Certified Payroll for Construction: Complete WH-347 Guide [2026]
Every contractor working on federal or federally-funded construction projects must submit certified payroll reports weekly -- no exceptions. The Department of Labor processed over 1,200 Davis-Bacon enforcement cases in 2025, recovering back wages averaging $1,150 per affected worker. Certified payroll compliance is not optional paperwork -- it is a legal obligation that directly impacts your ability to win and retain government contracts.
This guide walks through every aspect of certified payroll for construction contractors: what the WH-347 form requires, how to complete it accurately, when to submit it, what triggers DOL investigations, and how to build a compliance system that protects your company from penalties and debarment.
Certified payroll requires contractors on federal Davis-Bacon projects to submit weekly WH-347 forms documenting every worker's hours, classification, wage rate, and fringe benefits -- with a signed compliance statement under penalty of perjury. Reports are due within 7 days of each pay period end date.
Whether you are a prime contractor managing multiple subcontractor tiers or a specialty trade working your first federal project, understanding certified payroll requirements prevents costly mistakes that lead to payment withholding, back-wage liability, and contract debarment. For contractors new to government work, our government construction bids guide covers the full landscape of public project opportunities.
What Is Certified Payroll?
Certified payroll is a weekly payroll report that contractors and subcontractors must submit on federal construction projects covered by the Davis-Bacon Act and Related Acts (DBRA). The report uses Department of Labor Form WH-347, which documents every worker's identity, trade classification, hours worked, wage rate, deductions, and net pay for that week.
What makes it "certified" is the Statement of Compliance on the reverse side of the form. The contractor's authorized representative signs this statement under penalty of perjury, certifying that:
- All workers were paid the applicable prevailing wage rate for their classification
- All overtime was paid at 1.5 times the basic hourly rate
- All apprentices are registered in approved programs at the correct ratio
- No deductions were made beyond those permitted by law
- The information is complete and accurate
The Statement of Compliance carries the same legal weight as sworn testimony. Knowingly signing a false certified payroll report constitutes fraud under 18 U.S.C. § 1001, carrying penalties of up to $500,000 in fines and 5 years imprisonment. This is not a routine form -- it is a federal legal document.
The certified payroll requirement exists to enforce prevailing wage standards on government construction projects. Congress enacted the Davis-Bacon Act in 1931 to prevent contractors from undercutting local wage standards on federal projects. The WH-347 form is the primary enforcement mechanism -- it creates a verifiable paper trail that the DOL and contracting agencies use to confirm workers receive the wages specified in the contract's wage determination.
Who Must Submit Certified Payroll
Every contractor and subcontractor at every tier performing work on a covered project must submit their own certified payroll. This includes:
- Prime contractors for all employees working on the project
- First-tier subcontractors for their direct employees
- Lower-tier subcontractors at every level below first tier
- Staffing agencies providing temporary labor to the project
- Owner-operators who perform manual labor on the project
The only exemptions are material suppliers who deliver to the site but do not perform installation or construction work, and professionals (architects, engineers) providing design services rather than construction labor.
When Is Certified Payroll Required?
Certified payroll is required on three categories of construction projects, each governed by specific federal statutes and dollar thresholds.
Federal Davis-Bacon Act Projects
The Davis-Bacon Act applies to all federal construction contracts exceeding $2,000. This covers:
- New construction, alteration, or repair of public buildings
- Federal facility maintenance and renovation
- Military base construction
- Federal courthouse, post office, and office building projects
- National park and federal land improvements
Federally-Assisted Construction (Related Acts)
Over 60 federal statutes extend Davis-Bacon prevailing wage requirements to projects receiving federal funding. These "Related Acts" projects include:
| Funding Source | Typical Projects | Administering Agency | |---|---|---| | Federal Highway Administration (FHWA) | Roads, bridges, highways | DOT | | HUD Community Development Block Grants | Housing, community facilities | HUD | | EPA Clean Water/Drinking Water SRF | Water treatment, sewer systems | EPA | | FAA Airport Improvement Program | Airport construction, runways | FAA | | FEMA Hazard Mitigation Grants | Disaster recovery construction | FEMA | | Infrastructure Investment and Jobs Act | Broadband, transit, energy | Multiple |
These federally-assisted projects represent the largest volume of certified payroll obligations. A city water treatment plant funded by EPA State Revolving Fund loans triggers the same WH-347 requirements as a directly federal project. For more on federal project opportunities, see our federal construction contracts guide.
