The lean, small-team model most tech startups aspire to is in direct tension with EB-5's job creation requirement. An EB-5 tech startup plan needs to commit to a genuinely larger direct-hire team than a typical venture-backed startup playbook would recommend at the same stage.
Engineering and Support Team as the Job Creation Base
Your job creation table should reflect a real organizational build-out — engineering, product, sales/marketing, customer support, and operations — sized to reach 10+ full-time direct positions within 24 months. This is a different staffing philosophy than "stay lean until product-market fit," and your plan should own that difference rather than trying to reconcile the two.
Direct Investment vs. Regional Center for Tech
Tech investments are sometimes structured through Regional Centers, which allows counting some indirect and induced jobs via economic modeling — but that requires a specialized econometric report a business plan narrative doesn't replace. If you're investing directly, default to counting only genuine W-2 positions on your own company's payroll.
Revenue Model and Job Creation Must Reconcile
Your financial projections need to support the payroll your job creation table implies. A startup projecting modest early revenue but claiming 10 immediate hires needs to explain the funding logic clearly — typically, this means your EB-5 capital itself is funding the team build-out directly, which should be stated explicitly in your capital deployment schedule.
IP and Technical Specificity
As with any tech business plan, describe your actual technology and its current stage of development specifically — generic descriptions of "innovative software" do not support the market analysis or investment credibility Matter of Ho requires.
This is a draft for your attorney's review before filing — not a legal document itself, and no outcome is ever guaranteed.