What is certified payroll? A plain-English guide for first-timers

You just won a job, and somewhere in the subcontract it says Davis-Bacon, prevailing wage or “certified payroll.” The general contractor wants a report from you every week. If this is your first job like that, the term can sound like a special kind of payroll. It is not.

Certified payroll is your normal payroll records for one project, laid out in a set format, with a signed statement that your workers were paid at least the required wage. The signature is the “certified” part.

Why you are being asked for it

The Davis-Bacon Act requires that laborers and mechanics on covered construction contracts be paid at least the prevailing wage and fringe benefits listed on a wage determination attached to the contract. It applies to federal construction contracts over $2,000, and a group of “Related Acts” applies the same rules to many federally assisted projects, such as work funded through federal grants and loans.

The weekly report comes from the Copeland Act, the anti-kickback law, which requires contractors on these jobs to furnish a statement of the wages paid each employee for the prior week. The Department of Labor’s rules in 29 CFR Parts 3 and 5 spell out how.

Many states also run their own prevailing wage programs for state and local public works, with their own reporting rules. A single job can fall under both. That is covered in state prevailing wage vs Davis-Bacon.

Who has to submit

Every contractor and subcontractor, at every tier, that has laborers or mechanics working on the site of covered work. The regulation makes the prime contractor responsible for submitting all subcontractors’ certified payrolls, so in practice you send yours to the prime and they pass it on. On a federal contract the report goes to the agency. On a federally assisted project it goes to the owner or sponsor that keeps the records. Some agencies and primes use an online system for this.

“Laborer or mechanic” means workers whose duties are manual or physical, including apprentices and helpers. It does not include people whose duties are primarily administrative, executive or clerical. A foreperson who spends more than 20 percent of a week on hands-on work counts as a laborer or mechanic for that time.

You report weekly, for every week in which covered work is performed. The Copeland regulations set the delivery deadline at 7 days after the regular payday for that pay period. Ask your prime for their own cutoff, since they have to send your report up the chain.

What the report contains

For each worker, for each week:

• Name and an identifying number. The last four digits of the Social Security number are fine on the weekly report. Full numbers and addresses stay in your own records.
• The classification of work actually performed.
• Hours worked each day, split into straight time and overtime.
• The hourly rate paid, plus fringe benefits paid in cash or to plans.
• Gross pay, deductions and net pay.

The Department of Labor’s Form WH-347 is the common layout. Using it is optional, and any format with the same information is allowed, but many primes ask for the WH-347 or their own portal. Download the current version (revised January 2025) from dol.gov. For a field-by-field walkthrough, see how to fill out a WH-347 without getting it kicked back.

Who signs

Each report is accompanied by a Statement of Compliance, which is page 2 of the WH-347. It must be signed by the contractor, or by an agent who pays or supervises the payment of the workers, with a handwritten or legally valid electronic signature.

By signing, that person certifies that:

• The payroll information is correct and complete, and the required records are being kept.
• Every worker was paid the full weekly wages earned, with no rebates, and with only the deductions allowed under 29 CFR Part 3.
• Every worker was paid at least the wage and fringe rates for the classification actually performed.
• Anyone paid as an apprentice is registered in an approved program.

Do not sign a report you have not tied back to your payroll register. The form itself warns that willful falsification may lead to civil or criminal prosecution and debarment.

How long to keep records

At least 3 years after all the work on the prime contract is completed. That is the whole project, not just your part of it. The rule covers your regular payroll records, your certified payrolls, and your subcontract and related documents. Keep full Social Security numbers, addresses and contact details on file even though they stay off the weekly report, because the agency or the Department of Labor can ask for them. State programs may set their own retention periods.

What happens if it is wrong

• Underpaid workers. You owe back wages plus interest.
• Withheld payments. The agency can withhold money from the contractor to cover unpaid wages, and can suspend further payments if required records are not submitted. The prime and the responsible subcontractor are liable for unpaid wages, so expect your prime to look closely at your reports.
• Debarment. A contractor found to have disregarded its obligations can be barred from federal and federally assisted contracts for 3 years.
• False statements. Falsifying the certification can bring civil or criminal liability.

A first-job checklist

1. Get the wage determination from your subcontract, with its decision number and modification.
2. Ask the prime how to submit, to whom, in what format and by what day, and whether a state program also applies.
3. Check that the wage determination and the Davis-Bacon poster (WH-1321) are posted at the site. Contractors and subcontractors must post them where workers can see them.
4. Match each worker’s actual work to a classification on the determination. If your trade is not listed, ask about adding one before work starts.
5. Track hours by day, by project and by classification.
6. Pay at least weekly, and make only permitted deductions.
7. Collect registration paperwork for any apprentices.
8. Decide who signs, and set up a file you will keep for at least 3 years.

Where Payrung fits

Payrung is being built to take the payroll export you already run and produce the weekly WH-347 and the state and portal formats from it, flagging classification and fringe mismatches before you sign. If you would like early access, join the waitlist.

This guide is general information, not legal or payroll advice. Confirm requirements with your contracting agency or a qualified advisor.