🐻 California DIR Compliance
California's Department of Industrial Relations (DIR) runs the most comprehensive state-level construction compliance program in the country. If you do public works in California, you need DIR registration, electronic certified payroll reporting (eCPR), mandatory apprentice ratios, and meticulous record-keeping. The penalties for non-compliance are severe — up to $200/day per worker plus debarment.
DIR registration (SB 854)
Since 2014, all contractors and subcontractors performing public works in California must register with DIR before bidding or working on a public works project.
| Requirement | Details |
|---|---|
| Who must register | All contractors and subs on public works (including GCs, subs, and sub-subs) |
| Fee | $400/year (as of 2024) |
| Renewal | Annual — must be current at all times during the project |
| Verification | Awarding bodies must verify registration before awarding contracts |
| Penalty for non-registration | Cannot bid, cannot work — contract may be void |
Registration checklist
- Register at dir.ca.gov/Public-Works/Contractor-Registration
- Provide workers' comp policy information
- Pay the annual registration fee
- Ensure all subcontractors are also registered
- Verify registration before each project bid
If you hire an unregistered sub on a public works project, you (the GC) face penalties. Verify every sub's DIR registration before they start work. The DIR maintains a public search tool for verification.
Electronic Certified Payroll Reports (eCPR)
California requires electronic submission of certified payroll reports through the DIR's online system.
Filing requirements
| Requirement | Details |
|---|---|
| Format | Electronic Certified Payroll Report (eCPR) via DIR online portal |
| Deadline | Within 30 days of each pay period |
| Frequency | Every pay period (weekly or biweekly) |
| Who files | Each contractor and sub files their own eCPR |
| Content | Worker name, address, SSN (last 4), classification, hours by day, rates, fringes, deductions |
eCPR vs. federal WH-347
| Field | eCPR (California) | WH-347 (Federal) |
|---|---|---|
| Filing method | Electronic (DIR portal) | Paper or electronic (to contracting agency) |
| Deadline | 30 days after pay period | Weekly |
| Format | DIR-specified fields | Standard WH-347 form |
| Who receives | DIR directly | Contracting agency |
| Public access | Available to public upon request | Available to public upon request |
The A-1-131 form
California's traditional certified payroll form (prior to eCPR) is the A-1-131. Some awarding bodies still request it in addition to eCPR filing. It includes the same information as the eCPR but in a paper format.
Apprenticeship requirements
California mandates specific apprentice-to-journeyman ratios on public works projects.
Requirements
| Rule | Details |
|---|---|
| Mandatory participation | Must employ apprentices on public works projects over $30,000 |
| Ratios | Set by the DAS (Division of Apprenticeship Standards) per trade |
| Registration | Apprentices must be registered in a state-approved program |
| Wage rates | Per the apprentice prevailing wage determination (by period) |
| Reporting | Hours must be reported on eCPR with apprentice classification |
Typical apprentice ratios
| Trade | Typical ratio | Notes |
|---|---|---|
| Carpenter | 1 apprentice per 5 journeymen | Varies by local |
| Electrician | 1 apprentice per 3–5 journeymen | IBEW-specific |
| Plumber | 1 apprentice per 3–5 journeymen | UA-specific |
| Laborer | 1 apprentice per 5 journeymen | LIUNA standards |
| Operating Engineer | 1 apprentice per 5 journeymen | Varies |
| Ironworker | 1 apprentice per 5–6 journeymen | Varies by local |
Apprentice wage rates
Apprentice prevailing wage rates are published separately by DIR. They vary by:
- Trade classification
- Apprentice period (1st through 8th, depending on trade)
- Geographic area (same county-based system as journeyman rates)
Apprentice fringe rates also differ from journeyman rates — typically lower for some categories. Always pull the apprentice-specific wage determination, not a percentage of the journeyman rate.
The most common apprentice violation is not employing apprentices at all on projects that require them. The second most common is employing apprentices but not from a registered program. Both trigger penalties. Contact the local JATC (Joint Apprenticeship Training Committee) to request apprentices.
Penalty exposure
California takes prevailing wage enforcement seriously. Penalty exposure is per-worker, per-day:
| Violation | Penalty |
|---|---|
| Underpayment of wages | Back pay + 2x the underpayment as liquidated damages |
| Failure to pay prevailing wage | Up to $200/day per worker |
| Failure to maintain records | Up to $100/day per worker |
| Failure to file eCPR | Up to $100/day per worker |
| Unregistered contractor | Civil penalty + potential contract voiding |
| Failure to employ apprentices | Additional penalties per DAS |
| Willful violations | Debarment from public works for up to 3 years |
| Repeated violations | Increased penalties + referral for criminal prosecution |
Who is liable?
| Party | Liability |
|---|---|
| GC | Responsible for own compliance + ensuring sub compliance |
| Subcontractor | Responsible for own compliance |
| Awarding body | Must verify contractor registration and monitor compliance |
| Labor Compliance Program (LCP) | Some awarding bodies have their own compliance monitoring |
Dual-coverage projects
Many California public works projects have both federal and state prevailing wage requirements:
- Federally funded highway projects (FHWA) → Davis-Bacon + California DIR
- HUD-funded housing → Davis-Bacon + California DIR
- Clean Water Act projects → Davis-Bacon + California DIR
On dual-coverage projects:
- Compare federal and state rates for each trade — pay the higher of each component
- File both federal WH-347 and California eCPR
- Meet both sets of apprentice requirements
- Register with both SAM.gov and California DIR
Common audit findings (California-specific)
| Finding | Frequency | Prevention |
|---|---|---|
| Wrong classification | Very common | Daily foreman classification logs |
| Fringe underpayment | Common | Monthly trust fund reconciliation |
| Late eCPR filing | Common | Calendar reminders; file within 30 days |
| Unregistered sub | Occasional | Verify DIR registration before site access |
| Missing apprentices | Occasional | Contact JATC before project starts |
| Expired wage rates | Occasional | Track determination effective dates |
Related resources
- California Overtime Rules — Daily OT, 7th day, breaks
- Certified Payroll (Federal) — WH-347 and Davis-Bacon
- California Prevailing Wage & DIR — General CA PW guide
- Prevailing Wage Rate Management — Rate lookups and CBA vs PW
- Apprenticeship Programs — Union and non-union apprenticeship