Federal labor enforcement under Project Firewall has turned life upside down for many H-1B employers: investigations are climbing fast and corporate compliance teams are scrambling to keep pace. The initiative lets the Wage and Hour Division open secretary-certified probes even when no worker has filed a complaint, and companies that rely on foreign talent are now getting pulled into wider document and payroll sweeps. Reviews that once focused on a single employee are suddenly becoming potential companywide examinations.
Bloomberg Law reports that the Labor Department’s H-1B investigation caseload has jumped roughly 48% since Project Firewall began, and immigration attorneys say employers are seeing more frequent site visits and more complex, data-driven information requests. According to Bloomberg Law, those broader inquiries often pull payroll records, contracts and public-access files into a single, cross-agency review.
The Department of Labor first announced Project Firewall on Sept. 19, 2025, describing it as an effort to “safeguard the rights, wages, and job opportunities of highly skilled American workers” and to allow the Secretary to personally certify investigations when there is reasonable cause. The agency warned that violations could lead to back-wage collections, civil money penalties or temporary debarment from the H-1B program. As outlined by the U.S. Department of Labor, the Wage and Hour Division will lead Firewall alongside partners including DOJ, the EEOC and USCIS.
What investigators are doing on the ground
Immigration attorneys say on-site visits that once focused narrowly on a single beneficiary now commonly expand into reviews of an employer’s entire workforce, payroll practices and subcontractor relationships. "They're not focusing on just drugs and thugs anymore. They're looking for hyper-technical violations," one lawyer told Bloomberg Law, describing how oral answers during visits are cross-checked against petition paperwork and other filings.
Rule changes that ratchet up the pressure
The enforcement surge is arriving as policy moves have raised the stakes for employers: a presidential proclamation added a $100,000 payment requirement for many new H-1B entries, and DHS has proposed and moved toward a wage-weighted selection method for cap subject registrations. At the same time, the Labor Department's March 27, 2026 NPRM would recalculate prevailing-wage percentiles in a way the agency estimates would raise required pay by roughly 21% to 33%, depending on level and locality. See the American Immigration Lawyers Association and the DOL proposal in the Federal Register for details.
Wider context: past audits and who’s most exposed
Government reviews and academic studies help explain why enforcement is intensifying. A 2008 USCIS Benefit Fraud & Compliance Assessment, discussed in later work by the GAO, flagged fraud and technical violations in a random sample of petitions, underscoring why agencies say closer scrutiny is needed. Recent research at the NBER found H-1B hires earned about 16% less than comparable U.S. natives on average, a gap policymakers point to when justifying higher wage floors or fees. Major users of the H-1B program include large tech and IT services firms, and federal data highlighted by the Pew Research Center show Amazon, Infosys, Tata and other heavy petitioners appearing prominently in federal records.
What employers should do now
Compliance specialists advise companies to get ahead of the curve by auditing LCAs, payroll records, remote-work documentation and public-access files now, centralizing responses and involving immigration counsel before responding to broad government requests. With the DOL wage proposal and other rules moving through formal notice periods, employers and trade groups have a limited window to comment and prepare. For many tech and consulting firms, the new enforcement landscape translates into heavier administrative and legal burdens than they have faced in years.
