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For a project covered by the federal Davis-Bacon and Related Acts (DBRA), keep detailed worker-level payroll records while the work is performed, submit a certified payroll every week in which covered work occurs, deliver it within seven days after the regular payment date, and retain the complete project record for at least three years after all work on the prime contract is finished. The contract, funding agency, wage determination and agency instructions control the exact process.
This guide addresses federal and federally assisted construction. It does not make every private project or state and local prevailing-wage job subject to identical rules.
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First determine whether the project is covered
Do not start with a payroll form. Start with the contract and funding documents. The federal weekly certified-payroll duty described here applies to construction contracts covered by the Davis-Bacon Act or a Related Act, including federally assisted construction. A private project with no applicable federal funding may follow different rules, and state or local prevailing-wage programs can impose additional requirements.
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Review the controlling documents
- Identify the federal agency, funding recipient and contract number.
- Confirm that the contract contains the applicable DBRA labor-standards clauses.
- Record the wage-determination number and revision that apply to the project and work location.
- Check whether separate determinations apply to different counties, areas or types of work. Where no multicounty determination applies, more than one determination may be needed.
- Identify the person, agency, portal or other recipient to which certified payroll must be sent.
- Note any agency instructions about file format, naming, electronic signatures, supporting documents and correction procedures.
Keep a copy of every wage determination, revision, contract modification and agency instruction in the project file. If the wage determination changes, preserve the earlier version and document which period and work it governed.
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Set up a project payroll file before the first covered work
A project-specific file makes it possible to trace a worker’s hours and pay from the timecard to the certified payroll and, if necessary, to a correction. Use a secure electronic folder, paper file or both. A construction payroll record book or project folders can organize the material, but an organizational product does not replace any required record or submission.
Create a control sheet
At minimum, place these items at the front of the file:
- Project name, location and contract number.
- Prime contractor and each subcontractor performing covered work.
- Applicable wage-determination number and revision for each area or work category.
- Contract payment schedule and the regular payment date used for payroll deadlines.
- Designated payroll recipient and submission method.
- A weekly calendar showing the payroll period, payment date, seven-day submission deadline, date sent and any correction date.
- Names and authority of people allowed to review, certify and submit payroll.
Flow the labor-standards clause down
Include the DBRA labor-standards requirements in every covered subcontract and require the same obligations in lower-tier subcontracts. Tell each subcontractor what wage determination applies, what information must be supplied, when it is due to the prime, and how errors will be corrected. The prime contractor remains responsible for submitting subcontractor certified payrolls and should actively oversee compliance rather than treating a subcontractor’s form as automatically correct.
Keep complete worker-level records during the work
Record information as work happens. A weekly transmittal is a report; it is not the entire recordkeeping system. The underlying file must support the hours, classifications, rates, deductions, fringe calculations and actual wages shown on the report.
| Record element | What to capture |
|---|---|
| Worker identity and contact data | Name, address, telephone number, email address and an identifying number such as a Social Security number in the protected underlying record. |
| Classification | Each labor classification actually performed, matched to the applicable wage determination. |
| Hours | Daily and weekly hours, separated by classification when a worker performs more than one classification. |
| Pay rates | Hourly rate paid and the rate of fringe contributions or anticipated fringe costs, including how each amount was calculated. |
| Benefits and cash equivalents | Fringe-benefit contributions or permitted cash equivalents, with supporting calculations and records. |
| Deductions | Every deduction taken from the worker’s pay, with the payroll support used to calculate it. |
| Actual wages | The wages actually paid for the reported period, not merely the rate or an accrued amount. |
Protect contact information and full Social Security numbers. They belong in the secured underlying records and should be available for inspection when required, not copied into the weekly transmittal unless the contract specifically requires otherwise.
Handle multiple classifications correctly
If one employee performs work in two or more classifications during a week, separate the hours for each classification. WH-347 instructions call for separate rows while repeating the worker’s entry number. Apply the appropriate rate and fringe calculation to each classification’s hours. Do not place all hours on the classification with the highest or lowest rate simply to simplify the form.
Reconcile time records and payroll
Before preparing the weekly report, compare daily timecards, job-cost records, payroll registers, benefit invoices or trust records, and any approved changes. Resolve differences while the week is still fresh. Keep the source documents that explain adjustments, reclassifications, retroactive payments and corrections.
