Certified payroll is a weekly payroll report that contractors and subcontractors must submit when working on federally funded construction projects. Specifically, it proves that workers on covered projects are being paid at least the prevailing wage rates required by the Davis-Bacon Act. Moreover, the Davis-Bacon Act applies to all federal and federally-assisted construction contracts exceeding $2,000 — covering an estimated $217 billion in annual construction spending. Consequently, certified payroll is a mandatory compliance obligation for any contractor bidding on government construction work. Additionally, the updated Form WH-347 has been in effect since January 2025, and the old form is accepted until September 30, 2026.
Certified Payroll — Quick Facts 2026
Loreto Barrionuevo's Perspective — Certified Payroll Is Not Just More Paperwork
Contractors who treat certified payroll as an administrative burden tend to have the most compliance problems. Specifically, the mistakes I see most often are not intentional underpayment — they are classification errors. A worker is assigned to the wrong trade classification, which carries a lower prevailing wage rate, and the contractor does not catch it until the DOL audit. Moreover, the 2024 Davis-Bacon rule changes expanded covered work to include certain off-site prefabrication activities. More contractors are now subject to certified payroll than before. Additionally, fringe benefit calculations are a consistent pain point. The prevailing wage determination includes both the base rate and the required fringe benefits per hour. Consequently, build certified payroll compliance into your bid cost as a line item — not as an afterthought.
What Is Certified Payroll?
Certified payroll is a weekly payroll report submitted by contractors and subcontractors on federally funded construction projects. It certifies that all workers are paid at least the prevailing wage and fringe benefit rates set by the DOL for their specific trade and location. The report is submitted using Form WH-347. Specifically, the requirement stems from the Davis-Bacon Act of 1931. It was passed to prevent contractors from importing low-wage workers to undercut local labor rates on public construction projects.
According to the Department of Labor Wage and Hour Division, the Davis-Bacon Act applies to all federal and federally-assisted construction contracts exceeding $2,000. Additionally, the Davis-Bacon Related Acts extend the same requirements to federally assisted projects. These include HUD housing, highway projects, EPA water systems and IIJA-funded energy projects. Consequently, certified payroll obligations are far more common than many contractors realise.
Who Must Submit Certified Payroll?
Every contractor and subcontractor employing laborers or mechanics on a Davis-Bacon covered project must submit certified payroll weekly. Specifically, this includes prime contractors, subcontractors and lower-tier subcontractors. It applies to workers performing manual or physical labor — not office or administrative staff. Additionally, since the 2024 Davis-Bacon rule update, covered work can include certain off-site activities where a significant portion of the project work is completed. Consequently, prefabrication shops and off-site assembly operations may now be subject to certified payroll for the first time.
Covered Worker Classifications
Certified payroll applies to laborers and mechanics — a broad DOL definition that covers most hands-on construction trades. In practice, covered classifications include carpenters, electricians, plumbers, ironworkers, painters, concrete finishers, equipment operators and laborers. Furthermore, each classification has its own prevailing wage rate set by the DOL's wage determination for that county and project type. Assigning a worker to the wrong classification is the most common certified payroll error. It is specifically what DOL auditors check first.
Certified Payroll Requirements — What to Include in Form WH-347
| Data Field | Required Detail |
|---|---|
| Employee information | Full name, address, last four digits of Social Security number |
| Work classification | Trade or occupation (must match DOL wage determination) |
| Hours worked | Daily and weekly hours — straight time and overtime separately |
| Rate of pay | Hourly rate actually paid — must meet or exceed prevailing wage rate |
| Gross wages | Total earnings before deductions for the week |
| Deductions | Itemised payroll deductions (taxes, benefits, garnishments) |
| Net wages paid | Actual take-home pay after all deductions |
| Fringe benefits | Amount paid per hour into bona fide benefit plans |
| Statement of compliance | Signed certification that information is true and correct |
Certified Payroll Deadlines and Submission
Certified payroll reports must be submitted weekly. Specifically, they cover the previous week's work and are due to the contracting agency within seven days of the regular pay date for that period. The contracting agency then forwards a copy to the DOL on request. Additionally, some agencies require electronic submission through specific platforms — the Department of Energy uses LCPtracker for IIJA-funded projects. Notably, contractors must also post the Davis-Bacon Compliance Poster WH-1321 at every job site where covered work is performed.
Frequently Asked Questions — Certified Payroll
What is the difference between certified payroll and regular payroll?
Regular payroll calculates employee wages based on hours worked and pay rates, withholds applicable taxes and distributes net pay. Certified payroll does all of that, plus requires weekly submission of Form WH-347. This report confirms workers are paid at least the DOL-determined prevailing wage for their trade and location. Specifically, certified payroll is only required on federally funded or federally assisted construction projects over $2,000. Regular payroll applies to all employers regardless of project type.
What is the prevailing wage under the Davis-Bacon Act?
The prevailing wage is the minimum wage and fringe benefit rate the DOL sets for each trade classification and geographic area. Contractors must pay workers at least this rate on covered projects. Specifically, the DOL determines prevailing wages by surveying wages paid to workers in similar occupations in the same locality. The 2026 prevailing wage rates reflect the DOL's updated 30% threshold methodology. This results in higher wage determinations in most areas than previous years.
Who enforces certified payroll requirements?
The DOL's Wage and Hour Division enforces Davis-Bacon certified payroll requirements at the federal level. The contracting agency — HUD, DOT, EPA or another federal department — also has oversight responsibility for projects it funds. Contractors submit certified payroll weekly to the contracting agency or its designated system. The DOL can audit records, interview workers and impose back wage liability, civil penalties and debarment for violations. According to DOL Wage and Hour Division enforcement data, audit activity increased significantly following the 2024 Davis-Bacon rule update.
How long must certified payroll records be kept?
Davis-Bacon certified payroll records must be retained for at least three years after the work is completed. Specifically, this includes Form WH-347 submissions, underlying payroll records, fringe benefit documentation and any correspondence with the contracting agency about classifications or rates. Additionally, some agency contracts or state prevailing wage laws require longer retention periods. Consequently, a seven-year retention policy covers most applicable requirements across federal, state and potential litigation timelines.
Sources: DOL Wage and Hour Division · FHWA · Davis-Bacon Act · BlueWave HR · eBacon · LumberFi · Updated March 2026
