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Manage certified payroll as a controlled weekly evidence process: first determine which labor-standard rules and wage determination apply, then collect time and pay data by worker and classification, verify it against source records, certify and send it to the contract’s designated recipient, and preserve the complete record set. On covered federal or federally assisted work, weekly payroll information and a Statement of Compliance are required; Form WH-347 is optional, not a substitute for the underlying requirements.
What certified payroll reporting actually requires
Certified payroll is more than filling out a government form. It is the recurring process that demonstrates who performed covered work, what work they performed, how many hours they worked, what rates and fringe benefits applied, what they were paid, and whether the contractor complied with the applicable labor standards.
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For a federal or federally assisted construction contract covered by the Davis-Bacon and Related Acts (DBRA), contractors and subcontractors must submit payroll information weekly for each week in which covered work is performed. Each weekly submission must include a Statement of Compliance signed by the responsible official. The U.S. Department of Labor (DOL) describes the requirement this way: use of Form WH-347 is optional, but covered contractors and subcontractors must submit weekly payroll information under the DBRA regulations and contract clauses.
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Start with coverage, funding and contract clauses
Confirm whether federal DBRA applies
Before the first payroll period, review the prime contract and every modification for labor-standards clauses. Confirm whether federal funds or assistance trigger DBRA coverage and identify the agency administering the requirement. Do not rely on a project description, a bid advertisement or the fact that the owner is a public entity.
- Identify the statute or funding program that creates the labor-standard obligation.
- Locate the wage determination incorporated into the contract and note its effective revision.
- Confirm the covered project location and the classifications listed for the work.
- Read agency or recipient instructions for format, submission channel, signer authority and correction procedures.
- Check whether state or local prevailing-wage rules apply in addition to federal requirements.
Ask the contracting or funding agency, in writing when practical, which entity receives certified payrolls. Depending on the contract, that may be the contracting agency, an applicant or sponsor, the owner, or another recipient responsible for maintaining records.
Build a project compliance file
Create one controlled file before mobilization. Include the prime contract and modifications, funding or assistance terms, labor-standards clauses, all wage determinations and revisions, subcontract clauses and lower-tier flow-down language, approved classification conformances, the payroll calendar, and the agency’s submission instructions.
The prime contractor is responsible for submitting payrolls for its subcontractors under DBRA guidance. Flow the applicable labor clauses and wage determinations into each subcontract, including lower-tier subcontracts, and assign a person to collect and review every tier’s weekly report.
Set up weekly source data before work starts
Track each worker, date, project and classification
Certified payroll should be generated from ordinary business records, not reconstructed from memory at the end of a month. Configure timekeeping and payroll records to capture:
- Worker name and an allowed identifying number for the weekly transmittal.
- Project and employer, including subcontractor tier.
- Date-by-date hours and total weekly hours.
- Classification for the work actually performed.
- Base wage rate, fringe-benefit rate or cash-in-lieu treatment.
- Gross wages, deductions and net wages paid.
- Overtime information where applicable under the contract or law.
If a person performs more than one classification, record time separately for each classification. A single blended line can conceal an underpayment when the wage determination assigns different rates to the work.
Reconcile daily entries to the weekly total and reconcile the weekly total to the regular payroll register. Keep covered work distinct from other projects or noncovered work so that hours and pay are allocated correctly.
Use the contract wage determination, not a generic rate sheet
Check every worker’s actual duties and location against the wage determination incorporated into the contract. A classification should describe the work performed, not simply the employee’s preferred title or the title used in a timekeeping system.
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If the work has no listed classification, do not invent a rate. Follow the contract and applicable regulation for a classification conformance or other approval process. Keep the request, agency response and effective date in the project file, then use the approved result consistently in payroll.
Handle apprentices as a documentation question
An apprentice rate is not justified by the word “apprentice” in a personnel record. Verify both that the apprenticeship program is valid for the work and that the individual is registered or otherwise properly enrolled as required. Also verify the governing wage rate, fringe-benefit treatment and the permitted apprentice-to-journeyworker ratio.
When a person is reported at an apprentice rate but is not properly registered or employed under the applicable program, DOL guidance indicates that the worker must receive at least the wage-determination rate for the classification actually performed. Keep registration evidence and ratio calculations with the payroll support.
Prepare the weekly certified payroll report
WH-347 versus an alternative format
Form WH-347 is an optional federal convenience form. You may use another payroll report, including an electronic report generated from a payroll system, if the contract and recipient accept it and it contains all required information with the identical Statement of Compliance wording.
| Requirement | Form WH-347 | Alternative format |
|---|---|---|
| Federal status | Optional form under DOL guidance | Permitted only when it meets the same substantive requirements |
| Worker, classification, hours, rates, pay and deductions | Must be completed accurately | Every required field must be present; the specific field layout is not stated by DOL guidance |
| Statement of Compliance | Use the form’s required certification wording | Wording must be identical to the required certification; paraphrasing is not a waiver |
| Signature process | Must be signed by the responsible official | Must support the required signer and the contract’s accepted signature method |
| Personal identifiers | Do not include full Social Security numbers or contact details in the weekly transmittal | The same privacy restriction applies |
| Recipient acceptance | Still subject to contract and agency submission instructions | Confirm the recipient accepts the format, portal and file type before relying on it |
The Statement of Compliance certifies that the report is accurate and complete and that covered workers were paid no less than the applicable prevailing wages, including required fringe benefits. Signing is a substantive representation, not an administrative acknowledgment.
