Which projects require certified payroll?

Federally funded or federally assisted construction contracts over $2,000 trigger the Davis-Bacon Act and its certified payroll requirement. Most states have their own 'little Davis-Bacon' prevailing wage laws with their own thresholds and their own forms — California uses the DIR eCPR system, New York and Maryland have separate portals, and thresholds range from $1,000 to over $500,000 depending on the state and the type of public body funding the work.

How often is certified payroll due?

Weekly. A report is due for every week in which work was performed, generally within seven days of the pay date, and it must be submitted continuously until the contractor's work on the project is complete. Weeks with no work performed still require a 'no work' filing on many projects. Late or missing reports are the most common reason a payment application gets held.

How do you fill out a WH-347 form?

Each row is one worker. You list name and an individual identifying number (the last four of the SSN — never the full number), the work classification from the applicable wage determination, hours worked on that project by day, total hours, the hourly rate paid, gross earnings, each deduction itemized, and net pay. If the worker split time across classifications, each classification gets its own row. Page 2 is the Statement of Compliance, where you state whether fringe benefits were paid into approved plans or in cash, and sign.

What are the penalties for false certified payroll?

Because the Statement of Compliance is signed under penalty of perjury, a knowingly false certified payroll is a federal crime, exposing the signer to fines and up to five years imprisonment, plus False Claims Act liability. The more routine consequences are withheld contract payments, back-wage restitution with liquidated damages, and debarment from public work for up to three years.

What is the difference between certified payroll and prevailing wage?

Prevailing wage is the obligation: the minimum hourly rate and fringe benefit amount you must pay a worker in a given classification and locality, published in a wage determination. Certified payroll is the proof: the weekly report that demonstrates you actually paid it. You can be paying prevailing wage correctly and still be in violation for failing to report it properly.

What is certified payroll? A contractor's guide to WH-347

Q: What is certified payroll?

Certified payroll is a weekly payroll report that contractors and subcontractors on government-funded construction projects must submit, showing every worker on the site, their trade classification, hours worked by day, pay rate, fringe benefits, and deductions. It is filed on Form WH-347 or an accepted equivalent, and it carries a Statement of Compliance signed under penalty of perjury — that signature is what makes the payroll 'certified.'

What it is

Certified payroll is the weekly report that proves you paid prevailing wage on a public job. Every worker, every classification, every hour, every deduction — filed weekly, and signed under penalty of perjury.

That last part is the part contractors underestimate. The Statement of Compliance on page 2 of the WH-347 is a sworn federal statement. Signing it because a payroll clerk assembled the numbers and it looked about right is a materially different act from signing a lien waiver.

Which jobs trigger it

Federal. The Davis-Bacon Act applies to federally funded or assisted construction contracts over $2,000. Roughly sixty "related Acts" extend it to work funded through federal programs — highway money, HUD, transit, water infrastructure — which is why a job with no federal agency anywhere in sight can still be Davis-Bacon covered because of the funding source three layers up.

State. Most states run their own prevailing wage law with its own threshold, its own wage determinations, and its own filing system. California's DIR eCPR portal, New York's, Maryland's, and Pennsylvania's all differ in format and cadence. On a job covered by both federal and state law, you comply with both, and you pay the higher of the two rates.

The practical failure here is not ignorance of the law. It is a contractor who does one public job a year, assumes the state form is close enough to the federal one, and discovers otherwise when payment is withheld.

Filling out the WH-347

Page 1 is the payroll. One row per worker per classification:

Name and an individual identifying number — the last four digits of the SSN only. Full Social Security numbers and home addresses have not belonged on the submitted form since 2008. Contractors still put them there.
Work classification, taken from the wage determination that applies to this contract. Not your internal job title.
Hours worked on this project, by day, with overtime broken out.
Rate of pay and gross earnings. If the worker was on other jobs that week, show project gross over total gross.
Every deduction, itemized, with anything unusual explained.
Net wages paid.

Page 2 is the Statement of Compliance. The part that gets people is section 4: whether fringe benefits were paid into approved plans, paid in cash, or some combination — and if there are exceptions, they must be listed. Fringe handling is where most genuine underpayments hide.

The errors that hold up payment

Classification drift. A worker doing pipefitting is reported as a laborer because that is what your accounting system calls him. This is the single most expensive error, because the fix is back wages at the difference for every hour, and it usually spans months before anyone catches it.

Split classifications collapsed into one row. A worker who spent Tuesday on two classifications needs two rows. Averaging the rate is an underpayment for part of the day.

Fringe benefits mis-stated. Cash-in-lieu reported as plan contributions, or plan contributions that do not actually annualize out to the credited hourly amount.

Overtime computed on base rate only. Overtime is computed on the basic hourly rate, with the fringe added on straight for the overtime hours — not time-and-a-half on base with the fringe forgotten.

Missing weeks. No report for a week with work, or no "no work" filing where the project requires continuous submission. This holds pay applications more often than any substantive wage error.

Apprentices without registration. Paying an apprentice rate for someone who is not in a registered program, or exceeding the allowed apprentice-to-journeyman ratio on site. The rate reverts to full journeyman for every hour.

Owner-operators and independent contractors. Almost always covered laborers or mechanics on a Davis-Bacon site regardless of what the agreement calls them.

Why this eats so much time

Nothing here is intellectually hard. It is that the inputs live in five places — the timekeeping system, the daily reports, the wage determination PDF, the union agreements, and the payroll register — and reconciling them by hand every single week, per project, is a job.

That reconciliation is what we automate. The system reads the daily reports and timesheets, applies the correct wage determination and classification for the project and locality, computes fringe correctly including cash-in-lieu, produces the WH-347 or the state equivalent, and flags the exceptions for a human before anyone signs anything. The signature stays with a person. It should.

More on that here: the certified payroll system. For state-specific detail, see Maryland prevailing wage requirements for general contractors and what is certified payroll and why Maryland GCs get it wrong.

This is general information about a compliance process, not legal advice. Wage determinations, thresholds, and filing requirements vary by jurisdiction and change over time — confirm the requirements for your specific contract.