There is no universal E-2 hiring quota. The enterprise must be more than marginal, and staffing is one part of the evidence about its operations and economic capacity. E-2 should not be assessed using EB-5’s job rules.
Build the case from the enterprise
Explain what work exists, who performs it and how the business can fund its operating model. Existing payroll, credible recruitment plans and supported revenue assumptions can help. Adding an arbitrary number of future employees does not prove non-marginality if the business lacks demand, resources or a realistic path to those hires.
Ask what the staffing picture will look like at each stage, not only at opening. There is no hiring quota to satisfy, and the enterprise must be more than marginal, which is a question about the operation and its economic capacity rather than a headcount to reach. Explain what work exists, who performs it and how the business funds its operating model, using existing payroll, credible recruitment plans and supported revenue assumptions.
Adding an arbitrary number of future employees demonstrates nothing where the business lacks the demand, the resources or a realistic path to those hires. Do not assess this classification using the job-creation rules belonging to a different immigrant category. Ask what the plan would look like if demand arrived later than forecast.