Can I be an unpaid volunteer manager and still have it count as involvement?

Yes, it can count. In the EB-5 program, what matters for establishing your involvement is not whether you receive a salary, but rather your active and demonstrable participation in the management and decisions of the enterprise. The absence of compensation, by itself, does not invalidate that showing.

The program expects the investor to play a real role in the business, whether through direct management or within the oversight structure. A purely symbolic title tends to be insufficient; what counts is the substance of your actual participation.

For that reason, document what you do carefully. Records that typically help include:

• meeting minutes and strategic decisions in which you took part;
• a description of the responsibilities you assumed on a day-to-day basis;
• communications and other evidence of ongoing involvement.

If your role as a volunteer manager is well substantiated, it reinforces the involvement requirement. Since each case has its own particulars, it is worth organizing that documentation with specialized support and reviewing the current USCIS guidance.

About the author

Victoria Harper

Editor-in-Chief

Meet the author

As a journalist and lead editor at Visto n’ Visa, Victoria helps ensure that immigration topics are covered in a clear, trustworthy, and easy-to-understand way. Her focus is on delivering useful, human, and relevant content for people exploring new paths abroad.