On September 19, 2025, the U.S. Department of Labor (DOL) announced Project Firewall, a sweeping enforcement initiative aimed at strengthening oversight of the H-1B program. Alongside the newly introduced $100,000 supplemental H-1B filing fee, Project Firewall signals the government’s intent to raise both the financial and compliance bar for employers.

While much of the initial coverage frames this as an issue for attorneys, the reality is that employers themselves face heightened risk. Payroll, Public Access Files (PAFs), Labor Condition Applications (LCAs), and worksite documentation are now under closer scrutiny than ever before.

What is Project Firewall?

Project Firewall is a new enforcement initiative introduced by the DOL to significantly strengthen oversight of the H-1B program. Unlike routine compliance checks, it gives the US Secretary of Labor the power to personally certify investigations whenever there is “reasonable cause”. This means that the DOL can open a case even without a formal complaint from an employee or third party.

Through the project, the DOL is empowered to take a much harder line with employers. The initiative allows investigators to scrutinize payroll, LCAs, and PAFs with greater intensity. If violations are identified, the penalties can be severe:

• Companies may be required to pay back wages

• Employers could face substantial civil fines

• Organizations risk debarment from future participation in the H-1B program
  

This last consequence could effectively cut off a company’s ability to access global talent, creating both operational and reputational risks.

Another defining feature of the project is its emphasis on interagency collaboration. The DOL will now coordinate more closely with agencies such as U.S. Citizenship and Immigration Services (USCIS), the Department of Justice (DOJ), and the Equal Employment Opportunity Commission (EEOC). This means that noncompliance in one area, whether related to immigration documentation, labor practices, or anti-discrimination rules, could cascade into broader multi-agency investigations.

In practical terms, Project Firewall signals that even minor inconsistencies in documentation can trigger serious consequences for employers. Examples include:

• Mismatched job titles across records

• Missing documents in a Public Access File

• Discrepancies in wage reporting

By raising both the scrutiny and the stakes, this initiative pushes organizations to prioritize airtight compliance and audit-readiness in every aspect of their H-1B management.

‍Project Firewall: Why Employers Should Pay Attention

Historically, many compliance checks focused on attorneys and petition filings. With this initiative, the focus is shifting directly to employers and HR teams. This change means organizations can no longer rely solely on their legal counsel to manage risk. Day-to-day HR operations and documentation practices are now squarely in the spotlight.

Key Areas of Impact for Businesses

• Payroll and Wage Verification: Employers should expect much stricter checks to ensure that the wages promised on Labor Condition Applications (LCAs) align exactly with what employees are actually paid. This includes consistent monitoring of base salaries, bonuses, and any allowances. Even small discrepancies can lead to back-pay orders, exposing the company to unexpected financial liabilities. A missed adjustment or delay in implementing a prevailing wage increase could now trigger an investigation under the project.
  

• Public Access Files (PAFs) Under Review: Public Access Files have traditionally been seen by many employers as a low-priority compliance task. Under Project Firewall, that mindset is no longer safe. The DOL has clearly signaled that incomplete, outdated, or poorly maintained PAFs will be treated as substantive violations rather than technical errors. Employers must ensure these files are not only accurate but also audit-ready at all times. That means documenting wage determinations, posting notices, and ensuring all required supporting documents are current. A missing memo or outdated posting could trigger deeper scrutiny.
  

• Multi-Agency Investigations: Another significant shift is the coordination between the DOL, USCIS, DOJ, and EEOC. An issue identified in one area, such as payroll reporting, can now cascade into broader reviews involving discrimination or immigration fraud. For example, a discrepancy in worksite documentation could lead to questions not just from the DOL but also from the DOJ Civil Rights Division. This interagency model increases the risk that a small compliance slip may evolve into a multi-pronged investigation with much higher stakes.
  

• Risk of Debarment: Perhaps the most serious consequence for employers is the risk of debarment. If an employer is found to be in repeated or willful violation of H-1B requirements, the DOL can bar them from filing future H-1B petitions. For companies that depend on global talent, this is not just a compliance penalty. It is a direct threat to their ability to compete. Losing access to H-1B sponsorship can disrupt projects, delay client delivery, and weaken long-term workforce planning.

Why This Matters Now

The combination of these risks means employers cannot afford to view Project Firewall as a distant or theoretical issue. It represents a new enforcement scenario where HR leaders must adopt proactive compliance strategies. Organizations that take early action, by auditing their records, training HR staff, and investing in compliance technology, will be better positioned to withstand heightened scrutiny.

In short, the project makes compliance a business-critical function rather than a back-office task. Employers that adapt quickly will not only minimize legal and financial risks but also build stronger, more resilient workforce practices.
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‍Available H-1B Program Statistics

To better understand the context behind Project Firewall, it is helpful to look at recent and historical H-1B program statistics. These data points highlight the scale of the program, trends in registration, and areas of concern that influenced the decision to launch stricter enforcement.

Fiscal Year 2025 H-1B Lottery Data

Statistics from USCIS show the current state of demand and the impact of new anti-fraud measures:

• Total eligible registrations: 470,342

• Selected registrations: 120,603

• Eligible registrations for beneficiaries with multiple eligible registrations: 47,314, a significant decrease from FY 2024’s 408,000+

• Average registrations per beneficiary: 1.06, compared to 1.7 in FY 2024

This steep decline demonstrates that USCIS’s anti-fraud initiatives are working, reducing attempts by employers or agents to game the system by submitting multiple registrations for the same beneficiary.

