What’s Happening

In September 19, 2025, press release the Department of Labor (“DOL”) unveiled Project Firewall, an initiative aimed at strengthening enforcement of the H-1B visa program. According to the DOL, this effort will prioritize robust oversight of employer obligations under the H-1B framework, particularly those related to wages and working conditions as required by the Labor Condition Application (“LCA”) that must be filed with each H-1B petition where employers attest that they will offer the same wages, benefits, and working conditions to the H-1B employee as they offer to similarly situated U.S. workers.

While the DOL has long had the authority to investigate employer compliance, Project Firewall represents a renewed and more aggressive enforcement posture. The initiative is designed to improve worker protections and deter abuse of the H-1B system. 

Under Project Firewall, employers should expect increased audits and investigations related to H-1B wage practices and Labor Condition Application (LCA) compliance. Therefore, H-1B employers should undertake proactive compliance review of H-1B wage practices and documentation thereof, including Public Access Files, to mitigate risk, including potential fines, back wage liability, or even disqualification from the H-1B program.