State Prevailing Wage Projects
Twenty-eight states and the District of Columbia have their own prevailing wage laws (often called "little Davis-Bacon" laws) that require certified payroll on state and locally-funded construction projects. Thresholds vary:
- California: All public works projects exceeding $1,000
- New York: All public works projects (no minimum threshold)
- Illinois: All public works projects (no minimum threshold)
- Massachusetts: All public construction projects
- Ohio: Projects exceeding $250,000 (new construction) or $75,000 (renovation)
States use their own certified payroll forms or accept the federal WH-347 with state-specific modifications. Contractors working in multiple states must track which prevailing wage law applies to each project.
Find federal and state prevailing wage construction projects matched to your trade and location.
Start Free Trial -- Track Certified Payroll ProjectsThe WH-347 Form: Line-by-Line Guide
The WH-347 form has two sides. The front captures payroll data for up to eight workers per page. The reverse side contains the Statement of Compliance. Here is a detailed walkthrough of every field.
Header Section: Project Information
Complete the top section with project identification details:
- Contractor or Subcontractor: Your company's legal name and address
- Payroll No.: Sequential number starting at 1 for the project (Payroll #1, #2, etc.)
- For Week Ending: The Saturday date ending the weekly pay period
- Project and Location: Contract name, number, and physical location
- Project or Contract No.: The federal contract or grant number
Column 1: Worker Name and Identification
List each worker's full name and the last four digits of their Social Security number. Never include the full SSN -- the DOL requires only the last four digits to protect worker privacy. Each worker appears on a separate line. If a worker performs work in multiple classifications, they may require multiple lines.
Column 2: Work Classification
Enter the worker's trade classification exactly as it appears in the project's wage determination. Classifications come from the wage determination published on SAM.gov (formerly WDOL.gov). Common classifications include Carpenter, Electrician, Plumber, Laborer (Group 1-4), Operating Engineer (Group 1-6), Ironworker, and Cement Mason. The classification must match the actual work performed -- not the worker's job title or union affiliation.
Columns 3-5: Hours Worked
Record daily hours for each day of the work week (Sunday through Saturday). Column 3 shows the day-by-day breakdown. Column 4 totals straight-time hours. Column 5 totals overtime hours. All hours over 40 in a week must be recorded as overtime. Daily overtime rules vary by state -- California requires overtime after 8 hours in a day regardless of weekly total.
Column 6: Rate of Pay
Enter two figures: the basic hourly rate and the fringe benefit rate. The basic hourly rate is the cash wage paid to the worker. The fringe benefit rate covers health insurance, pension, vacation, training fund, and other benefits. Together, these must equal or exceed the prevailing wage rate in the wage determination. The overtime rate is 1.5 times the basic hourly rate (fringe benefits are not subject to the overtime multiplier).
Column 7: Gross Amount Earned
Calculate total gross wages: (straight-time hours x basic hourly rate) + (overtime hours x 1.5 x basic hourly rate). Do not include fringe benefits paid to approved plans in the gross wage calculation. Fringe benefits paid in cash directly to the worker are included in gross wages.
Column 8: Deductions
List all deductions from gross wages: federal income tax, FICA, state income tax, and any other authorized deductions. Voluntary deductions (union dues, 401k contributions, child support) must have written worker authorization on file. Do not include employer-paid items (employer FICA match, workers' comp) as deductions.
Column 9: Net Wages Paid
Gross wages minus total deductions equals the net amount paid to the worker. This figure must match the worker's paycheck or direct deposit amount for the hours worked on this specific project. If a worker splits time between Davis-Bacon and non-Davis-Bacon projects, report only the hours and wages for the covered project.
For contractors working on projects that also require bonding, our construction bonding requirements guide explains how bonding and compliance obligations intersect.
