DOL Launches Project Firewall: Here's What Employers Need to Know Now

On September 19, 2025, the U.S. Department of Labor (DOL) announced Project Firewall, a major enforcement initiative aimed at enforcing compliance within the H-1B visa program. The message to employers is clear: if you're sponsoring H-1B workers, now is the time to double-check your compliance.

What Is Project Firewall?

Project Firewall is designed to ramp up investigations into H-1B visa use, especially in cases where the DOL believes U.S. workers may be unfairly displaced. The initiative goes beyond routine audits: it includes Secretary-certified investigations triggered when there is "reasonable cause" to believe an employer is violating the rules.

The DOL isn't working alone. Project Firewall will involve coordination with the Equal Employment Opportunity Commission (EEOC), the Department of Justice Civil Rights Division, and U.S. Citizenship and Immigration Services (USCIS)…a multi-agency effort that reflects the seriousness of this push.

What’s at Stake?

Employers found in violation of H-1B requirements could face:

• Civil money penalties

• Back wage payments to affected workers

• Temporary debarment from the H-1B program

This initiative follows the DOL’s broader goal of ensuring highly skilled U.S. jobs go to American workers first and that H-1B visa usage does not suppress wages or displace domestic talent.

Key Compliance Reminders for H-1B Employers

If you currently employ H-1B workers or plan to, here are critical areas to revisit immediately:

• Wage Compliance:
  H-1B employees must be paid the higher of the prevailing wage or the actual wage paid to similarly qualified U.S. workers in a similar role.

• Notice Requirements:
  You must notify U.S. workers, through physical or electronic posting, of your intention to hire H-1B employees, as required by law.

• Public Access File:
  Maintain accurate and complete documentation, including:

  • Labor Condition Applications (LCAs)

  • Proof of wages paid

  • Evidence of meeting the notice requirements

  • Any supporting documentation required under H-1B regulations

• Policy Review:
  Ensure your internal practices and policies are fully aligned with federal H-1B rules. Spot checks and periodic audits are a smart strategy to stay ahead of enforcement.

Why This Matters

Project Firewall signals a heightened level of scrutiny, aiming to root out “fraud and abuse” in the H-1B visa system and to “ensure that highly skilled jobs go to Americans first.” Employers who get it wrong could face significant financial penalties and restricted access to future H-1B visas.

Looking Ahead

In addition to Project Firewall, recent announcements like the proposed $100,000 fee for new H-1B applications after September 21, 2025 have employers increasingly concerned about the future of the H-1B program. We’ll cover any updates on this front in future posts.

If you sponsor H-1B workers, don’t wait to get your compliance house in order. Project Firewall is here, and enforcement is ramping up. Ensure you’re not caught off guard.