEs and four JCEs, including a hotel operator, a construction LLC, and two restaurant tenants, with capital and job figures for each.
A common misconception is that wholly-owned subsidiaries do not need separate disclosure. They do, because each entity has its own EIN, payroll, and job-creation footprint.
Part 6: Aggregate Petition Data
Part 6 totals every I-526 and I-829 filed, approved, denied, or withdrawn during the fiscal year, plus cumulative totals since the center’s designation. The numbers must reconcile to USCIS’s internal records, so pulling case status data for each investor before filing is essential.
The plain-English version: count carefully and expect USCIS to check. The consequence of mismatched numbers is an RFE that consumes weeks of staff time.
A real-world example: principal James O’Connor of Atlantic Maritime Regional Center reported 38 I-526 filings, 31 approvals, 4 denials, and 3 pending. He cross-checked each against USCIS receipt notices before signing.
A common misconception is that withdrawn I-526s do not count. They do, and Part 6 has a specific line for them.
Part 7: Principal’s Certification
Part 7 is the signature block. The principal certifies under penalty of perjury that the information is true, that the center is in compliance with securities laws, and that no material change has gone unreported.
The plain-English version: sign only what you have personally verified. The consequence of a false certification can include perjury charges, debarment, and SEC fraud action.
A real-world example: principal Susan Wright of Mountain West Regional Center refused to sign Part 7 until her economist re-ran the IMPLAN model and her CFO re-tied the capital figures to the bank statements.
A common misconception is that an attorney can sign Part 7. Only the principal of the regional center may sign.
Part 8: Preparer Information
Part 8 captures the attorney or paralegal who prepared the form, including the G-28 Notice of Entry of Appearance. The preparer’s signature does not transfer liability away from the principal but creates a paper trail USCIS uses if questions arise.
The plain-English version: name the preparer and attach the G-28. The consequence of skipping Part 8 when an attorney prepared the form is a procedural defect that can delay processing.
A real-world example: attorney Mark Stevens prepared the I-924A for Capitol Hospitality Regional Center and signed Part 8, while the principal Helen Park signed Part 7.
A common misconception is that Part 8 is optional. It is required if anyone other than the principal helped prepare the form.
Three Common Filing Scenarios
Below are three of the most common I-924A scenarios regional centers face, each with the action taken and the USCIS outcome that followed.
Scenario A: Active Center With Many Investors
| Filing Action | USCIS Outcome |
|---|---|
| Files I-924A by Dec 29 with full exhibits, IMPLAN report, and reconciled investor list | Accepted; center remains in good standing and appears on the public list |
| Reports 22 new I-526 filings, $17.6M deployed, 285 indirect jobs | No RFE issued; data feeds the USCIS annual report to Congress |
| Discloses one material change already amended via I-924 | USCIS notes the prior amendment and clears the file |
Scenario B: Dormant Center With No Investors
| Filing Action | USCIS Outcome |
|---|---|
| Files I-924A reporting zero capital and zero jobs for fiscal year 2021 | Accepted but flagged for two-year inactivity review |
| Files again the next year showing zero activity | Receives Notice of Intent to Terminate under 8 CFR § 204.6(m)(6) |
| Submits business plan showing future projects within 30 days | USCIS may withdraw the NOIT if the plan is credible |
Scenario C: Late Filing After the December Deadline
| Filing Action | USCIS Outcome |
|---|---|
| Misses Dec 29 deadline by 14 days | USCIS rejects the late filing and does not refund the fee |
| Receives Notice of Intent to Terminate within 60 days | Center has 30 days to respond with good cause |
| Cannot show agency error or extraordinary circumstance | Designation terminated; pending I-526s denied under Matter of Soffici |
Mistakes to Avoid
The following are the seven most common mistakes that get regional centers terminated or fined, drawn from USCIS termination notices and IIUSA compliance guidance.
- Missing the December 29 deadline, which leads to automatic rejection and Notice of Intent to Terminate.
- Filing I-924A when the RIA requires I-956G, which causes rejection and a missed deadline.
- Using a name or receipt number that does not match the original I-924 approval, which triggers a procedural rejection.
- Reporting escrowed funds as invested capital, which violates the at-risk rule from Matter of Izummi.
- Inflating indirect or induced jobs without an accepted economic methodology, which leads to RFE or fraud referral.
- Skipping the G-28 Notice of Entry of Appearance when an attorney prepared the form, which creates a procedural defect.
- Failing to disclose a material change such as new geography, new NAICS code, or new principal, which is a basis for termination.
Do’s and Don’ts
The following list captures the rules that experienced EB-5 counsel apply when preparing I-924A.
- Do reconcile every receipt number against USCIS case status before signing because mismatches cause rejection.
- Do retain a licensed economist to run IMPLAN or RIMS II job-creation models because USCIS requires an accepted methodology.
- Do file an I-924 amendment before the I-924A if you have any material change because Part 1 must match the underlying designation.
- Do keep a complete audit binder of bank statements, subscription agreements, and Form D filings because USCIS can demand evidence years later.
- Do calendar the December 29 deadline at least 90 days in advance because exhibit assembly always takes longer than expected.
The following are the most common don’ts that get filings rejected.
- Don’t sign Part 7 unless you personally verified every figure because the principal carries personal liability.
- Don’t treat zero-activity years as optional filings because USCIS still expects the form.
- Don’t rely on email confirmations from USCIS staff as deadline extensions because no informal extension exists.