How to Complete the Statement of Compliance
The Statement of Compliance on the reverse side of WH-347 is the certification that gives the form its legal weight. This section requires careful attention because the signer accepts personal liability for the accuracy of every data point on the front side.
The Four Certification Paragraphs
The Statement of Compliance contains four numbered paragraphs, and the signer must check the applicable box for paragraph 4:
Paragraph 1 certifies that all workers listed were paid the full weekly wages earned without rebate, directly or indirectly, and that no deductions were made beyond those described in the regulations.
Paragraph 2 certifies that each laborer or mechanic was paid not less than the applicable prevailing wage rate for their classification, including overtime at 1.5x.
Paragraph 3 certifies that each apprentice is registered in an approved program, employed at the correct ratio, and paid the applicable apprentice rate.
Paragraph 4 has three options (check one):
- 4(a): Fringe benefits are paid to approved plans, funds, or programs -- list the programs
- 4(b): Fringe benefits are paid in cash directly to each worker
- 4(c): A combination of plan payments and cash (specify both)
Checking 4(a) when fringe benefits are actually paid in cash (4b) is one of the most frequent Statement of Compliance errors. If your company pays the fringe benefit portion as additional cash wages rather than contributing to health, pension, or training funds, you must check 4(b) or 4(c). The DOL treats this discrepancy as a potential violation regardless of whether workers actually received the correct total compensation.
Who Can Sign
The Statement of Compliance must be signed by an owner, officer, or designated agent of the contractor who has direct knowledge of the payroll information or authority to certify on behalf of the company. The signer's name, title, and the date must be printed below the signature. Many companies designate their payroll manager or project manager as the authorized signer through a written delegation of authority.
Signature Requirements
The DOL accepts both wet ink signatures on paper forms and electronic signatures on digital submissions. Electronic signatures must comply with the Government Paperwork Elimination Act (GPEA) and the contracting agency's specific e-signature requirements. Most electronic certified payroll systems (LCPtracker, ePRS) include compliant e-signature functionality.
Submission Deadlines and Methods
Certified payroll reports are due weekly -- within 7 calendar days after the end of each pay period. Missing deadlines triggers automatic compliance flags in most agency tracking systems.
Electronic Submission Systems
Most federal and state agencies now require electronic certified payroll submission through approved platforms:
| System | Used By | Cost to Contractor | Key Features | |---|---|---|---| | LCPtracker | DOL, HUD, EPA, state DOTs | Free (agency-funded) | Real-time validation, cross-reference checking, automated compliance flags | | ePRS (Elations) | Federal agencies, Army Corps | Free (agency-funded) | Integrated with WDOL wage determinations, batch upload capability | | DIR eCPR | California DIR | Free | California-specific prevailing wage, apprentice ratio tracking | | MyLCM | Various state agencies | Free | Wage determination lookup, subcontractor management portal | | Contractor-uploaded PDF | Some smaller agencies | No cost | Manual WH-347 completed and uploaded as scanned PDF |
Submission Workflow for Prime Contractors
The prime contractor typically serves as the central submission point. The workflow operates on a strict weekly cycle:
- Day 1-2 after pay period: Subcontractors prepare their individual WH-347 reports
- Day 3-4: Subcontractors submit to prime contractor for review
- Day 5-6: Prime contractor reviews, flags errors, requests corrections
- Day 7: Prime contractor submits full package (own payroll + all sub payrolls) to the agency
This timeline leaves almost no margin for error. Contractors who wait until day 6 to start collecting subcontractor reports consistently miss deadlines. The most effective prime contractors establish a firm internal deadline of day 4 for subcontractor submissions, leaving 3 days for review and correction.
What Happens When You Miss a Deadline
Late certified payroll submissions trigger escalating consequences:
- First late submission: Compliance flag in the agency tracking system; written reminder
- Second late submission: Formal notice of non-compliance; progress payment may be delayed
- Chronic lateness: Contract funds withholding until all outstanding payrolls are current
- Extended delinquency: DOL Wage and Hour Division investigation referral
Prime Contractor Responsibilities for Subcontractor Payroll
The prime contractor's certified payroll obligation extends far beyond submitting their own employees' records. Under Davis-Bacon, the prime contractor bears legal responsibility for the wage compliance of every subcontractor at every tier.
