Can I use volunteers in my business to save on staffing costs?

Using volunteer labor to reduce staffing costs is generally not a sound strategy in the EB-5 program. The program’s core requirement is the creation of qualifying full-time jobs for workers in the United States, and that job creation must be demonstrated based on the actual structure of the business.

Volunteering, by its nature, typically does not produce the formal employment ties, payroll records, and continuity needed to establish that real jobs exist. Replacing paid positions with volunteers tends to undermine precisely the evidence that the business generated the required jobs.

In addition, the business’s hires must comply with U.S. labor law, which covers wages, hours, and worker protections. Building operations around unpaid labor can raise concerns both in the project review and in the credibility of compliance with program requirements.

• The EB-5 program focuses on the creation of formal, ongoing jobs, not on cutting staff costs.
• Volunteering generally does not establish the employment relationship the program requires.
• All hires must comply with applicable labor law.

If the goal is to optimize costs, the safe path is to explore alternatives that conform to program rules. It is worth checking the current requirements with USCIS and reviewing the business structure with a specialist before making any decisions.

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.