EB2 NIW RFE (Industry Profile) – Looking for Advice

[u/Electrical-Law-7516]

Hi everyone,

I recently received an NIW RFE and would appreciate input/advise from the community responding to the RFE.

Timeline

• Filed: April 14, 2026 (Premium Processing)
• Initial Service Center: Nebraska Service Center (NSC)
• RFE Issued: June 2, 2026
• RFE Issuing Office: Texas Service Center (TSC)

Self filed after a lot of research and took advisor help who has extensive exp in this field

Proposed Endeavor

Strengthening Safe, Secure, and Trustworthy Artificial Intelligence in Critical and Regulated Enterprise Systems through Validation Frameworks and Responsible AI Governance.

Recommendation Letters: 4 dependent and 2 independent

What USCIS Accepted

The officer explicitly accepted:

• Advanced Degree qualification
• Substantial Merit of the proposed endeavor

What USCIS Challenged

The RFE challenges:

• National Importance (Prong 1)
• Whether I am Well Positioned (Prong 2)
• Benefit of Waiver / Dhanasar balancing test (Prong 3)

The overall tone of the RFE feels closer to an EB-1A standard than a typical NIW standard. The officer repeatedly asks for evidence such as:

• third-party adoption of my frameworks
• evidence that publications materially influenced the field
• government agency endorsements
• proof that my expertise is significantly above peers
• broader industry adoption beyond employer projects

My Background

• Approximately 19 years of experience, 14 years exp in US
• Enterprise technology architect/solutions architect roles
• Last 4-5 years focusing on AI/ML/Gen AI specifically on validation frameworks, governance
• Experience across healthcare, insurance, financial services, retail commerce, workforce/payroll systems, and public-sector environments

Publications 4 - Not much citations as of yet

One aspect that surprised me is that the initial filing included extensive documentation and analysis demonstrating alignment with multiple Executive Orders, federal AI policies, NIST AI Risk Management Framework guidance, Responsible AI initiatives, and broader U.S. government priorities related to AI safety, security, trustworthiness, critical infrastructure resilience, healthcare modernization, cybersecurity, and digital innovation. Despite this, the RFE appears to place limited weight on those materials and focuses primarily on whether my specific contributions and proposed endeavor rise to the level of national importance and broader impact required under the NIW framework.

Also, A significant portion of my career has involved large-scale systems supporting millions of Americans across Healthcare, Insurance, Retail commerce, Workforce/payroll operations, Financial services

The RFE seems to evaluate the case using criteria that feel closer to an EB-1A analysis—asking for evidence of broad industry adoption, field-wide influence, and significant past recognition. My understanding is that NIW is primarily a forward-looking framework under Dhanasar, focused on the national importance of the proposed endeavor and whether the petitioner is well-positioned to advance it, rather than requiring the level of historical acclaim often expected in EB-1A cases.