Preparing for H-1B Compliance Site Visits: A Checklist for Employers

The New Era of H-1B Enforcement Under Project Firewall

Immigration compliance enforcement has entered a more active phase following the launch of Project Firewall, a joint initiative led by the U.S. Department of Labor (DOL) in coordination with federal partners, including U.S. Citizenship and Immigration Services (USCIS). Announced in September 2025, the initiative is part of a broader effort to increase oversight of the H-1B program and ensure employers are complying with program requirements.

A central feature of Project Firewall is an expected rise in both random and targeted worksite inspections. These visits are designed to verify that employers are adhering to the terms of approved H-1B petitions and Labor Condition Applications (LCAs).

This guide provides a practical checklist to help employers prepare for unannounced H-1B site visits conducted by USCIS’s Fraud Detection and National Security Directorate (FDNS). It focuses specifically on H-1B-related inspections and does not cover other types of audits or enforcement actions, such as I-9 inspections, Immigration and Customs Enforcement (ICE) investigations, or wage and hour audits unrelated to the H-1B program.

Advance preparation remains the most effective way to reduce risk during a site visit. Noncompliance findings can lead to petition denials or revocations, civil penalties, and, in serious cases, debarment from participation in immigration programs.

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Why Site Visits Are Increasing

The current administration has made expanded enforcement of the H-1B program a priority, with a focus on alleged worker displacement and wage impacts in certain industries. Project Firewall, along with a final rule requiring employer cooperation during site visits, reflects a shift toward more active oversight.

Notably, the DOL has emphasized its authority to initiate investigations when there is reasonable cause to believe an employer may be out of compliance, including through investigations certified directly by the Secretary of Labor. As a result, employers should plan for the possibility of a site visit as a routine compliance risk rather than a remote scenario.

There have also been reports of site visits initially targeting certain metropolitan areas. While enforcement may roll out unevenly, employers across the United States should assume that a site visit is possible, regardless of location or company size.

Understanding the Types of Compliance Visits

Employers may encounter H-1B-related compliance activity from two primary agencies: USCIS and the Department of Labor. While both focus on program integrity, their authority and scope differ.

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