Joint Liability for Sub-Tier Violations
This is the critical point that catches many prime contractors off guard: 43% of Davis-Bacon penalty assessments involve subcontractor non-compliance attributed to the prime contractor. When a third-tier electrical subcontractor underpays workers by $3 per hour, the prime contractor faces:
- Joint liability for back wages owed to those workers
- Potential liquidated damages equal to the underpayment amount
- Contract withholding to cover the liability
- Compliance review that delays the entire project
What Prime Contractors Must Do
Effective prime contractors build certified payroll review into their subcontract management process:
Pre-construction requirements:
- Include explicit certified payroll obligations in every subcontract
- Require subcontractors to designate a certified payroll responsible person
- Distribute the project wage determination to every sub before work begins
- Conduct a pre-construction certified payroll training session for all subs
Weekly review process:
- Collect subcontractor WH-347 forms by the internal deadline (day 3-4)
- Cross-reference worker classifications against the wage determination
- Verify overtime calculations (hours over 40, state-specific daily OT rules)
- Confirm apprentice registration numbers and ratios
- Check that fringe benefit payments match the stated method (4a, 4b, or 4c)
- Flag discrepancies and require correction before submission
Documentation retention:
- Maintain all certified payroll records for 3 years after project completion
- Keep copies of subcontractor payroll records separate from your own
- Document any corrections or resubmissions with dated notes
For additional guidance on managing subcontractors on public projects, our prevailing wage resource provides supplementary compliance tools.
Monitor federal and state prevailing wage projects across your service area -- get matched to opportunities that fit your team's capabilities.
Start Free Trial -- Find Prevailing Wage Projects7 Most Common Certified Payroll Errors
DOL Wage and Hour Division investigators report the same certified payroll errors across thousands of construction cases every year. Avoiding these seven mistakes eliminates the vast majority of compliance risk.
1. Worker Misclassification
The error: Listing a worker under a lower-paid classification than their actual duties require. A laborer performing carpenter work, an operating engineer classified as a laborer, or a journeyman electrician classified as a helper.
Why it happens: Contractors assign classifications based on the worker's usual role rather than the specific work performed on the covered project. Some contractors deliberately misclassify to reduce labor costs.
The fix: Match every worker's classification to the actual tasks they perform each day. If a laborer spends 4 hours operating a backhoe, those 4 hours must be classified and paid at the Operating Engineer rate. The Davis-Bacon prevailing wage guide covers classification requirements in detail.
2. Incorrect Overtime Calculations
The error: Calculating overtime at 1.5x the prevailing wage rate (including fringe) instead of 1.5x the basic hourly rate only. Or failing to account for state daily overtime rules.
Why it happens: The Davis-Bacon overtime rule is counterintuitive. The overtime multiplier applies only to the basic hourly cash wage -- fringe benefits are paid at the straight-time rate for all hours. In California and other states with daily overtime, hours exceeding 8 per day are overtime regardless of the weekly total.
The fix: Overtime rate = (basic hourly rate x 1.5) + (straight-time fringe rate). Example: If the prevailing wage is $45/hr basic + $18/hr fringe, overtime is ($45 x 1.5) + $18 = $85.50/hr, not ($63 x 1.5) = $94.50/hr.
3. Missing or Incorrect Apprentice Documentation
The error: Listing apprentices without registration numbers, employing apprentices beyond the approved ratio, or paying apprentice rates to workers not enrolled in a registered program.
Why it happens: Contractors assume internal training programs qualify as apprenticeship programs. Workers are called "apprentices" informally without verifying their registration status.
The fix: Every apprentice on a certified payroll must have a current registration number from a DOL- or state-approved apprenticeship program. The ratio of apprentices to journeymen must not exceed the program's approved ratio. Unregistered workers performing apprentice-level tasks must be paid the full journeyman prevailing wage.