Is Project Firewall Related to the $100,000 H-1B Fee?

The Department of Labor’s announcement of Project Firewall came on the very same day that the government introduced a massive $100,000 supplemental fee on many new H-1B petitions. While the two measures are technically separate, their combined effect has created a significant shift in the H-1B scenario for employers.

The fee hike is designed to raise the financial bar for companies considering new H-1B sponsorships. Every new filing now carries an extraordinary upfront cost, which makes it essential for organizations to evaluate the return on investment of each hire with much greater scrutiny. Startups and small to mid-sized employers in particular may find that only critical or revenue-generating positions justify such a large expense.

At the same time, Firewall raises the compliance bar. Employers must maintain airtight documentation, keep Public Access Files complete, and ensure wage accuracy to avoid penalties or debarment. This means that paying the higher filing fee is just the beginning. Organizations must also prove that their processes can withstand heightened government review.

Together, these measures create a double burden: higher costs at the start of the process and ongoing compliance obligations afterward. For employers, this makes audit-readiness and ROI from every H-1B hire critical, transforming sponsorship decisions from routine administrative steps into high-stakes business choices.

Steps H-1B Employers Should Take Now

Here’s a comprehensive action plan to prepare your organization. Each step is more than just a checkbox; it represents a proactive strategy to minimize exposure under the Project and demonstrate a culture of compliance.

• Audit your Public Access Files: Go beyond a surface check. Employers should conduct periodic reviews to ensure every file is complete, up to date, and accessible for inspection. This includes wage determination documentation, posting notices, and supporting records. Missing or outdated files are one of the easiest ways to invite unwanted scrutiny.

• Check wage compliance: Payroll must align precisely with Labor Condition Application (LCA) obligations. Employers should run regular reconciliations to confirm that salaries, bonuses, and allowances meet or exceed prevailing wage requirements. Even minor payroll discrepancies can now trigger back-pay orders.  
  

• Standardize worksite records: Documenting where H-1B employees actually perform their work is essential, especially in remote or client-site arrangements. Standardization ensures consistency across LCAs, petitions, and HR systems. A clear trail of worksites and assignments reduces risk if investigators compare multiple records.

• Train HR & compliance teams: Awareness across HR and management teams is critical. Employers should provide periodic training on Project Firewall requirements and build accountability for maintaining compliance. Informed staff are less likely to make costly errors and more prepared to respond confidently if audited.

• Leverage compliance tools: Manual tracking creates gaps and is prone to error. Automated compliance platforms like OnBlick offer built-in intelligence to maintain audit-ready Public Access Files, provide alerts for missing documentation, and reduce administrative burden. By investing in reliable technology, employers can transform compliance from a reactive task into a preventive shield.
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By implementing these steps, organizations not only reduce their exposure but also create a compliance infrastructure that can stand up to the heightened scrutiny of the Project. Companies that delay action risk falling behind, while those that adopt tools like OnBlick early will strengthen trust, minimize legal liabilities, and ensure continuity in their H-1B hiring programs.

How OnBlick Can Help

OnBlick is purpose-built to help employers stay ahead of shifting compliance rules and reduce the risks introduced by Project Firewall. Rather than relying on fragmented spreadsheets or manual checklists, organizations can depend on a platform that brings all the moving parts of immigration compliance into one intelligent system. OnBlick:  

• Maintains audit-ready Public Access Files (PAFs) so employers are prepared if investigators request records without notice.

• Guides H-1B processes with built-in regulatory intelligence, reducing human error and ensuring that filings align with prevailing rules.

• Provides real-time alerts on potential compliance gaps, empowering HR teams to act before issues escalate into violations.

• Keeps I-9, LCA, and petition documentation consistent and accessible, eliminating the risks that come with scattered records.

• Supports training and accountability, helping employers build a culture of compliance by equipping staff with clear workflows and automated reminders.

With Project Firewall raising the stakes, employers cannot afford to take chances with manual processes or fragmented record-keeping. The cost of a single oversight, whether in a wage report, a PAF entry, or a missed posting, can be far greater than investing in preventive technology. OnBlick not only simplifies these tasks but also demonstrates to regulators that your organization takes compliance seriously.

Book a free personalized demo to see how OnBlick ensures your compliance program is firewall-proof and positions your business to thrive in this new enforcement scenario.
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Conclusion

Project Firewall is more than just another policy change by the DOL. It is a clear signal of the government’s tougher stance on H-1B compliance and a reminder that compliance is now a front-line business function. For employers, the message is clear: document everything, close compliance gaps, and always stay audit-ready.

Organizations that act quickly will not only reduce their risk of fines or debarment but also strengthen their operational credibility with clients, employees, and regulators. Proactive compliance builds trust, improves workforce stability, and helps companies continue to access global talent without disruption. The businesses that delay may find themselves struggling with last-minute fixes, reputational harm, or costly investigations.

By leveraging compliance partners like OnBlick, employers gain more than just technology. They gain a safety net. OnBlick equips HR and compliance teams with real-time insights, audit-ready documentation, and intelligent workflows that transform regulatory obligations into streamlined processes.  

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