- Don’t mix pre-RIA and post-RIA reporting categories because USCIS rejects hybrid filings.
- Don’t fund projects outside the approved geography because every related I-526 will be denied.
Pros and Cons of Filing I-924A vs. I-956G
The transition from I-924A to I-956G changed the compliance burden on regional centers in real ways, and understanding both forms helps clients pick the right path during transition years.
- Pro of I-924A: shorter form with fewer mandatory exhibits, which lowered preparation cost.
- Pro of I-924A: familiar to legacy centers with years of muscle memory built around the December 29 deadline.
- Pro of I-956G: aligned with RIA integrity measures, which strengthens program credibility.
- Pro of I-956G: requires fund administrator certifications, which protects investors from fraud.
- Pro of I-956G: integrates EB-5 Integrity Fund fee reporting, simplifying compliance.
The cons of each form are equally real and worth understanding.
- Con of I-924A: lacks RIA-mandated investor protections, which left gaps that bad actors exploited.
- Con of I-924A: no longer accepted for most current fiscal years, which creates rejection risk if filed by mistake.
- Con of I-956G: longer, more detailed, and costlier to prepare, which raises legal fees.
- Con of I-956G: requires fund administrator or audit certifications, which adds vendor cost.
- Con of I-956G: stricter penalties for material misstatement under the RIA, which raises litigation exposure.
Key Entities You Should Know
The EB-5 ecosystem is a web of agencies, statutes, and private actors that all touch the I-924A filing.
- USCIS Immigrant Investor Program Office adjudicates the form and manages regional center designations.
- The Securities and Exchange Commission polices fraud in EB-5 securities offerings tied to the centers.
- The Department of Justice prosecutes false certifications under 18 U.S.C. § 1001.
- IIUSA, the EB-5 industry trade association, publishes compliance guidance and aggregate data.
- The Bureau of Economic Analysis maintains RIMS II, one of the accepted job-creation models.
- IMPLAN Group LLC sells the IMPLAN economic model, the most common methodology used by EB-5 economists.
Each entity has a defined role, and the regional center principal must understand all of them because compliance failures with any one of them can cascade across the others.
Recap of Key Court Rulings
EB-5 compliance is shaped by Administrative Appeals Office (AAO) precedent decisions that bind USCIS adjudicators and influence every I-924A filing.
Matter of Izummi established that capital must be at risk and deployed, not merely escrowed, which directly drives Part 3 of the form. Matter of Soffici held that buying an existing business does not by itself satisfy job creation, which shapes how Part 4 is reported. Matter of Ho requires a comprehensive business plan with credible projections, which feeds the exhibits package every year.
These rulings are not optional reading. USCIS officers cite them in RFEs and termination notices, and ignoring them in your I-924A practically guarantees a problem.
FAQs
Is Form I-924A still required after the EB-5 Reform and Integrity Act?
No. Most regional centers now file Form I-956G instead. I-924A still applies to legacy fiscal years before the RIA transition and to centers correcting old filings.
Does a regional center with zero investors still have to file?
Yes. USCIS requires every approved center to certify annually, even with zero capital and zero jobs. Skipping a zero-activity year leads to a Notice of Intent to Terminate.
Is the December 29 deadline ever extended?
No. USCIS does not grant deadline extensions. Late filings are rejected, and the rejection counts as a missed filing under 8 CFR § 204.6(m)(6).
Can the immigration attorney sign the form?
No. Only the regional center principal may sign Part 7 under penalty of perjury. The attorney signs Part 8 as preparer with a G-28.
Does escrowed capital count as invested for Part 3?
No. Funds must be deployed and at risk in the new commercial enterprise to count, per Matter of Izummi.
Is the filing fee refundable if the form is rejected?
No. The USCIS fee is not refunded for rejection or termination. Refile with a new fee if rejection happens before the deadline.
Can a center change its geography on Form I-924A?
No. Material changes require an I-924 amendment filed and approved before the I-924A. Part 2 only confirms compliance with the existing designation.
Does USCIS audit I-924A filings?
Yes. USCIS conducts site visits and audits under the RIA. Centers must keep records for at least five years and produce them on request.
Can a terminated center be reinstated?
Yes, but rarely. Reinstatement requires a successful motion to reopen showing USCIS error or extraordinary circumstance, and most motions are denied.
Is Form I-924A available for online filing?
No. I-924A remains a paper filing mailed to the Immigrant Investor Program Office. USCIS has signaled future online filing for I-956G but not for legacy I-924A.
Does filing I-924A protect investors’ I-526 petitions?
Yes. A timely, accurate I-924A keeps the regional center in good standing, which is the legal foundation for every I-526 petition sponsored by that center.
Can a regional center file I-924A and I-956G in the same year?
Yes, but only during the RIA transition for fiscal year 2022. USCIS issued transition guidance explaining when both filings were required.
Related reading
- How to Fill Out USCIS Form I-924 (w/Examples) + FAQs
- How to Fill Out USCIS Form I-941 (w/Examples) + FAQs
- How to Fill Out USCIS Form I-956 (w/Examples) + FAQs
- How to Fill Out USCIS Form I-956F (w/Examples) + FAQs
- How to Fill Out USCIS Form I-956G (w/Examples) + FAQs
- How to Fill Out USCIS Form I-956H (w/Examples) + FAQs
- How to Fill Out USCIS Form I-821 (w/Examples) + FAQs