Project Firewall Is Here: What Employers Need to Know

Project Firewall Is Here: What Employers Need to Know About DOL’s New H-1B Enforcement Push

If you saw the words “Project Firewall” and assumed it was an IT thing, you are not alone.

But this “Firewall” has nothing to do with cyber security. It is the U.S. Department of Labor’s new enforcement initiative focused on the H-1B visa program, and it is designed to protect the rights, wages, and job opportunities of highly skilled U.S. workers by increasing scrutiny on employers who misuse the program.

For employers, the takeaway is simple: if you use the H-1B program (or plan to), it is time to tighten up your compliance practices. Because the Department of Labor is making it clear that enforcement is not just complaint-driven anymore.

What is Project Firewall?

Project Firewall is an enforcement initiative led by the U.S. Department of Labor’s Wage and Hour Division (WHD) and launched on September 19, 2025. Its purpose is to “maximize compliance” with the H-1B program and ensure qualified American workers are not unfairly displaced.

According to DOL, WHD will prioritize investigations when there are signs of issues like:

• Displacement of U.S. workers

• Inadequate recruitment of U.S. workers

• Preference for H-1B workers when qualified U.S. workers are available

• Retaliation against workers who raise compliance concerns

• Misrepresenting job duties, requirements, or working conditions

Just as important, DOL states Project Firewall supports more targeted, data-driven enforcement and coordination with other agencies.

“Hire Americans First” and what that really means in practice

You may hear “hire qualified American workers first” connected to Project Firewall. DOL uses that framing directly when describing the initiative.

In the real world, this “Americans first” focus shows up through enforcement of long-standing rules and protections tied to H-1B participation, including:

• Required wage and working condition standards

• Proper notices and documentation

• Protections against displacement and retaliation

• Scrutiny of hiring practices that may unlawfully exclude or discourage U.S. workers

• Accuracy in how the role is described and administered

Bottom line: Project Firewall is DOL signaling that they are watching for patterns where the H-1B process is used to sidestep qualified U.S. workers or undercut wage standards.

What can happen if DOL finds violations?

DOL is very direct about potential consequences. When violations are found, WHD may:

• Recover back wages

• Seek reimbursement of required fringe benefits

• Assess civil money penalties

• Impose debarment (loss of access to the H-1B program and certain other visa programs for at least one year)

That combination can get expensive fast, and it can also disrupt recruiting plans and project timelines.

DOL is not doing this alone: increased coordination with other agencies

Project Firewall is also a “whole-of-government” style effort. DOL highlights coordination with agencies including:

• Employment and Training Administration (ETA)

• U.S. Department of Justice, Civil Rights Division

• Equal Employment Opportunity Commission (EEOC)

• U.S. Citizenship and Immigration Services (USCIS)

In late 2025, DOL also publicly emphasized its partnership with the EEOC, pointing to concerns like job ads or recruiting practices that suggest positions are only open to H-1B holders, which can raise national origin discrimination issues.

Translation: this is not just a paperwork review. Hiring practices are in the spotlight, too.

A practical compliance checklist for employers using H-1B

If your organization uses H-1B workers (or plans to), here are smart “do it now” steps to reduce risk under heightened enforcement.

1) Pressure-test your H-1B documentation and role accuracy

Project Firewall specifically calls out concerns like misrepresenting job duties, requirements, or working conditions.
Make sure what is on paper matches what is happening in reality: title, duties, worksite, and working conditions.

2) Review hiring and recruiting practices for “preference” problems

DOL flags investigations where employers may be giving preference to H-1B workers when qualified U.S. workers are available.
Look for red flags like overly narrow requirements, inconsistent screening, or messaging that discourages U.S. applicants.

3) Confirm wage and benefit practices are consistent and defensible

Because WHD can pursue back wages, fringe benefit reimbursement, and penalties, wage and classification practices deserve a fresh look.

4) Train managers on retaliation risk

WHD explicitly lists retaliation as an enforcement priority.
Make sure managers know how to handle internal complaints, audits, or questions without creating a second issue.

5) Prepare for the possibility of a government inquiry

DOL’s launch announcement notes the Department will conduct investigations through Project Firewall, and that the Secretary of Labor will personally certify the initiation of investigations under certain circumstances.
This is a good time to ensure your records are organized and your internal owners know what to do if an inquiry arrives.

✴️Need help with compliance? Contact CTR today! 

Disclaimer: This blog is for general informational purposes and is not legal advice.

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