Project Firewall Intensifies H-1B Oversight: What Employers Should Know

The U.S. Department of Labor’s Project Firewall, launched in September 2025, marks one of the sharpest shifts in how the federal government polices the H-1B program in many years. For the first time, the Secretary of Labor can personally authorize proactive investigations into H-1B employers based on “reasonable cause” alone, without any complaint from a worker, competitor, or whistleblower.

This change allows the Department of Labor (DOL) to open broad compliance reviews of wage practices, Labour Condition Applications (LCAs), job duties, and complex contractor arrangements simply because patterns in the data raise concerns. For employers that rely on skilled foreign workers—and for thousands of international professionals and students who depend on H-1B status—Project Firewall raises both the enforcement stakes and the day‑to‑day need for strict compliance.

Expanded enforcement powers under Project Firewall

Under earlier practice, most DOL investigations into H-1B employers started with a complaint: a worker claimed they were underpaid, a competitor alleged unfair use of cheap labor, or another party came forward with specific allegations.

Project Firewall breaks that model. The DOL no longer has to wait for someone to file a formal complaint. Instead, the Secretary of Labor can certify investigations based on “reasonable cause,” which can include indicators such as:

• Unusual patterns of offsite placements or third‑party contracting
• Wage levels that look inconsistent with required standards
• A very high ratio of H-1B workers compared to U.S. workers
• Questionable job descriptions or positions that do not appear to match market norms

According to the source material, roughly 200 investigations are already underway under Project Firewall. That sends a clear signal: this is not a theoretical tool for future use. It is already active, and employers are already under review.

The DOL has emphasized coordination with other federal agencies, including USCIS, the Department of Justice (DOJ), and the Equal Employment Opportunity Commission (EEOC). Through Project Firewall, interagency data sharing can flag employers whose paperwork with USCIS does not match wage or job information available to the DOL, or whose hiring patterns raise concerns about discrimination or displacement of U.S. workers. The ability to cross‑check information across agencies makes it harder for employers to hide inconsistent practices.

What DOL investigators are looking at

Project Firewall gives the DOL wider authority to look beyond the four corners of an H-1B petition and into how a company actually runs its workplace. Primary areas of focus include:

• Wage practices
  • Are H-1B workers being paid at least the wage listed in the LCA and required under law?
  • Are there unpaid “bench” periods when workers are between projects?
• Public access files and LCAs
  • Are Labour Condition Applications complete, accurate, and consistent with actual job conditions?
  • Is the required public access file available and up to date?
• Job descriptions vs. real duties
  • Do day‑to‑day tasks match the job description filed with the LCA and H-1B petition?
  • Has the role shifted to different duties or a different level of responsibility without updates?
• Complex contractor and offsite arrangements
  • Are H-1B workers placed at client sites through multiple layers of vendors, making it difficult to track who controls the work and who is responsible for compliance?

Investigators can also examine overall workforce composition, especially when a company appears to be H-1B‑dependent—that is, having a high share of H-1B workers compared to U.S. workers. While the term is defined in regulations, the practical point is simple: the more a business leans on H-1B hiring, the more closely Project Firewall may examine its practices.

Potential consequences of violations

The potential consequences are serious and already-existing enforcement tools are now more likely to be used:

These penalties are not new, but Project Firewall increases the probability that the DOL will pursue them because investigations can be initiated proactively.

For official background on H-1B obligations and wage rules, employers and workers can refer to the Department of Labor’s H-1B information page on the Wage and Hour Division site at https://www.dol.gov/agencies/whd/immigration/h1b.

Why the focus on Labour Condition Applications and public files

The Labour Condition Application (LCA) is central to H-1B compliance. Before an H-1B petition is filed with USCIS, an employer must submit an LCA to the DOL stating the job title, location, prevailing wage, actual wage to be paid, and key attestations about working conditions.

Once certified, the LCA is the foundation for the H-1B petition and later compliance checks. Under Project Firewall, DOL investigators are paying closer attention to:

• Whether the wage level on the LCA matches what the employer actually pays
• Whether the work location on the LCA matches where the employee actually works (including remote and offsite work)
• Whether changes in job duties, promotions, or moves to new client sites are properly reflected in updated LCAs where required

The LCA also feeds into the public access file, which employers must make available for inspection. Investigators can quickly spot red flags by comparing public access file documents, internal payroll records, and the job description used in the H-1B petition.

According to analysis by VisaVerge.com, Project Firewall is already prompting companies to overhaul internal systems around LCAs and public access files, because any mismatch between paperwork and practice can trigger deeper questions during an audit.

While the LCA itself is filed through the DOL’s online system, workers and employers who want to understand these obligations can review official LCA guidance through the DOL, which explains what must be included in the file and how wage levels are set.

How employers are responding to Project Firewall

For employers that depend on the H-1B program to fill specialized roles, Project Firewall is pushing compliance to the top of the agenda. Many organizations are taking these steps:

• Conducting internal audits of wage payments, LCAs, and public access files
• Reviewing job descriptions and comparing them to actual duties and performance reviews
• Checking whether offsite placements and client‑site arrangements match positions and locations listed in LCAs
• Training HR and legal teams to track changes in duties, promotions, or transfers that might require updated filings

The scrutiny goes well beyond simple filing errors. An employer might have perfect paperwork yet still face risk if a worker is doing a different job than described or being paid less after a change in assignment. The DOL’s authority to examine real‑world conditions makes it harder to treat the H-1B process as a one‑time paperwork task.

