Certified payroll and prevailing wage

Certified payroll explained: Davis-Bacon, the WH-347 and the weekly statement of compliance

Updated November 4, 2026 · 5 min read

If you work on a federally funded or federally assisted construction job, you will be asked for certified payroll every week. It is not complicated once you know what goes in it, but mistakes in it carry real consequences, because each one is signed as a statement of fact. This guide explains the federal requirements. State prevailing wage programs have their own rules, covered in State certified payroll systems.

This is general information, not legal advice. The rules changed in 2023 and parts of them have been challenged in court since, so check the contract and the contracting agency's instructions for each job.

What it is and who needs it

The Davis-Bacon Act requires contractors on federal construction contracts over $2,000 to pay at least the locally prevailing wages and fringe benefits set in a wage determination. The "Related Acts" apply the same labor standards to many federally assisted projects, such as highways, housing and water work funded with federal money. Together they are called the DBRA.

Certified payroll is the weekly report that shows you paid those rates. The requirement comes from the Copeland Act and its regulations, which also prohibit kickbacks from workers' wages.

Every contractor and subcontractor with workers on the covered job submits one for each week in which covered work is performed. The prime contractor is responsible for collecting and submitting its subcontractors' payrolls, and since 2023 the prime is also liable for its subcontractors' unpaid wages.

When and where it goes

Weekly, for every week with work on the contract. Workers must be paid at least once a week.
Due within seven days after the regular pay date for that payroll period.
To the contracting agency if it is a party to the contract, otherwise to the applicant, sponsor or owner who keeps the records for the agency. On most jobs you send it to the prime, who forwards it.

An agency or prime may require electronic submission through a portal, but only if the system takes a legally valid electronic signature, keeps the payrolls available for three years, and allows another method for contractors who cannot use it.

What goes in it

For each worker, each week:

name and an individual identifying number (such as the last four digits of the Social Security number, not the full number);
whether they are a journeyworker or a registered apprentice;
the classification of the work actually performed (for example, Electrician or Laborer), as listed on the wage determination;
straight-time and overtime hours for each day;
the hourly rate, the fringe benefits paid to plans, and any cash paid in place of fringe benefits;
gross pay on this project and for all work that week;
deductions and net pay.

A worker who worked in two classifications in the same week appears on two lines, one per classification, with the hours in each. You can only pay the lower rate for some of the hours if the records accurately show the time spent in each classification.

The WH-347

The Department of Labor publishes Form WH-347 for certified payroll. Using it is optional: the regulations allow any format with the same information and a statement of compliance with identical wording. Many agencies and compliance portals expect the WH-347 layout anyway.

The current form is Rev. January 2025 (OMB 1235-0008). It added fields such as the wage determination number, a sequential payroll number, a checkbox for the final payroll, and a per-worker table of fringe benefit plans. In December 2025 the Department of Labor released an online fillable version and an annotated guide that walks through every field. If you still use an older version, check what your agency or prime accepts.

The statement of compliance

The second page is a signed statement that:

the payroll is correct and complete, and the required records are being kept;
each worker was paid in full, with no rebates and only permitted deductions;
each worker was paid at least the wage determination's rate and fringe for the classification of work they actually performed.

It is signed by an owner or officer of the company, or someone who pays or supervises payment, with a handwritten or legally valid electronic signature. A scanned or photocopied signature does not count.

Falsifying a certified payroll can lead to civil or criminal prosecution under the federal false statements law and the False Claims Act, and to debarment from government work for three years.

How long to keep records

Keep the underlying payroll records, the certified payrolls and the contract documents for at least three years after all work on the prime contract is complete. Since 2023 the basic records must also include each worker's phone number and email address, which do not go on the weekly report. If records are not produced when asked, the agency can suspend payments on the contract.

The mistakes investigators see most

The Department of Labor lists these as typical problems on DBRA jobs:

workers classified in a lower-paid classification than the work they did;
prevailing wage or fringe not paid for all hours, including overtime;
hours not recorded by classification;
apprentices paid apprentice rates without proof of registration;
payrolls not submitted weekly;
the wage determination and Davis-Bacon poster not posted on site.

The Wage and Hour Division recovered about $26.8 million in back wages for 5,812 workers on government contracts in fiscal year 2025, up from about $14.1 million in 2024.

Make it routine

Record each worker's classification with their hours every day, not at the end of the week.
Keep apprentice registration documents on file before paying apprentice rates.
Use the wage determination incorporated in your contract, and keep a copy.
Number payrolls in sequence, mark the last one as final, and ask whether the agency wants "no work" weeks reported.
Have the person who signs review the payroll, not just sign it.

See Getting prevailing wage right for wage determinations, fringe benefits and apprentices in more detail.