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Prepare a certified payroll for every covered week
Contractors and subcontractors submit payroll information weekly for each week in which DBRA-covered work is performed. The U.S. Department of Labor states in its WH-347 instructions: “While use of Form WH-347 itself is optional, covered contractors and subcontractors performing work on Federal or federally assisted construction contracts are required by the DBRA regulations and the contract clauses to submit payroll information on a weekly basis.”
Choose WH-347 or an equivalent format
| Choice | Requirement | Practical implication |
|---|---|---|
| WH-347 | Optional federal form with the required payroll fields and Statement of Compliance. | Use the current form and follow the agency’s file and submission instructions. |
| Another payroll format | Permitted only if it contains the same required information and an identical Statement of Compliance. | Map every field to the DBRA requirements before adopting the format. |
An internal payroll register by itself is not enough if it omits a required field or the identical certification. Conversely, a complete WH-347 submission does not eliminate the obligation to preserve the detailed underlying records.
Complete the report header and period information
Identify the project and contract, contractor or subcontractor, work location, payroll number and period ending. Enter the wage-determination number and revision relevant to the work in that period. Use a consistent numbering system so a reviewer can identify missing weeks, replacements and corrected submissions.
Report worker data accurately
List each worker’s identifying number rather than a full Social Security number on the weekly transmittal. Include the classification or classifications, daily and weekly hours, rates, fringe information, deductions and actual wages. Do not copy full addresses, telephone numbers or email addresses onto the weekly report when the DOL instructions call for those details to remain in the underlying records.
Check wage and fringe calculations before certification
Certification is not a clerical approval. It represents that the payroll is accurate and complete and that covered workers received the required wages and fringe benefits, or permitted cash equivalents, for the work reported.
Match work to the correct classification
- Review the duties actually performed during the period.
- Match those duties to the classification in the applicable wage determination.
- Separate hours when the worker performed more than one classification.
- Compare the paid hourly rate and fringe treatment with the required rate for each classification and area.
- Investigate any rate, classification or hour that changed from the prior week.
Do not assume a worker’s job title controls. The work actually performed and the applicable determination control the classification review. If the contract or agency gives a project-specific interpretation, keep that written direction with the payroll support.
Document fringe benefits
For each fringe benefit, retain the contribution record or anticipated-cost calculation and show how the amount relates to the hours and classification reported. If the required fringe is paid as a cash equivalent, document that treatment and include it in the wage calculation. Keep apprenticeship or training records when they affect the wage or fringe analysis.
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Review deductions and net pay
Check that deductions shown on the payroll agree with the payroll register and the worker’s actual payment. Preserve records supporting each deduction and any correction. The certification should not be signed while unexplained differences remain between time, gross wages, deductions, benefits and net pay.
Sign and submit on time
Use the seven-day deadline
DOL guidance places delivery within seven days after the regular payment date for the payroll period. The deadline is tied to the regular payment date, not to when someone finishes typing the form. Check the contract and agency instructions for a different submission workflow, portal cut-off or required supporting file.
- Close the payroll period and confirm the regular payment date.
- Reconcile time, classifications, rates, fringes, deductions and actual wages.
- Prepare the weekly report and attach any documents the contract or agency requires.
- Have the contractor or an authorized person who supervises wage payment review the report.
- Sign the Statement of Compliance and submit it to the designated recipient within seven days after the regular payment date.
- Save the submitted file, confirmation, email, portal receipt or other proof of delivery in the project file.
Use an informed authorized signer
The signer must be able to support the certification, not merely transmit a form. DOL recognizes legally valid electronic signatures that verify the signer’s identity. Use the agency’s approved electronic process and retain the signature record. A typed name without the required identity verification may not satisfy the agency’s process.
Correct errors transparently
If an error is found after submission, preserve the original submission, prepare the corrected payroll or other correction required by the recipient, explain what changed and keep proof that the correction was sent. Never overwrite the only copy of the original certified payroll.
Manage the prime and subcontractor workflow
| Party | Core recordkeeping and submission role |
|---|---|
| Subcontractor | Maintain accurate worker-level records, prepare its own weekly certified payroll for covered work, sign the Statement of Compliance through an authorized person, and provide the payroll and support to the prime by the required internal deadline. |
| Prime contractor | Flow DBRA clauses to subcontractors and lower tiers, review subcontractor classifications and calculations, submit subcontractor certified payrolls as required, maintain the prime’s own records, and exercise oversight of compliance. |
| Funding agency or designated recipient | Receive or maintain payrolls according to the contract and funding arrangement. The responsible entity can differ by project, so verify the designation rather than assuming the owner or agency is the recipient. |
Set the subcontractor due date earlier than the agency deadline so the prime has time to review and correct a payroll. Track every lower-tier contractor, the weeks it worked, the payroll number received, the review date, the date submitted and any outstanding correction.
