THE U.S. DEPARTMENT OF LABOUR (DOL) - "PROJECT FIREWALL"

 What’s New

  • On September 19, 2025, President Donald Trump signed a proclamation that will require a $100,000 annual fee for each H-1B visa application.

  • This fee is to be paid by the sponsoring employer. It is significantly higher than the current fees, which are only a few hundred to a few thousand dollars depending on the situation. 

  • The policy applies not only to new H-1B applications but also to renewals/extensions. 

  • Effective date mentioned is September 21, 2025


Why This Is Being Done (Admin’s Justification)

According to the Trump administration:

  • To discourage misuse or over-use of the H-1B visa for jobs that could be done by U.S. workers. They argue that many companies hire skilled foreign workers at wages lower than what equivalent U.S. workers would demand. 

  • To make sure H-1B visa holders are really highly skilled or indispensable, not filling entry level or lower wage roles. 

  • To shift some of the burden onto employers so they more carefully assess whether a foreign hire is necessary. 


Key Details & Unknowns

  • It is not completely clear how this fee interacts with or replaces existing fees (for lottery registration, petition filing, etc.). 

  • Whether there will be exemptions (for universities, nonprofits, certain startup/early-stage companies, etc.) is not yet fully detailed.

  • How this will be enforced, how transitions for ongoing H-1B holders will be managed (if at all), and whether legal challenges might delay or block parts of this.


What is Project Firewall

  • Official Launch: The U.S. Department of Labor (DOL) announced Project Firewall on September 19, 2025. 

  • Core Purpose: It is an enforcement initiative aimed at preventing misuse of the H-1B visa program — making sure highly skilled jobs go to qualified Americans first, and protecting wages, rights, and job opportunities of U.S. workers. 

  • Leadership & Authority:

    • The Wage and Hour Division (DOL), the Office of Immigration Policy, and the Employment and Training Administration will lead implementation. 

    • For the first time, the Secretary of Labor will personally certify the initiation of investigations when there is reasonable cause that an employer is violating H-1B rules. 


Key Features / How It Works

  1. Investigations & Audits

    • Employers suspected of not complying with H-1B visa regulations will be investigated. 

    • Secretary-certified investigations give the DOL heightened oversight power. 

  2. Penalties for Violations
    If abuses are found, the DOL can impose penalties including:

    • Back wages owed to affected workers.

    • Civil money penalties. 

    • Debarment from the H-1B program for some period for repeat or serious offenders. 

  3. Coordination Among Agencies

    • The DOL will work with other federal partners such as the Department of Justice’s Civil Rights Division, the Equal Employment Opportunity Commission (EEOC), and U.S. Citizenship and Immigration Services (USCIS).

    • Shared information, coordination to detect fraud, abuse, and discrimination.

  4. Compliance Assistance

    • Employers will have resources to help them stay compliant. The Wage and Hour Division offers assistance and has made available a toll-free number for questions. 


Motivations / Policy Context

  • This fits within the broader “America First” stance under the current U.S. administration, which emphasizes protecting American jobs, especially in segments that rely on foreign skilled labor. 

  • There has also been concern over perceived abuses in the H-1B system: underpayment, displacement of U.S. workers, misuse of visa rules, etc. Project Firewall is meant to address those concerns. 

  • The same time, other policy changes are being introduced (e.g. a $100,000 fee for H-1B applications) which amplify the regulatory pressure. 


Potential Impacts & Challenges

Impacts

  • On Foreign Nationals / H-1B Workers

    • Higher scrutiny of employers sponsoring H-1Bs might lead to slower visa processing or more rejections if compliance isn’t clean.

    • Costs for employers may increase (both in fees and in compliance overheads).

    • For many Indians and others who constitute a large share of H-1B beneficiaries, this could change job prospects or change employer behavior. 

  • On U.S. Employers (especially tech / skilled industries)

    • Companies using H-1B talent will need tighter compliance to avoid penalties or debarment.

    • Likely more legal/labor cost overhead, perhaps shifting hiring practices.

    • Potential risk of talent shortages if companies are less willing to navigate stricter rules, or if the foreign skilled labor pool shrinks.

  • On U.S. Workers

    • Intended benefit: to ensure qualified U.S. workers have better access to skilled jobs and are not undercut by visa misuse.

    • May lead to improved enforcement of wage standards and rights for those on H-1B too.

Challenges & Risks

  • Defining “Qualified Americans”: what counts as priority, what level of skill, education, etc. Clear criteria will be essential.

  • Resource and Capacity Constraints: DOL, USCIS, EEOC, DOJ will need adequate staff, funding, expertise to investigate, monitor, enforce.

  • Legal Pushback: Employers or industry groups may challenge debarments, fees, or definitions in court.

  • Global Competitiveness: U.S. innovation, especially in sectors like tech / AI, often depends on international talent. Overly strict rules could hamper that.

  • Administrative burden: It may create bureaucratic delays, especially if investigations are frequent or overlap.


Key Things to Watch

  • How “reasonable cause” is interpreted; that determines when Secretary certification triggers investigations. 

  • How much rise in application costs or fees beyond the existing changes (e.g., the $100,000 fee) will affect IOUs, startups, universities.

  • The number of debarments or employers penalized — that will signal how aggressive enforcement is.

  • Reaction from industry (e.g. tech companies, consulting firms) and from foreign governments whose citizens participate heavily in the H-1B program (e.g. India).

  • Whether this causes shift in U.S. immigration / labor policy — e.g. more domestic training or incentives to grow U.S. skilled labor supply.Here’s a detailed breakdown of the newly announced U.S. policy that introduces a $100,000 fee for H-1B visas for highly skilled foreign workers — what it is, why it’s being done, the reactions, and what it could mean. If you want, I can also do a version focused more from the Indian perspective.


    Reactions & Criticism

    • Business / Tech Sector: Likely to push back heavily. Companies that depend on H-1B workers (especially tech, consulting, engineering) may argue this will dramatically raise costs and reduce competitiveness. 

    • Immigration Advocates: Many see this as a barrier for talented foreign professionals, particularly those early in their careers or from lower-wage sectors, who won’t be able to command salaries or positions justifying this cost. 

    • Legal Concerns: Some experts say such a high fee may be legally vulnerable, since fees for immigration are usually governed by statutes (i.e. Congress) and are supposed to be cost-based or justified. 


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