Non‑compliance can have serious business consequences beyond fines and back wages, including:

• Legal liability from affected workers
• Loss of ability to hire H-1B workers, disrupting projects and business lines
• Competitive harm for sectors reliant on international talent (technology, consulting, outsourcing)

Employers classified or perceived as H-1B‑dependent face especially high pressure. Their workforce mix is likely to draw attention, and any evidence of displacement of U.S. workers or wage undercutting can lead to more intense investigations.

Impact on H-1B workers, students, and global professionals

For H-1B visa holders, applicants, and international students hoping to move into H-1B status, Project Firewall means their employer’s compliance is now even more tightly tied to their own immigration future.

Key impacts include:

• If an employer is audited and found non‑compliant, the DOL can order back wages or other remedies. In serious cases, information may be shared with USCIS, which can review or revoke H-1B approvals.
• Workers may face visa disruptions if their employer is debarred or if an H-1B petition is questioned due to inconsistent wage or job data.
• The stigma of a compliance investigation can make it harder for workers to move to new employers if doubts arise about past employment records.

For Indian nationals, NRIs, international graduates, and other global professionals, the new environment means choosing an employer involves assessing how seriously the company takes immigration compliance—especially around LCAs and wage payments.

Students on F-1 visas moving through OPT or STEM extensions into H-1B status must be particularly careful. Early U.S. work often includes training‑heavy roles, blended duties, or client‑site work—all areas Project Firewall may scrutinize. If the job duties listed in the LCA don’t match day‑to‑day tasks, that mismatch can create risk when moving into H-1B status.

Workers should also note that offsite consulting and third‑party project assignments are flagged as high‑risk for DOL audits. If an employer’s business model places H-1B workers at client locations, every document—from the LCA to client letters to internal records—needs to be exact.

Broader policy context and 2025 H-1B reforms

Project Firewall builds on broader 2025 reforms to the H-1B program, which include:

• A new $100,000 supplemental fee on certain H-1B petitions
• Stricter wage standards to reduce use of lower wages for skilled foreign workers
• Other regulatory tightening that makes it harder to use the H-1B category for roles that do not clearly require specialized skills

According to the DOL’s statements, Project Firewall is part of a broader effort to “safeguard the rights, wages, and job opportunities of American workers” and prevent misuse of the H-1B program. These changes reflect a political and labor environment in the United States where foreign hiring and outsourcing—especially in tech and related sectors—are under heavier public and congressional scrutiny.

Project Firewall is both a compliance initiative and a political signal. It tells U.S. workers that the government is watching how employers use foreign labor, and it tells employers and foreign professionals that grey‑area practices are less tolerable. For some companies, this will mean higher compliance costs and more cautious H-1B hiring. For others—particularly those already investing heavily in compliance—it may level the playing field against competitors who cut corners.

The central message: H-1B status is not just a visa; it is an ongoing compliance relationship between the government, the employer, and the worker.

Practical steps for international students and global talent

For individuals aiming to build a U.S. career on H-1B status—international students, NRIs, digital workers, and global professionals—Project Firewall is a clear message to take compliance seriously from day one. Recommended actions:

1. Before accepting an H-1B offer, ask direct questions about:
   • The exact job title and detailed job description
   • The wage level and how it relates to the LCA
   • Whether the employer maintains clean, up‑to‑date public access files and takes audits seriously
2. After starting the job, regularly confirm that:
   • Your paychecks match the wage listed in the LCA
   • Your day‑to‑day duties align with the role in the H-1B petition
   • Any changes in duties, location, or work model are documented and, when required, backed by updated LCA filings
3. Be cautious with offsite or consulting projects:
   • If you are placed at a client site or moved across client projects, ask how those assignments are reflected in your LCA and H-1B paperwork
4. Stay informed about enforcement trends:
   • The DOL can now launch proactive investigations, so employer practices may shift quickly; understanding trends helps you spot red flags
5. Plan for the long term:
   • Treat visa status as part of your employment lifecycle, not a one‑time event; compliance problems early on can surface during later immigration processes

USCIS maintains official H-1B program information, including general requirements and employer obligations, at https://www.uscis.gov/working-in-the-united-states/temporary-workers/h-1b-specialty-occupations. Although Project Firewall is driven by the DOL, USCIS decisions on petitions and extensions may be affected by DOL findings.

What Project Firewall signals for the future of H-1B hiring

For students, NRIs, and global professionals, especially from India where demand for H-1B opportunities is intense, Project Firewall signals that the pathway remains open but is more guarded. The visa category is still a key route for skilled workers, but the “compliance fence” around it is higher.

For employers, particularly in high‑tech, consulting, outsourcing, and other H-1B‑heavy sectors, Project Firewall means a renewed obligation to demonstrate:

• Transparency in role definitions and hiring practices
• Proper documentation from LCA filings through daily work records
• Wage compliance that withstands detailed review

While these changes may curb misuse of the H-1B system, they demand more care from everyone involved. Foreign professionals cannot assume “the company will handle everything.” Instead, they should be active partners in keeping records accurate and aligning real work with LCAs and petitions.

The central message of Project Firewall is clear: treat H-1B status as an ongoing compliance relationship. Those who stay informed, maintain accurate documentation, and insist on proper wages and job descriptions will be best positioned to build stable, long‑term careers in the United States under this new enforcement regime.