How can the EB-5 project create the required jobs?

For an EB-5 direct investment, only new jobs created as a result of your capital qualify toward the job creation requirement; any preexisting positions at the hotel would not count. You must create at least 10 new full-time positions for U.S. citizens, lawful permanent residents, or other authorized immigrants (excluding the investor and their immediate family). These roles need to be permanently created and are expected to be ongoing rather than seasonal or intermittent. While the jobs can be generated at any point during the renovation or expansion, they must be in place by the time you file to remove conditions on your residency (Form I-829). The requirement is for job creation, not that the same individuals occupy the roles continuously, as long as the roles themselves remain filled on a permanent basis​​.

They should have a detailed business plan and economic studies to show the jobs that would be created by the project. You should definitely ask about this before investing.

In direct EB-5 cases (as opposed to the regional center cases), the New Commercial Enterprise (the NCE) has to create 10 new jobs directly by hiring employees on its payroll. The qualifying employees can be any US citizen, permanent resident, or any other immigrant lawfully authorized to work in the U.S. (not including you or your family members working for the NCE). Different people can be working for the same role, as the jobs are counted by positions created (which can be occupied by different people over time).

To meet the EB-5 job creation requirements, the project must create at least 10 full-time jobs for U.S. workers. Here are the key points regarding job creation for an EB-5 project:
• New Jobs Requirement: The jobs created must be new. For a hotel
renovation and expansion project, this means that the investment should
result in the creation of at least 10 new full-time positions.
• Timing of Job Creation: The jobs can be created at any point during the
project, but they must be expected to last at least two years. The business
plan submitted with the Form I-526 petition should demonstrate a likelihood
of job creation within the next two years.
• Job Continuity: It is not necessary for the same individuals to hold the
jobs throughout the two-year period. The requirement is that the positions
themselves are maintained as full-time jobs, not that the same employees
occupy them.
• Hiring Individuals in the Naturalization Process: Jobs created by the
EB-5 project can be filled by U.S. citizens, lawful permanent residents, or
other immigrants lawfully authorized to work in the U.S., including those
going through the naturalization process. However, the positions cannot be
filled by the EB-5 investor, their spouse, or their children.