In our September webinar, Managing Partner Matthew Hellrung and Senior Counsel Michael Turansick covered urgent H-1B visa updates that every employer and HR professional should know.

Download the Deck →MH H-1B Updates 09-25-25

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Key Takeaway: Continue normal H-1B extensions, transfers, and amendments for now, but prepare for compliance scrutiny and stay alert for litigation or policy shifts that may affect the H-1B program.

1) $100,000 H-1B Filing Fee Proclamation

• A sudden presidential proclamation introduced a $100,000 H-1B filing fee.

• While framed as an entry restriction, it functions as a fee that normally requires APA rulemaking.

• Agencies have since clarified it does not apply to existing H-1B holders, pending petitions, extensions, transfers, or amendments.

• Litigation is expected. For now, employers should continue business as usual while monitoring developments.

2) Proposed Weighted H-1B Lottery Rule

• USCIS has proposed weighting the H-1B lottery by wage levels (LCA Level 1–4) under the beneficiary-centric system.

• This would reduce chances for entry-level roles, including recent graduates.

• Integrity rules would scrutinize changes in job title, location, or wage level after selection.

• Legal challenges are likely, as the law requires a “random selection process.”

3) DOL “Project Firewall” – Increased H-1B Compliance Investigations

• The Department of Labor announced Project Firewall, signaling aggressive H-1B employer investigations in partnership with the DOJ IER.

• Employers should immediately:

  • Audit Public Access Files (PAFs)

  • Confirm that job duties and locations match H-1B petitions

  • Refresh site visit protocols

  • Train managers and HR teams on H-1B compliance