H-1B Employers Face Stricter Audits Under New DOL Project Firewall

September 19, 2025, the U.S. Department of Labor (DOL) announced Project Firewall, a sweeping initiative to strengthen oversight of the H-1B visa program.

Under this new framework:

• The Secretary of Labor can personally certify investigations when there’s “reasonable cause” to suspect noncompliance.

• DOL will partner more closely with USCIS, DOJ, EEOC, and other agencies, coordinating findings and enforcement actions.

• Audits will become more frequent and proactive, initiated even without a formal complaint.

In short: this marks a shift from reactive enforcement to active, preventive oversight.

Why It Matters Now for Employers

1. Stiffer Penalties for Noncompliance

Employers found in violation of H-1B program rules may face:

• Payment of back wages owed to employees

• Civil monetary fines

• Debarment from participating in the H-1B program for a set period

In other words: even relatively small missteps in paperwork, wage disparities, or posting rules could trigger serious consequences.

2. $100,000 Fee on New Petitions

Simultaneous with Project Firewall, a Presidential Proclamation now mandates a $100,000 supplemental payment for new H-1B petitions filed after September 21, 2025 (though not for existing visas or renewals).

This fee is aimed at deterring misuse of the visa program.

3. Higher Risk of Cross-Agency Scrutiny

Because DOL is sharing data and coordinating with other federal offices, employers may face multi-agency audits — e.g. USCIS immigration reviews, DOJ civil rights probes, or EEOC discrimination checks.

4. Focused on Wage & Documentation Compliance

Project Firewall places particular emphasis on:

• Ensuring payroll matches LCA wage commitments (no deviations)

• Maintaining complete, accurate public access files (PAFs)

• Matching job duties, job classification, and work location precisely to what was filed in the petition and LCA
  
  

What Employers (Especially in Travel / Aviation B2B) Must Do

Conduct an Internal Compliance Audit

Review all your H-1B files, especially:

• Public Access Files (PAFs) — are they complete, signed, and readily accessible?

• LCAs — check accuracy of wage levels, worksite locations, job titles, and SOC codes.

• Payroll vs LCA wage — ensure consistency in every pay period.

• Notice postings — confirm proper posting (physical & electronic) at each worksite.
  
  

Implement Standardized Practices

• Use uniform job classifications, minimal variation across filings.

• If worksite changes, amend LCAs and petitions before moving employees.

• Keep a change-tracking log for duty, location, or compensation adjustments.
  
  

Train HR, Managers & Compliance Teams

Everyone handling visa or overseas hiring must:

• Know H-1B rules (wages, documentation, postings)

• Be vigilant about red flags (sudden layoffs, underpaying, site misrepresentation)

• Understand how to respond during audits or investigations
  
  

Prepare for Government Inquiries

• Designate audit response leads

• Keep records in audit-ready format

• Consult external legal/immigration counsel proactively

• Establish internal communication protocols to respond quickly to requests
  
  

Revisit Business Strategy

• Evaluate whether H-1B reliance is sustainable under the new regime

• Budget for the $100,000 fee on new petitions

• Consider alternative visa categories or talent sourcing strategies
  
  

Takeaway for B2B Travel & Aviation Stakeholders

Though Project Firewall is focused on the U.S. H-1B visa domain, its ripple effects influence global talent sourcing, vendor contracts, and compliance risk frameworks—especially in travel, aviation, and related services.

If your company depends (even indirectly) on H-1B–sponsored staff (e.g. IT teams, analytics, customer support, contract staff in aviation tech), now is the moment to get ahead. A proactive compliance posture not only minimizes exposure to hefty penalties, but also helps maintain operational trust with clients, vendors, and regulators.

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