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Retain the complete project record
Keep payrolls and other basic records for at least three years after all work on the prime contract is completed. The retention period runs from completion of the prime contract’s work, not from the date of an individual weekly payroll.
Preserve, as applicable:
- Worker identity and contact records and protected identifying numbers.
- Timecards, daily reports and classification-by-classification hour detail.
- Payroll registers, checks or payment records, deductions and wage calculations.
- Certified payrolls, Statements of Compliance, submission confirmations and corrections.
- Wage determinations, revisions, contract clauses, modifications and agency directions.
- Subcontracts, lower-tier flow-down documents and subcontractor payroll packages.
- Fringe-benefit contribution records, anticipated-cost calculations and supporting invoices or trust records.
- Apprenticeship and training records when relevant to the work or wage calculation.
- Inspection requests, responses and explanations of classification or payment decisions.
A funding recipient’s or agency’s retention duty may be related to, but distinct from, the contractor’s own duty. Follow the contract and funding instructions even when they require a longer or different administrative process.
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Paper and electronic records: choose the method the contract accepts
Paper payrolls, scanned files, electronic spreadsheets and payroll systems can all be workable if they preserve the required information, signature, audit trail and retention period. DOL permits qualifying electronic submission and signatures, but the project agency controls the accepted portal, file format and identity-verification process.
- For paper: use legible copies, sign each required certification, date the submission and file proof of delivery.
- For electronic files: restrict access to sensitive worker data, preserve the submitted version, retain portal receipts and prevent later edits from replacing the certified copy.
- For either method: use consistent payroll numbers, maintain a deadline calendar and make corrections traceable.
Commercial payroll software may assist with calculations or electronic submission, but verify that it supports the particular project’s wage determinations, multiple classifications, fringe calculations, subcontractor workflow, signature method and agency format. No software replaces contract-specific review.
Common failures and how to fix them
Submitting only a summary
Failure: The contractor keeps the weekly form but not timecards, full worker details or fringe support.
Fix: Maintain the underlying basic records and link them to the payroll number and period.
Using one classification for all hours
Failure: A worker’s week contains multiple types of work, but every hour is reported under one classification.
Fix: Separate the hours by classification, repeat the worker’s entry number as required, and recalculate rates and fringes for each segment.
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Failure: Full Social Security numbers, addresses, phone numbers or email addresses are placed on the weekly report.
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Fix: Use an individual identifying number on the transmittal and secure the fuller details in the underlying file.
Missing the payment-date deadline
Failure: The team counts seven days from the end of the workweek or from payroll preparation.
Fix: Record the regular payment date and calculate the seven-day delivery deadline from that date, then verify any contract-specific portal cut-off.
Signing without reviewing subcontractor data
Failure: The prime forwards a subcontractor payroll without checking classifications, rates, fringes or missing weeks.
Fix: Use a subcontractor review checklist, return discrepancies promptly and retain the review and correction trail.
Replacing the original after a correction
Failure: The corrected file is saved over the original, leaving no record of what was certified first.
Fix: Keep the original, label the correction clearly, document the reason and retain proof of the resubmission.
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- Confirm that covered work occurred during the period.
- Identify the controlling wage determination and revision.
- Collect each contractor’s time, classification, wage, fringe, deduction and payment records.
- Separate hours by classification for workers who performed different work.
- Reconcile source records to the payroll register.
- Complete WH-347 or an equivalent format with all required fields and an individual identifying number.
- Check the project, contract, location, payroll number and period-ending information.
- Review wage and fringe compliance against the applicable determination.
- Obtain the authorized signature on the Statement of Compliance.
- Submit within seven days after the regular payment date to the recipient specified by the contract or funding arrangement.
- Save the submitted copy, confirmation and any correction record.
- Update the project retention file and deadline log.
What to verify on every project
Before relying on this workflow, confirm the project’s federal coverage, funding structure, wage determination and revisions, designated payroll recipient, agency portal or file format, additional project records, and any independent state or local prevailing-wage requirements. DBRA guidance is a federal baseline; it is not a complete state-by-state recordkeeping guide.
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