The actual function-manager criteria matter, not a universal headcount. Establish the essential function, senior role, discretion and primarily managerial work.
Distinguish management from personal delivery
Explain who performs ordinary tasks and what decisions the applicant makes about the function. A person cannot establish this account merely by renaming their own production work. Use the operational reality, including work performed by other teams, and independently document the qualifying organizations and foreign employment. Lack of many direct reports is not itself the complete eligibility answer.
A first review should produce a short eligibility map that marks facts already proved, facts needing a primary record, and facts that cannot be solved by a job title. Check the qualifying relationship and the continuous qualifying foreign year within the preceding three years separately from the proposed role. The seven-year L-1A ceiling may change the business decision even where the role evidence is persuasive. Hypothetical example: a manufacturer of specialty microphones moves a product director who still approves every daily repair.
The decision is to resolve any missing eligibility fact before presenting the role as settled.