Specific evidence

Organizational chart

Whether the chart accurately shows the structure at filing and matches the rest of the record.

What USCIS is questioning

High confidence Whether the chart shows the structure as it existed on the filing date, with names, titles and reporting lines.^[1,2]
High confidence Whether the people and positions on the chart match payroll, tax records and job descriptions.^[1,3]

The legal standard

The Policy Manual directs officers to review the totality of the evidence, including the duties of the beneficiary and subordinates, and to check that they correspond to their placement in the structural hierarchy.^[3]
High confidence Eligibility is judged as of filing, so a chart of a later structure doesn't establish it.^[1,2]

How the request usually reads

Interpretation RFEs often ask for brief job descriptions for the beneficiary's subordinates and contractors, and officers may ask for a description of the management structure with position descriptions; what counts is the structure in place at filing.^[1,3]

Evidence petitioners often provide

Interpretation A dated chart as of filing, with names, titles, reporting lines and whether each person is an employee or a contractor.^[1,2,3]
Interpretation Payroll and position descriptions that match the chart.^[3]

Where responses go wrong

High confidence Submitting a new chart in the RFE response that reflects changes after filing.^[1]
Interpretation Charts that list positions nobody fills, or omit people who appear in payroll or correspondence.^[1,4]

AAO decisions on this issue

AAO non-precedent decision, Form I-140 multinational manager or executive, In Re: 41372977 (Feb. 26, 2026)
A post-filing chart couldn't show eligibility, and inconsistencies between the charts, W-2s and email signatures went unresolved.
Matter of Chawathe, 25 I&N Dec. 369 (AAO 2010)
The petitioner must prove eligibility by a preponderance of the evidence; a material doubt justifies an RFE, and a denial only if the doubt leads the officer to believe the claim is probably not true.

This information is for general informational purposes and is not legal advice. It does not create an attorney-client relationship and does not predict the outcome of any individual case.

Sources

1.AAO non-precedent decision, Form I-140 multinational manager or executive, In Re: 41372977 (Feb. 26, 2026)USCIS Administrative Appeals Office · AAO decision · Published Feb 26, 2026 · Checked Sep 27, 2026
2.8 CFR 103.2 - Submission and adjudication of benefit requestseCFR (Office of the Federal Register) · Regulation · Checked Sep 27, 2026
3.USCIS Policy Manual, Volume 6, Part F, Chapter 4 — Multinational Executive or ManagerUSCIS · USCIS Policy Manual · Checked Sep 27, 2026
4.AAO non-precedent decision, Form I-140 multinational manager or executive, In Re: 39666475 (Oct. 7, 2025)USCIS Administrative Appeals Office · AAO decision · Published Oct 7, 2025 · Checked Sep 27, 2026
5.Matter of Chawathe, 25 I&N Dec. 369 (AAO 2010)USCIS Administrative Appeals Office (published in DOJ EOIR Virtual Law Library) · AAO decision · Published Oct 20, 2010 · Checked Sep 27, 2026