Protect worker information in the transmittal
Weekly certified payrolls must not include workers’ full Social Security numbers, last known addresses, telephone numbers or email addresses. Use an individual identifying number permitted by DOL guidance, such as the last four digits of an SSN, in the report. Retain fuller identifying information in secured underlying records when required for payroll administration, audits or legal obligations.
Limit portal access to personnel who need it, encrypt files when the contract or agency requires secure transmission, and avoid sending payroll attachments through an unapproved personal email account. Privacy protection does not eliminate the recordkeeping duty; it separates the public or agency-facing report from the secured source file.
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Use a documented pre-certification review every week. The reviewer should compare the proposed report with the records that created it, not merely check that every box is populated.
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- Reconcile workers. Confirm that every person who performed covered work appears and that no person from another project is included.
- Validate classifications. Compare actual duties, approved conformances and the wage determination. Check multi-classification time splits.
- Check hours. Compare daily timecards, weekly totals, covered and other work, and any overtime calculations.
- Check rates and fringes. Compare base and fringe rates to the applicable wage determination revision. Verify fringe credits or cash in lieu against supporting benefit records.
- Reconcile money. Tie gross wages, deductions and net wages to the regular payroll register and proof of payment.
- Verify apprentices. Confirm program and individual registration, ratio compliance, rate and fringe treatment.
- Review privacy. Remove full SSNs and personal contact information from the weekly report.
- Resolve exceptions. Correct the source record and report, document the reason, or obtain the required agency approval before certification.
- Obtain the signature. The responsible official should sign only after the review is complete and retain evidence of the submitted version.
DOL investigators compare certified payrolls with timecards, payroll registers, benefit records and worker interviews. An accepted upload does not prove that the wages or classifications were correct.
Collect and review subcontractor payrolls
The prime contractor owns the project-level workflow even when another employer pays the workers. Set a weekly cutoff that gives the prime time to review each subcontractor report before the agency deadline established by the contract.
- List every subcontractor and lower-tier subcontractor expected to perform covered work.
- Require the same weekly report and Statement of Compliance from each tier.
- Check that the subcontractor used the project’s wage determination and approved classifications.
- Compare reported workers and dates with site access, daily reports or superintendent records.
- Return incomplete or inconsistent reports with a written correction request.
- Escalate missing reports to the project manager and contract administrator rather than submitting an unexplained gap.
- Keep the original report, corrected report, communications and approval evidence in the project file.
The prime’s certification should not be treated as a rubber stamp for lower-tier data. The prime contractor is responsible for submission of the certified payrolls to the contracting, funding or assisting agency, including subcontractor payrolls, under DOL investigative guidance.
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Submit to the correct recipient and track the transaction
Submit each weekly package to the recipient named by the contract or agency instructions. When the contracting agency is a party to the contract, it may receive the payroll directly. In other arrangements, submission may go to an applicant, sponsor, owner or another designated record custodian.
There is no single nationwide portal, universal upload date or one correction workflow for every public project. Record the project-specific cutoff, accepted file types, naming convention, signer requirements and escalation contact in the compliance file.
For every submission, retain:
- The exact payroll file and Statement of Compliance that were sent.
- The date and recipient.
- Portal receipt, confirmation email or other evidence of delivery.
- Any rejection notice, correction request and resubmitted version.
- An internal log showing who reviewed and approved the submission.
If an error is found after submission, follow the recipient’s correction process promptly. Preserve the original and corrected versions, identify what changed, and avoid silently overwriting the audit trail.
Retain records for an audit-ready period
Maintain regular payrolls and supporting records while the work is ongoing and for at least three years after all work on the prime contract is complete, as stated in current DOL DBRA investigative guidance.
The retained set should allow an authorized reviewer to trace a reported line from certification to payment and back to the contract requirement. Keep:
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- Worker identifiers and secured contact information.
- Classifications, wage rates and fringe rates.
- Daily and weekly hours, including time by classification.
- Deductions, actual wages paid and proof of payment.
- Apprenticeship registration, program and ratio records where relevant.
- Contracts, subcontracts, bids, amendments, modifications and extensions.
- Wage determinations, revisions and approved classification conformances.
- Every certified payroll, Statement of Compliance, submission receipt and correction history.
