An H-1B LCA Filing Is Not Your Job Order

A public labor condition application record can show that an employer filed about H-1B, H-1B1, or E-3 workers, a worksite, and a determination the government already made. It cannot show that the employer will accept your candidates, that a seat is open today, or that the worker count on the form is a requisition you are allowed to fill. Read the disclosure as a past filing. Keep any search in a different column.

We used the Labor Department's foreign labor certification page and the FY2026 Q2 LCA record layout. The page describes the public disclosure release. The layout describes fields in that disclosure family. The Q2 layout is not the Q3 data file. Open the layout that matches the file you download. DOL foreign labor certification, accessed October 2026. LCA record layout, FY2026 Q2 PDF, accessed October 2026.

The file is a set of final determinations, not a live board

The Department's page says the Office of Foreign Labor Certification released public disclosure data through the third quarter of fiscal year 2026, drawn from employer applications for prevailing wage determinations and labor certifications, including the LCA programs for H-1B, H-1B1, and E-3. The public files include final determinations issued from October 1, 2025, through June 30, 2026. A row in that window is a determination the office had already issued by June 30, 2026. It is not a job advertisement observed on October 21, 2026, and it is not evidence that the same filing remains the employer's current plan.

The page also covers other programs, including PERM, H-2A, H-2B, CW-1, and prevailing wage. Those files answer different questions. An H-2A or H-2B row is not an H-1B professional search, and a prevailing-wage file is not a list of acceptances. If you export more than one program, label the program on every row before you sort by employer.

A determination can be certified, denied, or withdrawn. The disclosure page describes final determinations. It does not say that a certified application produced a hire, that a denied application produced an agency opening, or that a withdrawn application means the work disappeared. Store the determination status in its own field. Do not translate certified into “still hiring” or withdrawn into “call us instead.”

Worker counts and secondary entities are form fields

The FY2026 Q2 layout describes WORKSITE_WORKERS as the number of workers placed at the first worksite, from the application section on that worksite. It describes SECONDARY_ENTITY as a yes or no flag for whether workers will be placed with a secondary entity, and SECONDARY_ENTITY_BUSINESS_NAME as the name of that entity when the flag applies. Those fields tell you what the application said about placement. They do not tell you which company will employ the worker at the end of the process, and they do not authorize you to recruit for either name.

The same layout describes wage fields for the first worksite, including the offered rate and the prevailing wage, with units such as hour, week, month, and year. A wage on an application is the wage information submitted for that filing. It is not a quote you can offer a candidate, and it is not a market survey of what your other clients pay. If the unit is hourly, do not annualize it in the account note unless you show the arithmetic and keep the original unit beside it.

Employer name, worksite address, and attorney or agent fields can also appear. An attorney on the application is a representative for the filing. That person is not a hiring manager and is not a client who has agreed to your fee. Calling the law firm because it is listed in section E of the form confuses a disclosure contact with a business-development lead.

An LCA row records what an employer asked the government to process, and what determination followed. It does not record an agency job order.

How to store a row so it cannot leak into sourcing

When we read the release note beside the field layout, the risk was a spreadsheet that sorts employers by worker count and treats the largest number as the hottest client. The worker count is a form entry about a worksite on an application that received a determination in a closed reporting window. Rank it only if your question is about filings, and say that the ranking is about filings.

A proposed row for a recruiting desk:

1. Copy the case number, employer name as printed, program, determination, and determination date.
2. Copy the first worksite and the worker count, and label the count as the application's worksite figure.
3. If the secondary-entity flag is yes, copy that business name into a separate employer field. Do not merge it into the filer.
4. Keep the offered wage and its unit. Do not replace them with a salary you infer.
5. Leave “agency search” blank. Fill it only after a permitted conversation about a specific role.

An illustrative status is: “LCA determination in the October 1, 2025–June 30, 2026 file. Not checked against a career page on October 21, 2026. No job order.” The status admits what you have not done. That admission is safer than a guessed opening.

If you later find a public job posting, link it as a new source with its own date. Do not paste the LCA worker count into the posting's openings field. The posting might cover one role. The application might have described a worksite placement that never became this posting.

Where the disclosure is the wrong tool

This file is a poor tool for a confidential search, for a private employer that does not file these applications, and for roles that will not use H-1B, H-1B1, or E-3 status. No row can mean the employer hires only locally, hires through another entity, or has not filed in the quarter you downloaded. Absence is not a clean bill of “no hiring.”

It is also the wrong tool once a client has given you an approved requisition. The requisition controls the search. The LCA row, if you keep it, is background about a past filing. Do not tell a candidate that a certified application proves the job is open, and do not tell a client you “saw their headcount in the DOL file” as if the worker field were a live order.

Stop when the row cannot be tied to a current role and a permitted route. That employer can stay on a research list keyed by the case number and the file vintage. The next useful document is a career-page posting, a supplier instruction, or a conversation with someone who can authorize a search. The disclosure has value as a filing history. It does not become your job order by being public.