EB-5 NPRM 2026: The Proposed $1.4M Threshold Explained, and Why Caribbean CBI Is Worth Considering Now

The US Department of Homeland Security published a landmark Notice of Proposed Rulemaking (NPRM) on 2 July 2026, proposing to fundamentally restructure the EB-5 Immigrant Investor Programme's investment thresholds. Under the proposal, all investors, regardless of whether their project sits in a Targeted Employment Area, would face a single, unified threshold of $1,400,000. This represents a 75% increase for the most common TEA pathway, currently priced at $800,000.

For the 250+ families Mirabello Consultancy has guided through investment migration, with an IMC membership, ACAMS certification, and 99% approval rate from our Zurich and Dubai offices, the NPRM creates two clear signals: first, that EB-5 is entering a period of genuine regulatory uncertainty; and second, that Caribbean Citizenship by Investment at $200,000-$250,000 with 3-6 month processing has never been a more rational alternative to consider in parallel.

Weighing EB-5 against Caribbean CBI? Book a free consultation with Mirabello Consultancy, our IMC-qualified specialists assess your eligibility, timeline, and goals at no cost.

What Is the EB-5 NPRM That DHS Published on 2 July 2026?

The EB-5 NPRM (Federal Register 2026-13392, published 2 July 2026) is a formal Notice of Proposed Rulemaking in which the US Department of Homeland Security proposes raising the EB-5 Immigrant Investor Programme's investment threshold to $1,400,000 across all project categories. A 60-day public comment period closes 31 August 2026; the proposed rule has not yet taken legal effect.

NPRM stands for Notice of Proposed Rulemaking, the mechanism US federal agencies use to signal intended regulatory changes and collect public comment before finalising a rule. The proposal does not immediately alter the thresholds currently in force. Any investor who filed an I-526E petition before a Final Rule takes effect continues under the rules that applied at the time of filing.

The EB-5 programme was established under the Immigration Act of 1990 and last reformed by the EB-5 Reform and Integrity Act of 2022, which set the current two-tier threshold structure ($800,000 TEA / $1,050,000 standard). The July 2026 NPRM is the first proposed threshold revision since that reform.

Key proposed changes in the 2026 NPRM include:

• Elimination of the TEA two-tier system: all routes unified at $1,400,000
• Standard threshold: from $1,050,000 to $1,400,000 (+33%)
• Targeted Employment Area (TEA) threshold: from $800,000 to $1,400,000 (+75%)
• Infrastructure project rate: aligned to the new unified standard
• Regional centre annual compliance fee revisions: proposed alongside threshold changes

Public comments must be submitted by 31 August 2026 via Regulations.gov (Docket USCIS-2026-0012). Comments are open to any party, investors, immigration attorneys, regional centres, trade bodies, and advisory firms worldwide. The USCIS EB-5 Immigrant Investor Program page provides the official programme overview and current application guidance.

What Investment Amounts Are Being Proposed Under the 2026 EB-5 NPRM?

The 2026 EB-5 NPRM proposes a single unified investment threshold of $1,400,000 for all investors, abolishing the discounted $800,000 Targeted Employment Area (TEA) rate. This is a 75% increase for TEA investors, the most widely used route, and a 33% rise for the existing $1,050,000 non-TEA standard. Investors with petitions already filed at the current thresholds are unaffected.

DHS cites CPI inflation adjustment and programme integrity as the rationale for the proposed increase. Critics in the immigration bar have noted that the proposed $1.4M overstates the inflation-adjusted figure since the 2022 reform. Others argue that abolishing the TEA discount removes a deliberate policy tool intended to direct investment capital towards underserved communities, the original legislative intent of the TEA provision.

From a pure investor standpoint, the proposal changes the EB-5 value proposition materially: a $1.4M commitment with a 2-5 year I-526E adjudication timeline is a fundamentally different calculation than the current $800,000 TEA route.

When Would the Proposed $1.4M EB-5 Threshold Take Effect?

If the DHS NPRM is finalised after the 31 August 2026 comment deadline, the new $1.4M threshold would typically take effect 60-90 days after the Final Rule is published in the Federal Register, placing the earliest possible effective date at Q1 2027. All I-526E petitions filed before that effective date are governed by the thresholds in force at the time of filing.

The standard federal rulemaking timeline runs as follows:

1. NPRM published in Federal Register, 2 July 2026 (complete)
2. Public comment period closes, 31 August 2026
3. Agency reviews comments, prepares Final Rule, typically 3-9 months post-comment
4. Final Rule published in Federal Register, estimated Q4 2026 to Q2 2027
5. Effective date (60-90 days post-publication), estimated Q1-Q3 2027

Regulatory uncertainty is the operative risk here. Investors in the planning phase, who have not yet filed an I-526E, face a genuine decision: file at the current $800,000 TEA rate and lock in existing rules, or wait and risk filing under $1,400,000 if a Final Rule takes effect before they are ready. Given EB-5's notoriously long adjudication backlogs (I-526E petitions currently take 2-5 years), the compounded cost of delay makes the timing decision material.

