Can affordable housing be an EB-5 project?

There is no reason why this could not work with a regional center, if it creates the necessary jobs. One issue is the program expires 9/2027 and grandfathering ends 9/2026 so unless the program is extended, this may be hard.

I don’t see why not if it creates the requisite new jobs, especially if located in a rural or high unemployment area.

Any business that can hire 10 full-time workers using your investment can qualify.

Yes, affordable housing can be an EB-5 project as long as it meets the core program requirements, which are that the investment must be made into a for-profit new commercial enterprise (NCE), the capital must be at risk, and the project must result in the creation of at least 10 full-time jobs per investor.
Importantly, if you your affordable housing project is not required to be a nonprofit entity, it may be able to qualify for EB-5 financing, particularly through regional centers using the loan model, where the EB-5 funds flow from the NCE into the project entity (JCE) as a loan. The exit strategy is also key. EB-5 loan terms are typically structured to allow for repayment after the investor’s sustainment period (usually after 2 years under the RIA) and once job creation requirements are met.
If this is a realistic possibility on the business side for you, then you may wish to consider an EB-5 capital raise.