4. Fringe Benefit Calculation Errors
The error: Failing to account for fringe benefits that must be paid in addition to the basic hourly wage. Or double-counting employer-paid benefits that do not qualify as Davis-Bacon fringe benefits.
Why it happens: The distinction between qualifying and non-qualifying fringe benefits is complex. Workers' compensation insurance, employer FICA, and unemployment taxes do not count as fringe benefits under Davis-Bacon -- even though they are employer costs. Only health insurance, pension, vacation, holiday pay, and training fund contributions qualify.
The fix: Identify which employer-paid benefits qualify as Davis-Bacon fringes. Calculate the hourly value of qualifying benefits. Verify the total (basic wage + qualifying fringes) meets or exceeds the prevailing wage. Pay any shortfall as additional cash wages.
5. Incomplete Work Week Reporting
The error: Reporting hours for only certain days rather than documenting every day the worker was on the project. Or omitting workers who performed minor tasks during the week.
Why it happens: Project schedules change, and workers show up for partial days. Administrative staff occasionally perform covered work (moving materials, site cleanup) without being included on the payroll.
The fix: Every person who performs manual or mechanical labor on the project site -- even for one hour during the week -- must appear on the certified payroll for that week. Track daily attendance rigorously using sign-in sheets, badge systems, or GPS-based time tracking.
6. Unauthorized Deductions
The error: Deducting amounts from worker pay without proper written authorization. Common unauthorized deductions include tool purchases, uniform costs, damage charges, and equipment rental.
Why it happens: Contractors apply standard company deduction policies to Davis-Bacon projects without recognizing that federal wage protections restrict what can be deducted from prevailing wages.
The fix: Only deductions required by law (taxes, FICA, court-ordered garnishments) and deductions with specific written worker authorization (union dues, voluntary retirement contributions) are permitted. Any deduction that brings the worker's effective hourly rate below the prevailing wage is a violation -- even with authorization.
7. Failure to Submit "No Work" Payrolls
The error: Not submitting a certified payroll for weeks when no work was performed on the project. Gaps in the sequential payroll numbering trigger compliance reviews.
Why it happens: Contractors assume that if no one worked, no report is needed. But the contracting agency has no way to verify that without a formal record.
The fix: Submit a "no work performed" WH-347 for every week during the contract period when your company had no workers on site. Write "No work performed" across the employee section and submit the form with the Statement of Compliance signed as usual. Maintain sequential payroll numbering without gaps.
Certified Payroll Software Comparison
Manual WH-347 completion on paper or basic spreadsheets works for contractors with fewer than 5 workers on a single project. Beyond that scale, certified payroll software pays for itself in time savings and error prevention.
| Software | Best For | Price Range | Key Strengths | |---|---|---|---| | LCPtracker | Agency-mandated compliance | Free (agency-funded) | Direct agency integration, real-time validation, automatic wage determination lookup | | ePRS (Elations) | Federal project compliance | Free (agency-funded) | Federal wage determination integration, batch processing, DOL-approved format | | Sage 300 CRE | Large GCs with full ERP needs | $500-2,000+/mo | Integrated payroll, job costing, certified payroll generation from standard payroll | | Foundation Software | Mid-size contractors | $300-800/mo | Construction-specific payroll with built-in WH-347 generation and union reporting | | Viewpoint Vista | Enterprise contractors | $500-1,500+/mo | Multi-state prevailing wage, automatic rate tables, certified payroll from payroll module | | ComputerEase | Small-to-mid GCs and subs | $200-500/mo | Prevailing wage job setup, WH-347 generation, integration with AP and job cost | | Points North (Elations) | Subcontractors | $50-200/mo | Focused WH-347 generation, subcontractor portal, electronic submission to prime | | Paycom/ADP with CP module | Contractors using national payroll providers | $100-400/mo add-on | Generates WH-347 from existing payroll data, multi-state compliance |
Choosing the Right Software
The decision depends on three factors:
Project volume: Contractors working on 1-2 prevailing wage projects can use agency-mandated platforms (LCPtracker, ePRS) at no cost. Companies juggling 5+ simultaneous prevailing wage projects benefit from integrated construction payroll software that generates certified payrolls automatically from standard payroll processing.
