The employment creation requirements will depend on whether the investment is in a direct or Regional Center project. For instance, in a direct EB-5 project the jobs have to be full time not a combination of part time jobs. Furthermore the jobs have to be created during the two and a half period after the I-526 petition has been approved.
For direct jobs, this may be required, but in the regional center context, were indirect jobs can be counted, the specific indirect employee is not named when removing the conditions to permanent residency (I-829). We work closely with EB-5 economists to review the job creation requirements of projects we work with.