Idk if your comment was bot/AI generated. Nevertheless, I'll reply:
1. Our web forms are exactly based on the official USCIS's PDF, with smart logic. If you fill A -> section B is hidden -> jump directly to section C (you get the point)
2. Regarding high risk: When a user fills our form, they get the official USCIS PDF filled. All the instructions are given in the PDF. At the end, the user has to submit the form by themselves.
3. "The "free alternative" positioning also creates a distribution problem..." "The people who most need this are the least likely to find a developer's side project on HN or GitHub" - you are right. I just shared what I'm building on HN. I share my project on immigration subreddits + FB groups. Thats where my audience is. So far, I've received positive review. In the long run, I'm leaning on: community + word of mouth + SEO
4. "..., but the actual competition is immigration attorneys at $2,000-5,000 and free legal aid clinics". Fillvisa is aimed at DIY applicants. People who need legal advise should absolutely hire legal help.
5. "One more operational risk worth flagging: USCIS revises forms regularly and without much warning..." - fillvisa.com is 100% free. That said, I'm also building a paid version (plus.fillvisa.com) for immigration lawyers/law firms. Both the apps utilize the same form + mapping. Thus that cares of revenue + I have incentive to maintain the forms.