Certified payroll is the weekly compliance report contractors and subcontractors submit on federally funded construction projects. Submit Form WH-347 each week to certify workers received the prevailing wage for their trade and location. Moreover, the 2024 Davis-Bacon rule update was the most significant overhaul in four decades. It expanded covered work to off-site prefabrication, raised civil penalties to $13,508 per violation and added anti-retaliation protections. Consequently, certified payroll compliance in 2026 is more demanding and more heavily enforced. Additionally, 32 states have prevailing wage laws that layer on top of federal requirements.
Certified Payroll for Construction — Quick Facts 2026
Loreto Barrionuevo's Perspective — Certified Payroll Is a Systems Problem, Not a Forms Problem
After working with construction contractors on certified payroll for over a decade, the pattern is clear: compliance failures almost never start with the WH-347 form itself. They start upstream — in the timesheets, in the trade classifications and in the fringe benefit calculations. Specifically, a worker clocked to the wrong classification in the time tracking system produces a certified payroll error every single week until someone catches it. Moreover, the 2024 Davis-Bacon rule changes have expanded the universe of covered work significantly. Contractors who assumed off-site prefabrication was outside Davis-Bacon may now have new certified payroll obligations. Verify your coverage before the first payroll run on any new project. Consequently, treat certified payroll compliance as a payroll system design question — not a reporting task. When your classifications and fringe tracking are correct before the first payroll run, the WH-347 becomes an automatic output rather than a weekly scramble.
What Is Certified Payroll for Construction?
Certified payroll is a weekly report contractors submit to prove workers received the prevailing wage. It covers every laborer and mechanic on the project. Specifically, it lists each worker's name, classification, hours by day, pay rate, gross wages, deductions and net pay. Each submission must include a signed Statement of Compliance certifying accuracy under penalty of perjury.
The requirement comes from the Davis-Bacon Act of 1931 and applies to all covered contracts over $2,000. Additionally, the Copeland Anti-Kickback Act requires weekly wage statements alongside the certified payroll. Furthermore, 32 states have Little Davis-Bacon Acts applying to state-funded projects — federal funding is not required. Consequently, multi-state contractors face layered certified payroll obligations with different forms and portals per jurisdiction.
What Must Be on a Certified Payroll Report (Form WH-347)?
| Field | Required Detail |
|---|---|
| Worker name and address | Full legal name and address |
| Identification number | Last four digits of Social Security number |
| Work classification | Trade or occupation — must match DOL wage determination exactly |
| Hours worked | Daily hours by day of week + total — straight time and overtime listed separately |
| Rate of pay | Base hourly rate paid — must meet or exceed prevailing wage rate |
| Fringe benefits | Cash or benefit plan contributions per hour toward the fringe portion of the wage determination |
| Gross wages | Total earnings for the week before deductions |
| Deductions | Itemised — taxes, union dues, benefit contributions, garnishments |
| Net wages paid | Actual take-home pay after all deductions |
| Statement of Compliance | Signed certification on page 2 — verifies accuracy under penalty of perjury |
How to Complete and Submit Certified Payroll — Step by Step
Pull the correct wage determination before the project starts
Each covered project has a DOL wage determination specific to the county and type of construction work. Specifically, verify the wage determination in SAM.gov or the agency's contract documents before your first payroll run. Using the wrong determination is one of the most common audit triggers.
Classify every worker correctly
Each worker's classification must match the actual work they perform — not their job title or a lower-rate classification. Specifically, a carpenter doing carpentry work must be paid at the carpenter rate. Misclassification is the most common violation DOL auditors look for first. Additionally, apprentices must be individually registered in a DOL-approved program to qualify for apprentice rates.
Track daily hours by classification and project
Workers who split hours between covered and non-covered work in the same day need separate hour tracking for each. Consequently, time tracking systems must assign hours to the correct project and trade classification — not just to the worker. Additionally, overtime for Davis-Bacon projects follows FLSA rules: 1.5× for hours over 40 in a workweek.
Calculate fringe benefits correctly
The prevailing wage determination has two components: a base wage rate and a fringe benefit rate. You can meet the fringe obligation through cash wages, contributions to a bona fide benefit plan or a combination. Specifically, base rate plus fringe must equal or exceed the full prevailing wage for the classification.
Complete and sign Form WH-347 within 7 days of the pay date
Specifically, submit the completed WH-347 to the contracting agency — or the designated system such as LCPtracker for DOE projects — within seven calendar days of the regular payment date. A signed Statement of Compliance must accompany every submission. Moreover, submit a "No Work Performed" payroll for any week when no work occurs — do not skip weeks.
Retain all records for at least 3 years after project completion
Federal regulations require retaining certified payroll records for at least three years after project completion. Additionally, state prevailing wage laws may require longer retention. Specifically, records must be available for DOL inspection on request. Digital recordkeeping in a construction payroll system significantly simplifies audit response.
The Most Common Certified Payroll Errors — and How to Avoid Them
| Error | Why It Happens | How to Prevent It |
|---|---|---|
| Worker misclassification | Job title used instead of actual duties performed | Classify based on work done, not title — verify monthly |
| Wrong wage determination applied | Using a different county or project type rate | Pull the exact determination from the contract documents at setup |
| Fringe underpayment | Only paying cash wage, missing the fringe component | Track base and fringe separately in payroll system |
| Missing or late submissions | Weekly cadence overlooked, especially on slow weeks | Set automatic calendar reminders — submit "No Work" reports when idle |
| Unregistered apprentices | Apprentices paid at apprentice rates without proper DOL registration | Verify registration status before placing any apprentice on a Davis-Bacon project |
| 1099 contractors omitted | Assuming subcontractors are outside Davis-Bacon | Include all workers performing covered work regardless of W-2 / 1099 status |
Frequently Asked Questions — Certified Payroll for Construction
Who must submit certified payroll?
Every contractor and subcontractor employing laborers or mechanics on a Davis-Bacon covered construction project must submit certified payroll weekly. This includes prime contractors, subcontractors and lower-tier subcontractors. According to DOL Wage and Hour Division enforcement data, prime contractors are ultimately responsible for their subcontractors' compliance — so review all subcontractor submissions before forwarding them to the contracting agency.
What is the penalty for missing a certified payroll submission?
Civil penalties reach $13,508 per violation in 2026. Willful or repeated violations can result in debarment from all federal contracting for up to three years. Late or inaccurate submissions also trigger compliance investigations. These can escalate to a full DOL audit — with an average investigation cost of $45,000 according to industry data. Additionally, back wages plus interest are owed to any worker who was underpaid.
Does certified payroll apply to subcontractors?
Yes. Every subcontractor performing covered construction work on a Davis-Bacon project must submit their own certified payroll weekly — regardless of contract size or tier. Specifically, the DOL's 2024 rule changes also extended coverage to certain off-site fabrication operations where a significant portion of the project work is performed. Consequently, prefabrication shops supplying material for Davis-Bacon projects should verify whether their operations trigger certified payroll obligations.
Can software automate certified payroll reporting?
Yes. Construction-specific payroll software like eBacon, Lumber, Miter and Payroll4Construction automates WH-347 generation, prevailing wage rate updates and electronic submission. Specifically, these platforms pull hours from time tracking, apply classification rates, calculate fringe obligations and produce the WH-347 immediately after payroll runs. Consequently, the certified payroll report that used to take hours produces in minutes when the underlying payroll data is correct.
Sources: DOL Wage and Hour Division · Davis-Bacon Act · eBacon · hh2 · Payroll4Construction · BlueWave HR · Updated March 2026
