DOL Launches ‘Project Firewall’ – New H-1B Enforcement Initiative
Announced September 19, 2025
The U.S. Department of Labor (DOL) has launched Project Firewall, a nationwide initiative to increase oversight of the H-1B program. The goal is to protect U.S. workers while holding employers to stricter compliance standards. This marks one of the most aggressive enforcement actions in recent years.
What Project Firewall Does
- Protects U.S. Workers: Ensures that qualified Americans are considered first for highly skilled jobs.
- Raises Compliance Standards: Employers must strictly follow prevailing wage rules, ensure accurate job classifications, and align actual duties with what’s in the Labor Condition Application (LCA) and H-1B petition.
- Expands Enforcement: The Secretary of Labor can personally certify investigations if there is “reasonable cause” to suspect violations. Penalties may include back pay, fines, and debarment from the H-1B program.
- Increases Collaboration: The DOL will coordinate with the Department of Justice, EEOC, and USCIS to target fraud, discrimination, and abuse.
- Aligns with Administration Priorities: The initiative pairs with a new $100,000 H-1B supplemental fee announced in a presidential proclamation to reinforce tighter oversight.
What This Means for Employers
- Greater Scrutiny: Expect more frequent audits, data-sharing across agencies, and tougher reviews of H-1B petitions.
- Higher Costs: Employers face significant financial and administrative burdens, including possible penalties and the $100,000 supplemental fee.
- Need for Preparedness: HR and management teams must be ready to respond to investigations quickly and confidently.
Steps Employers Should Take Now
- Train HR/managers on H-1B compliance and audit response.
- Audit hiring practices, wage determinations, and job classifications.
- Confirm LCA postings and recordkeeping are complete at all worksites.
- Keep Public Access Files (PAFs) current and accessible.
- Organize payroll, job descriptions, and immigration records for rapid response.
What This Means for Foreign Nationals
- Stricter Oversight: Employers must follow compliance rules more carefully, which could delay or complicate petitions.
- Worker Protections: The initiative also enforces wage and anti-discrimination safeguards for H-1B workers.
- Indirect Impact: While Project Firewall targets employers, foreign nationals may feel the effects through longer processing times, stricter job documentation, and heightened scrutiny of roles.
Key Takeaway
Project Firewall signals a tougher regulatory environment for H-1B employers. Companies should act now to review compliance procedures, while foreign nationals should be prepared for stricter documentation and oversight.
The content of this article is intended only to provide a general guide to the subject matter. It should not be construed as legal advice. Please contact FGI at info@employmentimmigration.com or (+1) 248.643.4900 for guidance if you have specific questions.