Previously, applicants in EB-2 China had seen slow but steady progression in priority dates, allowing some to file their I-485 adjustment of status applications. The current freeze means no new I-485 filings can be approved for applicants with priority dates after September 1, 2021, limiting the green card pipeline for many. USCIS’s policy framework under 8 CFR §204.5(k)(2) requires that final action dates must be current for approval, so the freeze effectively halts approvals in this category.
Additionally, investors who planned to use EB-2 NIW or EB-5 may consider the current EB-5 rural and infrastructure categories, which remain current for China-born applicants as of May 2026. This can be particularly advantageous given the EB-5 program’s recent enhancements and more flexible investment options. Our team recently helped an investor switch from EB-2 NIW to an EB-5 rural project, expediting the green card timeline.
Actionable steps include (1) verifying your priority date and visa bulletin monthly at travel.state.gov, especially Table A (Final Action Dates), to know when you can file or expect approval; (2) for those with priority dates near or before September 1, 2021, prepare your I-485 and supporting documentation to file promptly when dates advance; (3) assess eligibility for EB-1 categories or EB-5 options with your attorney to diversify your green card strategies.
From a policy perspective, the freeze likely reflects demand-supply dynamics and backlog management by the Department of State. While frustrating, it also underscores the importance of flexibility and multiple filing strategies. We advise clients not to wait passively but to actively pursue parallel tracks where possible. For example, an L-1 intracompany transferee might consider EB-1C to avoid EB-2 bottlenecks, while H-1B holders might look at O-1 or L-1 alternatives as bridges.
Data Sources:
- Visa Bulletin, May 2026, U.S. Department of State [1]
- USCIS Policy Manual, 8 CFR §204.5(k)(2) [2]
[1] travel.state.gov [2] uscis.gov
