Why is the leading role most often not counted?

Key answer

Two reasons repeat across the parsed notices: the role is not shown to have been leading or critical - a title does not establish it - and the organisation's distinguished reputation is not documented against comparable entities. Across 1242 AAO decisions the criterion was counted in 41% of the cases where it was claimed: of 624 such cases it survived in 256.

Breakdown from the data

The answers below are translated from the original Russian - the language of the community chats.

The first reason is substituting a title for a role. A list of duties describes what you were assigned; the criterion asks what turned on you.
The second is the forgotten half. The organisation's reputation is proven separately and by comparison, and in petitions that block is often missing entirely.
A third, not stated outright but visible in the texts: the evidence comes from inside the company. Your own deck, your manager's letter and the website blurb are one side speaking, and an officer weighs them accordingly.
And the one common to every criterion: an assertion with no document attached is not evidence. It is among the most-cited lines in the notices.

This breakdown is built on real USCIS notices and public sources, linked below. It is reference material, not legal advice: officers decide similar cases differently.

How it reads in the notice

The analysis of this criterion almost always runs in one order. First the officer restates what you asserted. Then notes which documents support it. Then names what is missing - and here one of two formulations appears: the role is not shown, or the organisation's reputation is not documented.

If a citation stands nearby saying that going on record without supporting documentary evidence does not meet the burden of proof, the objection is to missing exhibits rather than to their content. That is good news: such a request is closed with documents you probably already hold.

It is worse if the officer notes a discrepancy - different dates or titles across documents. Then the reliability of everything else is in question, and the answer cannot be confined to this criterion.

What to do in the response

Answer the half that was named. If the objection is to the role, file the org chart, the appointment orders, the minutes and the contracts; if to the organisation, an independent ranking, the company's awards, coverage about it and letters from outside parties.

Replace characterisation with consequence. Instead of "led the direction" - what was launched, when, with what result, and who confirms it from outside.

Go through the rest of the packet and resolve discrepancies with a document, not an explanation. Put dates, titles and figures into one table and file it.

And judge honestly whether this criterion is worth defending at all. If there is no external corroboration for either the role or the organisation, the effort pays off better elsewhere - a weak criterion adds no weight but does supply material to argue with.

Why "Leading role" gets refused

Accepted in 23% of challenged petitions (51 of 222); not an approval rate.

The role is not shown to have been leading or critical. A job title does not establish it: what turned on you personally has to be visible.

All refusal grounds and the sample

Sources

All questions on: Leading role All questions on: EB-1A All questions on: RFE and denials All questions on: The petition and formatting