Before Sponsoring, Run the DOL H-1B Debarment and Willful-Violator Check
Pull both DOL H-1B debarment and willful-violator lists before approving a sponsorship, because the second can add five-year LCA attestations and audits.
| By | The Petition File — Newsroom |
|---|---|
| Filed | 14 September 2026 |
| Read | 3 MIN |
The deadline comes before the offer
The deadline is the first thing to pin down. If the employer is debarred today, the petition cannot be approved; if the employer is a willful violator, the filing can still move but with a five-year compliance tail.
A debarment hit after offer approval forces a pause, a re-check, and sometimes a different filing strategy. The check belongs in the approval workflow, where the sponsor still controls the next step. It is the point where a bad match is still fixable.
Two lists answer two different filing questions
The debarment roster asks whether the employer may file now. The willful-violator list asks whether the employer will carry extra attestations and audit exposure for years. The two lists answer different questions, so the check needs both before approval. A current debarment is a bar for a new sponsorship. A prior finding can be a longer exposure.
The debarment window controls the filing date. The willful-violator window controls what the employer must certify and what may be audited. A filing team that checks only the debarment roster can miss the longer exposure that follows a prior finding.
For up to five years after a willful-violation finding, every new LCA filed by the affected employers must include additional attestations about not displacing U.S. workers, genuine recruitment, and offering the job to equally or better-qualified U.S. applicants. The agency may also run random compliance reviews of willful violators across that five-year period, so oversight continues after the debarment date ends.
The paired check belongs before approval
Run the check before the offer is approved, not after the petition is drafted. Each item below is quick to run, and each one maps to a filing risk.
- Pull the federal H-1B debarment roster, maintained publicly by the DOL Wage and Hour Division.
- Search the employer's legal name, trade name, and relevant affiliates.
- Pull the DOL willful-violator list, publicly searchable on the DOL website and updated regularly.
- Compare the effective date, the debarment window, and the filing date.
- If the employer is a willful violator, flag the added LCA attestations and random-audit exposure.
- Document the result before the sponsorship is approved.
Start with the roster, because it controls whether the petition can be approved. The name search catches matches that a single legal name can miss. Date comparison turns the list result into a filing decision. Documentation gives counsel a record that the check happened before approval.
Record the pull date, the names searched, the result, and the reviewer. A legal name match is the cleanest hit. A trade name or affiliate match needs counsel review. The file should show who made the call and what was checked.
If the roster returns a match, stop the approval and send the match to counsel. If the willful-violator list returns a match, continue only with counsel review and the longer exposure flagged in the file.
The live pull also matters because a name can appear under a trade name or an affiliate that the offer letter does not use. A clean result is still a result, and it should be recorded.
The current lists show the dates that matter
Use the current lists as a working example, not a substitute for the live pull. As of September 1, 2026, the DOL's official H-1B debarment list identified five employers as debarred or disqualified. The DOL willful-violator list effective July 1, 2026 named GowraTech LLC, Renotek Group LLC, Seeloz Inc., and Sherwood at Mount Dora Inc. doing business as Sherwood Academy.
The debarment windows are the dates to compare against the filing date: GowraTech LLC, May 12, 2025 through May 11, 2027; Renotek Group LLC, August 8, 2025 through August 7, 2027; Seeloz Inc., March 4, 2026 through March 3, 2028; and Sherwood at Mount Dora Inc., May 26, 2026 through May 25, 2028.
The dates matter because the debarment window and the longer exposure can run on different timelines. A filing date inside the debarment window cannot be approved. A filing date after the debarment window can still carry the longer exposure. Counsel should treat the dates as a filing calendar.