There is also a non-trivial probability that the proposed rule is modified or withdrawn following the comment period. The EB-5 industry has consistently pushed back against threshold increases, and the elimination of the TEA discount is particularly contentious. Investors should not assume the $1.4M will be the final number, but they also cannot assume it will not.

Who Is Most Affected by the Proposed EB-5 Threshold Change?

The proposed $1.4M EB-5 threshold primarily impacts middle-tier high-net-worth investors who currently qualify under the $800,000 TEA route but would be priced out at $1,400,000, investors from high-demand nationalities already facing severe priority date retrogression, and investors in the active research or pre-filing phase who now face a race against the regulatory clock.

The five investor profiles most directly affected:

• TEA investors with $800K-$1.2M in investable capital: The most impacted group. Many qualified for EB-5 specifically through the TEA discount; the proposed elimination prices them out entirely.
• Chinese, Indian, and Vietnamese nationals: Already face 5-20+ year priority date backlogs due to per-country visa caps. A 75% cost increase compounds an already compromised proposition.
• US-based investors and business owners seeking a Plan B passport: Those evaluating EB-5 as a way to hedge residency will reassess whether $1.4M makes sense against Caribbean CBI at $200,000-$250,000.
• Investors with pending I-526E petitions already filed: These investors are unaffected, their applications are locked in at the threshold current when filed. No action required.
• Investors in research or planning phase: Facing genuine time pressure. Filing under current rules before a Final Rule takes effect may be strategically preferable, but requires verifying readiness and capital availability on an accelerated timeline.

Importantly, the NPRM does not change EB-5 for investors who have already committed. For those still evaluating, however, the proposal introduces a clear strategic fork: move now under existing rules, or pivot to alternative routes.

Why Are Investors Considering Caribbean CBI Whilst EB-5 Settles?

Caribbean Citizenship by Investment delivers a second passport and full citizenship in 3-6 months for $200,000-$250,000, without regulatory uncertainty, priority date backlogs, or multi-year adjudication. For investors who need a second passport now, not in 2027-2028, Caribbean CBI is structurally complementary to EB-5 planning and, in many cases, superior to waiting for EB-5 rules to stabilise.

Caribbean CBI does not replace EB-5 if permanent US residency is your primary objective, EB-5 remains the principal investment pathway to a US Green Card. What Caribbean CBI offers is a fast, cost-efficient, and certain complement: a second passport with global mobility delivered in months, whilst EB-5 planning continues on its own timeline. For many investors, holding both is the rational strategy.

Not sure whether to run Caribbean CBI alongside EB-5 or instead of it? Get a free programme assessment from Mirabello Consultancy, we advise the full spectrum of investment migration options, including dual-track strategies.

What Is the Grenada E-2 Treaty and Why Does It Matter for US Investors?

Grenada has an active E-2 Treaty of Commerce and Navigation with the United States, meaning Grenadian citizens, including those who obtained citizenship through Grenada's CBI programme, can apply for US E-2 non-immigrant visas. This allows Grenada passport holders to invest in and manage a US enterprise and reside in the USA on a renewable basis, without requiring a Green Card or EB-5 status.

The E-2 investor visa is a US non-immigrant category available to nationals of treaty countries who invest a substantial amount in a bona fide US enterprise and manage it actively. Unlike EB-5, which delivers lawful permanent residency, the E-2 is a non-immigrant status, but it is renewable indefinitely so long as the investor maintains and manages the business, and it extends to the investor's spouse (who can obtain work authorisation) and unmarried children under 21.

For investors researching EB-5, the Grenada E-2 combination offers a structurally distinct alternative worth modelling:

• Total upfront cost: Grenada CBI from $235,000 (National Transformation Fund) + a qualifying US business investment (amount varies; no fixed minimum, must be substantial relative to the business). Combined cost is typically well below $800,000, and far below the proposed $1,400,000.
• Speed: Grenada citizenship in 3-6 months; E-2 visa application processed separately by a US consulate in 3-6 months after. Total path to US business presence: under 12 months in most cases.
• Global mobility: Grenada passport grants visa-free or visa-on-arrival access to 140+ countries, including all Schengen Area nations. Unlike a US Green Card, you are not obliged to maintain a US domicile, travel freely whilst operating a US business.
• No priority date retrogression: Grenada is not a high-demand E-2 nationality. No backlog, no wait.
• Renewable indefinitely: The E-2 does not expire so long as the underlying business and investment remain active.
• Not a path to a US Green Card: The E-2 is non-immigrant status, it does not create a direct route to LPR. Investors who need a Green Card still need EB-5 or an alternative immigrant visa category. But for those who want a US business presence without the Green Card commitment, E-2 is often the right tool.