Company size: Sole proprietors and small subcontractors need focused WH-347 generation tools. Mid-size contractors need payroll integration. Enterprise GCs need multi-project, multi-state, multi-tier certified payroll management with subcontractor portals.
Integration requirements: If your company uses Sage, Viewpoint, or Foundation for accounting, the built-in certified payroll modules are the most efficient path -- they eliminate data re-entry between payroll and certified payroll reporting.
Penalties for Non-Compliance
Davis-Bacon certified payroll violations carry escalating penalties designed to deter underpayment and encourage self-correction. Understanding the penalty structure helps contractors evaluate the true cost of non-compliance.
Administrative Penalties
- Back wages: Full payment of the difference between the prevailing wage and the amount actually paid, for every affected worker, for every hour of underpayment
- Liquidated damages: An additional amount equal to the back-wage liability (effectively doubling the cost)
- Contract funds withholding: The contracting agency withholds sufficient contract funds to cover back-wage and liquidated damage liability
- Cross-withholding: Funds can be withheld from other federal contracts held by the same contractor
Debarment
Contractors who willfully violate Davis-Bacon requirements face debarment from all federal contracts and federally-assisted projects for up to 3 years. Debarment applies to the contractor entity, its principals, and any successor organizations. The DOL maintains a public debarment list that contracting officers check before awarding contracts.
In fiscal year 2025, the DOL debarred 47 construction contractors and their principals. Debarment does not require criminal conviction -- a pattern of violations or a single egregious case is sufficient.
Criminal Penalties
Willful falsification of certified payroll reports is prosecutable under 18 U.S.C. § 1001 (false statements to a federal agency). Penalties include:
- Up to $500,000 in fines per violation
- Up to 5 years imprisonment per count
- Restitution to affected workers in addition to criminal penalties
Criminal prosecution is reserved for the most egregious cases -- contractors who systematically falsify payroll records, operate phantom employees, or engage in kickback schemes. The DOL refers approximately 50-70 construction cases per year to the Department of Justice for criminal investigation.
For related information on bonding and financial compliance, see our construction bonding requirements resource.
Best Practices for Certified Payroll Management
Contractors who build certified payroll compliance into their standard operating procedures avoid the reactive scramble that causes errors and missed deadlines.
Standardize Time Tracking
Implement daily time sheets that capture worker name, classification, project, and hours by task. Digital time tracking (mobile apps with GPS) creates an auditable record that supports your certified payroll. Eliminate the gap between field timekeeping and payroll data entry.
Verify Classifications Weekly
Review worker classifications against actual tasks performed every week before preparing the WH-347. Assign a field supervisor to confirm that each worker's classification matches their duties. Document classification reviews in your project files.
Front-Load Wage Determination Review
Analyze the wage determination at bid time and during pre-construction. Identify every classification you will need, confirm prevailing rates, and set up your payroll system with the correct rates before the first worker sets foot on site.
Create a Subcontractor Compliance Package
Develop a standard package that every subcontractor receives at contract signing: wage determination, WH-347 instructions, submission deadlines, electronic system login credentials, and a named contact for compliance questions. Make expectations clear before work begins.
Conduct Internal Audits Monthly
Assign someone outside the payroll function to spot-check certified payroll reports against time sheets, pay stubs, and benefit plan contributions. Catching errors internally is always better than having the DOL find them during an investigation.
Maintain a Compliance Calendar
Set automated reminders for submission deadlines, wage determination anniversary dates (when rates may change), and apprentice ratio reporting periods. A missed deadline is never worth the compliance risk it creates.
Building a Culture of Compliance
The most effective certified payroll programs are not run by a single payroll clerk -- they are embedded in the company's project management culture. Field supervisors understand classification requirements. Project managers review subcontractor payrolls before passing them to accounting. Estimators build prevailing wage rates into bids accurately. When compliance is everyone's responsibility, errors drop dramatically.
For contractors exploring government opportunities that require this level of compliance readiness, our government construction opportunities resource tracks current projects across federal and state agencies.
