On admission to the United States as a conditional permanent resident, or on the grant of adjustment of status. The petition to remove conditions is filed in the ninety days before the second anniversary of that date.
The date that matters is on the residence, not the investment
Hypothetical example: Xiomara, who owns a pharmacy near East Ferris, transferred her EB-5 capital in the spring and assumes the two-year period began then. It did not. The conditional residence period runs from the day she is admitted as a conditional permanent resident, or her adjustment of status is granted, which may be well over a year after the money moved.
That distinction shapes everything after it. Job creation is generally assessed against the conditional period, so a project already hiring may be further along than she expects and one that has not started is behind. The I-829 petition removing conditions is filed within the ninety days before the second anniversary, and missing that window creates problems a diary entry would have prevented.
Between the two dates she must keep the investment sustained and remain engaged in management or policy formulation, and she should gather the evidence of both as it accumulates rather than reconstructing it in the final quarter.