U.S. Launches Project Firewall to Expand H-1B Enforcement

(UNITED STATES) The U.S. Department of Labor launched Project Firewall on September 19, 2025, a sweeping enforcement drive aimed at employers that sponsor workers under the H-1B program and the foreign nationals employed on those visas. The initiative seeks to step up oversight, root out abuse, and ensure that highly skilled jobs are protected for U.S. workers. It also marks the first time the Secretary of Labor will personally certify investigations when there is “reasonable cause” to believe an employer broke H-1B rules.

The Department of Labor (DOL) said Project Firewall is already in effect and will expand the government’s ability to respond to complaints, audit employers, and coordinate with other agencies. According to analysis by VisaVerge.com, the program signals a major shift in enforcement intensity, especially for large H-1B employers in the IT and outsourcing sectors and for workers from India, who historically account for about 70% of H-1B recipients.

Policy Details and Enforcement Priorities

Under Project Firewall, the DOL can open Secretary-certified investigations into several types of violations. The list focuses on behavior that harms both U.S. and H-1B workers and undermines program integrity:

• Wage underpayment or wage theft
• Displacement of U.S. workers by H-1B hires
• Fraudulent labor condition applications (LCAs)
• Misrepresentation of job duties or worksite locations

Employers found in violation may face a range of penalties designed to change conduct quickly. Those penalties include:

• Civil fines
• Payment of back wages to affected workers
• Temporary bans on filing future H-1B petitions

The DOL will share data and coordinate enforcement with the Department of Justice (DOJ), Equal Employment Opportunity Commission (EEOC), and U.S. Citizenship and Immigration Services (USCIS). The initiative is led by the DOL’s Office of Immigration Policy, the Employment and Training Administration, and the Wage and Hour Division.

Workers and employers seeking compliance help can contact the Wage and Hour Division at 1-866-4-US-WAGE (487-9243).

Important: Project Firewall became effective immediately on September 19, 2025. That same day, the White House announced a new $100,000 H-1B application fee under the Trump administration. While the DOL has not confirmed whether the announcements were coordinated, the timing reflects strong political pressure to tighten oversight of high-skilled immigration and to protect American jobs.

For detailed federal guidance on H-1B worker protections and employer obligations, consult the DOL’s Wage and Hour Division resource page: U.S. Department of Labor – H-1B Program.

Impact on Employers

Project Firewall places immediate pressure on employers that rely heavily on H-1B talent, especially those in the IT and outsourcing space.

• Expect more document requests, site reviews, and cross-agency checks.
• Payroll records, LCAs, and contracts tied to worksite locations will receive closer scrutiny because of the enforcement focus on wage theft.
• Employers found to have displaced U.S. staff or misrepresented job duties can expect swift penalties, including back-pay orders and temporary bans that halt future H-1B hiring.

The DOL’s personal certification of investigations by the Secretary raises the stakes for employers because it signals senior oversight at the outset. The department’s use of existing authority also means Project Firewall can move quickly without waiting for new legislation.

Practical takeaways for employers:

1. Keep payroll records aligned with certified wage levels.
2. Ensure LCAs reflect the actual job duties and worksites.
3. Review vendor and client contracts to confirm job descriptions and locations match filed information.
4. Expect increased data-matching between agencies — discrepancies may lead to penalties.

Industry observers expect the heaviest scrutiny on companies that file large volumes of H-1B petitions, including major IT service providers and outsourcing firms. According to VisaVerge.com, these employers may need to invest in stronger internal audits and compliance tools to reduce risk.

Impact on H-1B Workers

Foreign nationals working on H-1B visas—especially those from India—could experience both disruption and protection.

• Risks:
  • Tougher checks may disrupt assignments, particularly in third-party placement settings.
  • Project reviews could delay project starts if an employer comes under audit.
• Benefits:
  • Stronger action against wage theft and misrepresentation can protect lawful workers who are underpaid or misclassified.
  • Affected workers who believe they are owed back wages can contact the Wage and Hour Division for confidential guidance at 1-866-4-US-WAGE (487-9243).

Practical guidance for workers:

• Keep copies of job offer letters, pay stubs, LCAs posted at worksites, and any communications that describe job duties and locations.
• These documents can be crucial if wage theft is suspected or if the filed worksite does not match actual assignment locations.

Broader Federal Context

Project Firewall launches alongside other federal actions that increase H-1B oversight:

• A Department of Homeland Security final rule effective January 17, 2025, increased anti-fraud steps, required stricter employer attestations, and expanded site visits and compliance checks — particularly for third-party placements.
• On September 19, 2025, President Trump issued a proclamation restricting entry of certain H-1B nonimmigrants and clarifying the scope of the new $100,000 fee.

While the DOL has not formally linked Project Firewall to those actions, together they create a period of high-intensity H-1B oversight.

Compliance Focus: Wage Theft and Location-Based Rules

In a climate of heightened scrutiny, enforcement on wage theft may be the most visible change day-to-day.

• Underpayment cases hinge on exact pay rates, hours, and location-based wage requirements.
• Even small discrepancies can trigger a review under Project Firewall, with back-wage orders possible if violations are found.
• Employers that operate across multiple client sites must verify that project documents, timesheets, and assignment letters remain current and accurate.

Key Message and Recommendations

The DOL’s position is straightforward: if there is reasonable cause to believe an employer broke the rules, the department will act—backed by data-sharing with DOJ, EEOC, and USCIS.

For employers:
– The safest path is rigorous compliance: up-to-date payroll records, accurate LCAs, and aligned worksite/job descriptions.

For H-1B workers:
– Use the Wage and Hour Division as a direct channel to address wage theft and misrepresentation without waiting for broader policy changes.

Key contact: Wage and Hour Division — 1-866-4-US-WAGE (487-9243)

For federal guidance, see: U.S. Department of Labor – H-1B Program.