The figure appears in the department’s 2025 accomplishments report and represents investigations launched by the agency—not findings that the companies violated the law. The development matters to employers, recruiters, H-1B workers and U.S. job applicants because federal agencies are increasingly comparing visa filings, workplace records, recruiting practices and actual job duties.

What changed

Project Firewall launched on September 19, 2025. Bloomberg Law reported on April 7, 2026, that a Labor Department official described a 48% increase in the agency’s H-1B investigative caseload since the initiative began.

Bloomberg Law also reported that immigration attorneys representing employers have seen more site visits and broader, more data-driven information requests. The attorneys said inquiries that begin with one worker can expand to payroll and immigration records involving other employees. Those accounts describe reported enforcement activity and compliance concerns, not a new rule making ordinary H-1B hiring unlawful.

The H-1B program remains available to employers that meet its requirements. Project Firewall is an enforcement initiative, not a new H-1B statute.

What DOL is examining

Labor Department materials identify priorities that include possible failures to recruit U.S. workers in good faith, preference for temporary visa holders, retaliation against workers who raise concerns, and inaccurate descriptions of job duties, requirements or working conditions.

The department’s H-1B labor-condition framework also covers wage and workplace obligations. During an investigation, an employer may need to reconcile labor-condition applications, H-1B petitions, public-access files, payroll records, recruitment documentation, job descriptions, work locations and the duties workers actually perform.

Bloomberg Law reported that officials have asked detailed questions about qualifications, job requirements and workplace duties, with answers compared against information in earlier filings. A mismatch can prompt additional questions, but it does not automatically establish a violation or guarantee a penalty.

Potential consequences

Depending on the facts and the applicable proceedings, DOL enforcement may involve back wages, civil penalties and possible debarment from the H-1B program for at least one year. These are potential remedies, not the outcome of every investigation.

Employers should distinguish DOL’s wage-and-hour and H-1B compliance work from the Justice Department’s separate enforcement of citizenship-status discrimination rules. The two areas can overlap in practice when recruiting language suggests that a position is reserved for H-1B workers.

Why job advertisements matter

On July 7, 2026, the Justice Department’s Immigrant and Employee Rights Section finalized a settlement agreement with Creative Team, LLC, a Texas-based consulting company. DOJ said the agreement resolved its determination that the company engaged in citizenship-status discrimination in hiring and recruitment after posting a job advertisement restricting positions to H-1B visa holders without legal justification.

The agreement required Creative Team to pay $4,730 in civil penalties, train employees and stop using employment-advertisement restrictions that unlawfully exclude protected workers. The case illustrates a separate compliance risk under the Immigration and Nationality Act: job advertisements that limit hiring to H-1B workers without a documented legal basis can draw DOJ scrutiny.

A practical compliance check

• Compare current job descriptions and actual duties with H-1B petitions and labor-condition applications.
• Keep public-access files, payroll records, wage documentation and recruitment records complete and consistent.
• Review job advertisements and recruiter instructions for language limiting hiring to H-1B workers without a documented legal justification.
• Give managers a clear process for responding to agency inquiries, and avoid casual answers that conflict with filed records.
• Coordinate HR, recruiting, managers and immigration counsel before changing job duties, work locations or wage arrangements.

Employers should watch for additional DOL investigations, DOJ settlements, interagency information-sharing and any future H-1B wage changes. An investigation or settlement involving an employer does not, by itself, establish wrongdoing by every H-1B worker or invalidate every visa petition.

Sources

• U.S. Department of Labor: 2025 accomplishments
• Bloomberg Law: Employers See Spike in Labor Department Immigration Enforcement
• U.S. Department of Justice: Creative Team settlement

If your company hires using H-1B visas, or if you’re a job seeker assessing how an H-1B employer handles compliance, this matters because WHD’s willful-violator standard connects a designation to specific extra Labor Condition Application (LCA) attestations and oversight during a defined time window.

What the H-1B willful violator list is

WHD maintains a list of “willful violator employers” under the H-1B program. The roster identifies named employers (and, in some cases, named individuals) that WHD says have met the willful-violator standard under the H-1B program.

What makes an employer a “willful violator” (per WHD)

WHD defines a “willful violator employer” as an employer that meets all of these standards:

• A finding of violation is entered in either a Department of Labor proceeding under INA § 212(n)(2), or a Department of Justice proceeding under INA § 212(n)(5).
• WHD finds the employer committed a willful failure or misrepresentation of a material fact, tied to two LCA attestations.
• The agency’s finding is entered on or after October 21, 1998.

WHD says a willful violator employer must comply with additional attestations under any LCA it files within five years of the willful violation finding (with a limited exception when an LCA is filed for and used exclusively for exempt H-1B workers).

What the designation can require in real hiring workflows

WHD says willful violators (and H-1B-dependent employers that file an LCA) must meet additional requirements when they file an LCA, including:

• No displacement at the time of filing: the employer has not displaced a U.S. worker at the time of filing an H-1B visa petition.
• Secondary work-site inquiry: before placing an H-1B worker at a secondary employer’s work site, the employer has inquired about the secondary employer’s intent to displace a U.S. worker.
• Good-faith U.S. worker recruitment steps.
• Offers to equally or better qualified U.S. applicants: the employer has offered the job to any equally or better qualified U.S. worker who applies for the job for which the H-1B worker is sought.

WHD also says willful violators are subject to random investigations by the Department of Labor for a period of up to five years from the date the employer is determined to be a willful violator.

For hiring teams, that means additional compliance review around LCA-related documentation and recruitment/offer handling—especially for employers that file multiple LCAs over time.

Why the July 1, 2026 update is the key date

The practical “clock” for readers is that WHD’s updated roster becomes effective July 1, 2026. In other words: if an employer appears on the effective list, WHD’s willful-violator framework (including the extra LCA attestations and investigation exposure described in Fact Sheet #62S) is the baseline employers and job seekers should understand for compliance context.

What job seekers should watch for

The willful violator list can be one compliance signal job seekers use when evaluating employers that hire through the H-1B process. WHD’s definition and consequences focus on the LCA attestations tied to displacement, recruitment steps, secondary work-site inquiries, and how offers are handled for qualified U.S. applicants—plus the possibility of random investigations within the stated time framework.

Practically, you can look for whether a recruiter or hiring manager can clearly explain recruitment efforts and offer-handling consistent with the kinds of steps WHD identifies—without assuming any single conversation proves compliance.

What’s next

WHD maintains the willful violator list on its website. Employers and workers can monitor that page for future updates and any changes to the roster’s effective timing.

Sources

• U.S. Department of Labor (DOL) Wage and Hour Division — H-1B Willful Violator List of Employers