Get notified about federal and state construction projects that match your certifications, trade, and service area.
Start Free Trial -- Find Government Projects NowFrequently Asked Questions
What is certified payroll in construction?
Certified payroll is a weekly payroll report (DOL Form WH-347) required on federal Davis-Bacon and related acts construction projects. It documents each worker's name, classification, hours worked, wage rate, deductions, and net pay. The contractor signs a Statement of Compliance certifying accuracy under penalty of perjury. The report ensures that all workers on federally-funded construction projects receive the prevailing wage for their trade classification in the project's geographic area.
When is certified payroll required?
Certified payroll is required on all federal construction contracts exceeding $2,000 and federally-assisted projects funded through programs like FHWA, HUD, and EPA. Twenty-eight states also require certified payroll on state and locally-funded public works projects above varying thresholds. Any project with a Davis-Bacon or state prevailing wage clause in the contract specifications requires weekly certified payroll from every contractor and subcontractor performing on-site labor.
How often must certified payroll be submitted?
Weekly, within 7 calendar days after the end of each pay period. Most agencies require submission through electronic systems like LCPtracker or ePRS. Contractors must maintain sequential payroll numbering throughout the project duration, including "no work performed" reports for weeks with no on-site activity. Late submissions trigger compliance flags and may result in progress payment withholding.
Who is responsible for subcontractor certified payroll?
The prime contractor bears ultimate responsibility for collecting, reviewing, and submitting certified payroll from every subcontractor tier. If a sub-tier subcontractor underpays workers, the prime contractor faces joint liability for back wages, liquidated damages, and potential debarment. Effective prime contractors build internal submission deadlines, review checklists, and compliance training into their subcontractor management process.
What are the penalties for certified payroll violations?
Penalties include back-wage liability for the full underpayment amount, liquidated damages equal to the back wages (doubling the cost), contract funds withholding, debarment from federal contracts for up to 3 years, and criminal prosecution for willful falsification (up to $500,000 in fines and 5 years imprisonment). The DOL recovered over $1,150 per affected worker on average across 1,200+ construction enforcement cases in 2025.
What information goes on the WH-347 form?
The WH-347 requires: worker name and last four digits of SSN, work classification matching the wage determination, daily hours worked (Sunday through Saturday), total straight-time and overtime hours, basic hourly rate and fringe benefit rate, gross wages earned, itemized deductions, and net wages paid. The reverse side contains the Statement of Compliance with certification paragraphs covering wage compliance, overtime, apprentices, and fringe benefit payment method.
How do I handle workers with multiple classifications?
Record hours separately for each classification on the WH-347. If a carpenter spends 4 hours on carpentry work and 4 hours on laborer tasks, list two entries: 4 hours at the Carpenter prevailing rate and 4 hours at the Laborer prevailing rate. If daily records do not segregate hours by classification, pay the highest applicable rate for all hours worked that day. Accurate daily time tracking is essential for split-classification compliance.
Can I use software instead of the paper WH-347 form?
Yes. The DOL accepts electronic certified payroll submissions containing all required WH-347 data fields. Approved platforms include LCPtracker, ePRS, Elations, and construction payroll software packages that generate WH-347 equivalent reports. The digital format must include the equivalent Statement of Compliance with a compliant electronic signature. Many contracting agencies now require electronic submission and no longer accept paper forms.
What is the most common certified payroll mistake?
Worker misclassification is the most common and most costly error. Listing a worker under a lower-paid classification than their actual duties require triggers DOL investigation as a potential prevailing wage violation. The classification on the certified payroll must match the work actually performed during that pay period -- not the worker's job title, union membership, or usual role on non-prevailing-wage projects.
Do apprentices require special certified payroll treatment?
Yes. Apprentices must be registered in an approved DOL or state apprenticeship program and paid the percentage rate specified in their program standards. The certified payroll must include the apprentice's registration number and the name of the sponsoring program. The ratio of apprentices to journeymen must not exceed the approved ratio. Any worker classified as an apprentice without current registration in an approved program must be paid the full journeyman prevailing wage rate.