Use a consistent naming convention and access controls. A retention policy that keeps only the final PDF but discards timecards, payroll registers or fringe support cannot demonstrate how the certification was established.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Coordinate federal, state and local prevailing-wage rules
A federally assisted project may also be subject to a state or local prevailing-wage law. Federal labor standards do not automatically replace those requirements. Determine whether the project’s location, funding mix, contract value or owner triggers an additional regime.
| Question | Federal DBRA baseline | State or local requirement |
|---|---|---|
| Coverage | Determined by federal statute, assistance and contract clauses | Depends on the jurisdiction’s law, threshold and project type |
| Workers and classifications | Use the federal wage determination and actual work performed | May use a separate classification schedule or registration rule |
| Report format or portal | WH-347 is optional; recipient instructions control | May require a jurisdiction-specific form or electronic system |
| Deadline | Weekly submission is required; the contract or agency sets the practical cutoff | Deadline is jurisdiction- and contract-specific |
| Retention | At least three years after completion of all work on the prime contract | Confirm the jurisdiction’s period; it may differ |
Do not assume one report satisfies both regimes. Map each obligation by jurisdiction, covered worker, classification, wage determination, report fields, portal, deadline and retention period. If a combined submission is accepted, verify that every required field and certification for each regime is present.
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Common failure points and safeguards
Wrong wage determination or classification
Symptom: A worker is paid from a generic company rate sheet or listed under a title that does not match the work. Safeguard: Tie duties and location to the contract wage determination and obtain an approved conformance where no listed classification applies.
Apprentice treated as a job title
Symptom: A reduced rate is used without registration or ratio documentation. Safeguard: Verify the program, individual registration, ratio, wage and fringe rules before the first report.
Protected identifiers sent to the agency
Symptom: A payroll export includes full SSNs, addresses, phone numbers or email addresses. Safeguard: Configure the transmittal to use only an allowed identifying number and keep fuller data in a secured source record.
Subcontractor report missing or late
Symptom: The prime discovers that a lower-tier report was never collected after the submission cutoff. Safeguard: Put every tier on a weekly tracker, set an internal deadline before the agency cutoff and escalate exceptions immediately.
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Symptom: The signer relies on a portal validation message or a completed-looking form. Safeguard: Require documented comparison to timecards, payroll registers, deductions, fringe support, wage determinations and apprentice records.
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Silent corrections
Symptom: A corrected file replaces the original with no explanation. Safeguard: Keep both versions, record the error, document the correction and follow the recipient’s resubmission process.
What can happen when reporting or payment is wrong?
DOL identifies possible enforcement outcomes for violations, including withheld contract funds, contract termination or debarment in applicable circumstances. A false certification may also expose a contractor to civil or criminal prosecution. These are possible outcomes, not automatic penalties for every clerical error.
The most effective protection is a process that detects errors before certification: current wage determinations, classification review, source-record reconciliation, subcontractor follow-up, privacy controls and a preserved audit trail.
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- Confirm that covered work occurred during the reporting week.
- Collect payrolls and Statements of Compliance from every subcontractor tier.
- Export worker, project, classification, hours, rates, fringes, deductions and net-pay data.
- Compare daily time records with weekly totals and regular payroll.
- Check wage determination revisions and approved conformances.
- Verify apprentice registration, ratios, rates and fringe treatment.
- Remove full SSNs and personal contact details from the transmittal.
- Resolve exceptions and document corrections.
- Obtain the responsible official’s certification.
- Submit through the contract-designated channel and save proof of delivery.
- Update the submission and correction log.
- File the report with its source records for the required retention period.
Frequently asked questions
Do I have to submit certified payroll every week?
For covered federal or federally assisted construction work, submit payroll information weekly for each week in which covered work is performed, together with a Statement of Compliance. A state or local rule may add requirements, so follow the contract and applicable jurisdictional instructions.
Is Form WH-347 required?
No. DOL guidance makes WH-347 optional. An alternative format is acceptable only when it contains the required information, uses the identical Statement of Compliance wording, supports the required signature process, protects personal identifiers and is accepted by the contract recipient.
What information goes on a certified payroll report?
The report must accurately identify workers, classifications, daily and weekly hours, wage and fringe rates, gross wages, deductions and net wages, along with the required certification. Do not include full SSNs or personal contact details in the weekly transmittal.
Who submits subcontractor certified payroll?
The prime contractor is responsible for submitting certified payrolls for subcontractors to the designated contracting, funding or assisting agency or other recipient identified in the contract. Subcontractors prepare their own reports and certifications, but the prime must collect and review them.
How long do I keep certified payroll records?
Keep regular payrolls and supporting records for at least three years after all work on the prime contract is complete under current DOL DBRA guidance. Preserve the records needed to reconcile certifications to time, pay, classifications, fringes and contract requirements.
Do state prevailing-wage rules apply to a federally funded project too?
They may. A federally assisted project can also fall under state or local prevailing-wage requirements. Confirm coverage, thresholds, registrations, wage schedules, portals, deadlines and retention periods with the relevant authority and contract documents; never assume the federal report alone satisfies both systems.
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