Project Firewall: Why H-1B Compliance Just Became a Bigger Deal Than the $100K Visa Fee

On Friday, September 19th, 2025, the U.S. immigration world was rocked by the announcement of a proposed $100,000 H-1B visa fee for large employers filing new H-1B petitions. The news, issued via presidential proclamation, sparked immediate backlash from employers, immigration advocates, and the broader business community.

But while that story dominated headlines, another critical development in the H-1B space quietly unfolded: the U.S. Department of Labor (DOL) launched a sweeping new enforcement initiative called “Project Firewall.”

This initiative could have far more lasting implications for H-1B employers and immigration attorneys than even the headline-grabbing fee.

What Is Project Firewall?

Announced on the same day as the visa fee news, Project Firewall is the DOL’s new compliance strategy targeting employers who misuse or mishandle the H-1B program. While the exact details of the initiative are still unfolding, the DOL’s official statement highlighted several key priorities:

Expanding the authority of the Secretary of Labor to initiate investigations independently

Strengthening inter-agency coordination with the Department of Justice (DOJ), Equal Employment Opportunity Commission (EEOC), and U.S. Citizenship and Immigration Services (USCIS)

Prioritizing data-sharing and proactive enforcement to detect and prevent fraud or abuse

In other words, the DOL is no longer waiting for whistleblowers or complaints. It is building an aggressive, cross-agency framework to proactively enforce H-1B compliance—especially around Labor Condition Applications (LCAs) and Public Access Files (PAFs).

You can read the DOL’s official announcement here.

Why This Matters More Than the $100K Fee

Let’s be clear: the proposed $100,000 fee is alarming. But it’s also widely expected to face legal challenges, delays, or revisions before it ever goes into effect—if it ever does at all.

Project Firewall, on the other hand, is already in motion.

And it’s targeting one of the most overlooked areas of H-1B compliance: how employers post LCAs and manage PAFs.

This is where most companies—especially those without specialized immigration compliance teams—are the most vulnerable.

For a primer on these requirements, check out our guide:
What Goes Into an H-1B Public Access File?

Common Mistakes That Could Now Trigger Penalties

With Project Firewall’s heightened scrutiny, it’s no longer just about major fraud or willful violations. Even technical noncompliance—the kind that often happens due to outdated workflows or misunderstandings—can now become the basis for fines, audits, or worse.

In our experience working with immigration law firms and H-1B employers of all sizes, here are some of the most common (and risky) LCA/PAF mistakes:

Failing to post LCAs for the full 10-business-day minimum

Not ensuring LCA visibility for remote workers’ coworkers, as required by DOL guidance

Waiting more than 24 hours after filing an LCA to create the PAF, which violates strict DOL timelines

Holding onto PAFs too long, even after the retention period ends, increasing audit exposure

Any one of these violations could result in a compliance failure. When combined, they can significantly increase the risk of a Department of Labor audit or investigation.

We cover some of these issues in more depth in:
The Hidden Risk of Holding PAFs Too Long

History Repeats Itself: Remote Work and H-1B Compliance Chaos

At LaborLess, we’ve seen this pattern before.

Our first major growth spike came in 2020, when the COVID-19 pandemic forced millions of workers—and their employers—into remote setups almost overnight. H-1B employers were suddenly scrambling to figure out where to post LCAs and how to remain compliant with existing DOL rules that weren’t built for a remote-first world.

We stepped in to offer a digital, compliant, and scalable solution.

And now, it’s happening again—this time fueled not by a global health crisis, but by a federal enforcement wave.

Why Bulletproof H-1B Compliance Matters More Than Ever

The message from Project Firewall is clear: the government is going to start nitpicking every part of the H-1B process.

That means employers need to move beyond good intentions and implement systems that guarantee compliance from the ground up. It’s no longer enough to trust spreadsheets, manual processes, or outdated paper files.

That’s where LaborLess comes in.

How LaborLess Helps You Stay Compliant (and Audit-Ready)

LaborLess was built specifically to help employers and immigration attorneys automate and modernize LCA posting and PAF compliance.

Here’s how we help you stay ahead of Project Firewall and any other audit-prone regulation that might come your way:

Electronic LCA Posting: Meet posting duration requirements (10 business days) with digital LCA posting that’s compliant and trackable.

Remote Work Support: Ensure LCA visibility for coworkers—no matter where your employees are based.

Automatic PAF Creation: Our system auto-generates compliant Public Access Files within 24 hours of LCA filing, meeting DOL deadlines.

Secure Retention and Auto-Purge: PAFs are safely stored and automatically purged at the end of their required retention period, reducing unnecessary audit exposure.

Want to see how this works in practice? Check out:
How a Top AmLaw 200 Firm Streamlined H-1B Compliance with LaborLess

Don’t Wait for the Audit Letter

If your company or firm works with H-1B, H-1B1, or E-3 visa holders, now is the time to reassess your compliance systems.

The DOL isn’t waiting for someone to report you. With Project Firewall, it’s looking at data, patterns, and red flags—and acting before problems arise.

Make sure you’re ready.

Visit www.laborless.io to learn how we can help you stay compliant, reduce risk, and future-proof your immigration program.

Frequently Asked Questions (FAQ)

What is Project Firewall?
Project Firewall is a new Department of Labor initiative focused on proactive H-1B enforcement. It expands investigative authority and increases inter-agency coordination to identify and penalize employers who violate visa program rules.

What does it mean to post an LCA electronically?
Posting an LCA electronically means making it available in a digital format where affected employees can access it easily—such as on a secure internal network or intranet. Learn more in our article on what counts as compliant LCA posting.

What is the PAF 24-hour rule?
According to DOL regulations, a Public Access File must be created within 1 working day (usually 24 hours) of filing the LCA. LaborLess automatically generates PAFs to help ensure compliance.

How long should PAFs be retained?
PAFs must be retained for one year beyond the last date of the LCA’s validity or the employee’s termination, whichever is later. Holding them longer can actually increase your audit risk. For more, see our blog post: How Long Do You Need to Keep H-1B Public Access Files?

Does LaborLess support H-1B1 and E-3 compliance?
Yes. Our platform supports compliance for all LCA-based visa categories, including H-1B1 (for Chile and Singapore) and E-3 (for Australia).

If you’re still handling H-1B compliance manually, or worse, assuming “it won’t happen to us,” it’s time to rethink your strategy. Project Firewall is here, and LaborLess is ready to help.