Grenada is the only Caribbean CBI programme with an active E-2 treaty with the USA, St Kitts, Dominica, St Lucia, and Antigua do not offer this route. This makes the Grenada CBI programme distinctly compelling for US investors and entrepreneurs who want US access and global mobility without committing to the EB-5 pathway.

Which Caribbean CBI Programme Is Best for EB-5 Researchers in 2026?

The best Caribbean CBI programme for an investor researching EB-5 alternatives in 2026 depends on their primary objective. For US business access via the E-2 treaty, Grenada ($235,000) is the clear choice. For the lowest investment and fastest processing, Dominica ($200,000) leads. For the strongest passport and longest track record, St Kitts and Nevis ($250,000) is the market standard. All four programmes are ECCAS ECCIRA members and operate under new residency requirements live from 1 July 2026.

Grenada, from $235,000
The only Caribbean CBI programme with an active US E-2 treaty. Grenada passport: 140+ countries visa-free including Schengen. Processing: 4-6 months. E-2 application follows citizenship approval. Ideal for: US entrepreneurs, investors seeking US business access without EB-5 commitment.

St Kitts and Nevis, from $250,000
The world's oldest CBI programme, established 1984. Consistently ranked among the most powerful Caribbean passports. Visa-free to 150+ countries. Processing: 3-6 months. Accelerated Application Programme (60-day) available. Ideal for: investors prioritising programme pedigree and passport strength.

Dominica, from $200,000
Lowest entry point across all ECCIRA programmes. Well-established programme with strong IMC oversight. Processing: 3-4 months. Note: US B-1/B-2 visa for Dominica passport holders is currently restricted to 3 months single-entry, Mirabello advisers can explain what this means for your travel profile before you proceed.

St Lucia, from $240,000
Competitively priced, growing programme. Visa-free to 145+ countries including Schengen. Processing: 3-5 months. Strong choice for investors who want a Schengen-access passport at a mid-range price point without the Dominica US travel nuance.

All ECCIRA programmes introduced mandatory residency requirements from 1 July 2026: a minimum of 5 days in the country in year one, rising cumulatively to 30 days over 5 years, plus an orientation programme. These requirements are manageable for international investors and do not change the fundamental appeal of Caribbean CBI as a rapid second citizenship route.

Review the full landscape at Mirabello's Best Citizenship by Investment Programmes guide.

What Do Investors Most Commonly Ask About the EB-5 NPRM 2026 and Caribbean CBI?

What is the current EB-5 investment threshold in 2026?

In 2026, the current EB-5 investment thresholds are $800,000 for investments in Targeted Employment Areas (TEAs) and $1,050,000 for standard (non-TEA) projects. These rates were established by the EB-5 Reform and Integrity Act of 2022. The July 2026 NPRM proposes raising both to $1,400,000, but this proposal is not yet in effect, the comment period closes 31 August 2026, and a Final Rule would take additional months to implement.

Does the 2026 EB-5 NPRM affect I-526E petitions already filed?

No, the proposed $1.4M threshold applies only to new I-526E petitions filed after the effective date of a Final Rule. All petitions filed before that date are governed by the thresholds in force at the time of filing. If your petition is already filed at $800,000 or $1,050,000, the proposed increase does not affect your application. No action is required for existing applicants.

Can a US citizen hold dual citizenship through Caribbean CBI?

Yes. US citizens can legally hold dual citizenship in all five ECCIRA Caribbean CBI countries, Grenada, St Kitts and Nevis, Dominica, St Lucia, and Antigua. Caribbean CBI delivers a second passport in 3-6 months from $200,000. Caribbean CBI does not affect US citizenship or confer US residency, but Grenada's active E-2 treaty with the USA provides a separate pathway to live and work in the USA as a Grenadian citizen.

What is the Grenada E-2 visa and how does it differ from EB-5?

The Grenada E-2 is a US non-immigrant visa available to Grenada citizens who invest in and manage a US enterprise. It is renewable indefinitely while the business remains active, and extends to the investor's spouse and children. Unlike EB-5, the E-2 does not lead directly to a US Green Card or lawful permanent residency, but it is faster, substantially less costly, and carries no priority date backlog. Grenada citizenship ($235,000, 3-6 months) is the gateway to E-2 eligibility.

How Do I Start with Mirabello Consultancy?

Book a free initial consultation at mirabelloconsultancy.com/contact-us-for-your-free-consultation. Mirabello Consultancy is an IMC-accredited investment migration adviser with a 99% approval rate, 250+ CBI cases successfully completed, and offices in Zurich and Dubai. Our specialists will assess your nationality, family profile, capital, goals, and advise whether Caribbean CBI, EB-5 planning, a combined dual-track strategy, or another route best serves your objectives. There is no fee for the initial consultation.