📋 Certified Payroll (Federal)
Federal certified payroll is required on all projects subject to the Davis-Bacon Act — any federally funded or assisted construction contract over $2,000. The WH-347 is the standard form, filed weekly to the contracting agency. Getting it wrong isn't just a paperwork issue — falsifying a certified payroll is a federal crime.
For California-specific eCPR and DIR requirements, see the California DIR Compliance page.
Compliance setup flow
Step-by-step from project identification through ongoing reporting.
When federal certified payroll is required
| Trigger | Threshold | Required? |
|---|---|---|
| Direct federal construction | Over $2,000 | Yes |
| Federally assisted (grants, loans) | Over $2,000 | Yes — via "Related Acts" |
| Federal highway (FHWA) | Over $2,000 | Yes |
| HUD-funded housing | Over $2,000 | Yes |
| EPA water/sewer projects | Over $2,000 | Yes |
| Military construction | Over $2,000 | Yes |
| State-funded only (no federal $) | Varies | No — but state CPR may apply |
| Private construction | Any | No |
Over 60 federal statutes incorporate Davis-Bacon requirements. Many projects that appear state or locally funded have federal money flowing through them (grants, loans, subsidies). Always verify the funding source — if any federal dollars touch the project, Davis-Bacon likely applies.
The WH-347 form
Required fields
| Section | What's required |
|---|---|
| Header | Contractor name/address, project name/location, week ending date |
| Worker info | Name, last 4 SSN, work classification |
| Hours | Hours worked each day (daily breakdown — not just weekly total) |
| Pay rates | Basic hourly rate and fringe rate shown separately |
| Earnings | Gross wages earned |
| Deductions | Itemized deductions |
| Net pay | Take-home amount |
Statement of Compliance
The certification statement must be signed by an authorized company representative stating:
- Wages paid are accurate and complete
- Classifications are correct for the work performed
- No kickbacks occurred (Anti-Kickback Act)
- Apprentices are registered in an approved program (if applicable)
- Fringe benefits were paid to qualifying plans or as cash
This is a sworn statement. Knowingly falsifying it is a federal offense punishable by fines and imprisonment.
Filing requirements
| Requirement | Federal (Davis-Bacon) |
|---|---|
| Form | WH-347 |
| Frequency | Weekly |
| Submit to | Contracting agency (not the DOL directly) |
| Deadline | Per contract terms (typically within 7 days of pay period end) |
| Who files | Each contractor and sub files their own CPR |
| Retention | 3 years minimum |
| GC responsibility | Collect and review sub CPRs before forwarding |
Subcontractor CPR management
The GC is responsible for ensuring every sub complies. This is both a legal obligation and a practical risk management issue.
Best practices
- Require weekly submission — don't wait until month's end or project completion
- Review before forwarding — check classifications, rates, and hours against the wage determination
- Verify registration — ensure subs are not on the DOL debarment list
- Include in subcontract — CPR requirements, deadlines, and penalties for non-compliance
- Withhold payment — if CPRs are not current, withhold sub progress payments until received
- Keep copies — maintain your own file of all sub CPRs for the retention period
What to check on sub CPRs
| Check | What to look for |
|---|---|
| Classifications | Do they match the work being performed? |
| Rates | Does the basic + fringe meet or exceed the wage determination? |
| Hours | Do the daily hours look reasonable for the crew size and scope? |
| Workers | Are all workers who were on site included? |
| Signature | Is the Statement of Compliance signed by an authorized person? |
| Dates | Does the week ending date match the pay period? |
Common audit findings
| Finding | Why it happens | Consequence |
|---|---|---|
| Wrong classification | Workers doing multiple tasks get classified at lower rate | Back pay at correct rate + penalties |
| Missing fringe payments | Not making trust fund contributions or paying cash shortfall | Back pay + interest + liquidated damages |
| Unreported hours | Workers performing covered work not included in CPR | Assessment for full underpayment |
| Late filing | Not submitting CPR within required timelines | Civil penalties, contract withholding |
| Incomplete daily records | Reconstructing time from memory at week's end | Triggers deeper audit scrutiny |
| Split checks / off-book payments | Paying part cash to avoid taxes or lower reported wages | Criminal penalties |
| Missing sub CPRs | GC didn't collect or review sub reports | GC liable for sub violations |
Audit your own certified payrolls before submitting them. Cross-reference daily time records against the CPR, verify fringe contributions match the wage determination, and confirm every worker who performed covered work is included. The most common finding — unreported hours — is entirely preventable with a monthly reconciliation between payroll registers and daily time sheets.
State certified payroll requirements
Many states have their own certified payroll requirements in addition to (or instead of) federal:
| State | Form | Filing | Key differences |
|---|---|---|---|
| California | eCPR (electronic) | Within 30 days to DIR | Full CA guide → |
| New York | State CPR form | To contracting agency | Includes "supplements" (fringes) |
| Illinois | State CPR form | To awarding body | Monthly, not weekly |
| Massachusetts | Weekly CPR | To awarding body | Per-project wage schedules |
| Connecticut | State CPR form | To contracting agency | Annual rate updates |
On dual-coverage projects (federal + state), you must file both the WH-347 and the state form. Pay the higher of each component (base, H&W, pension, etc.) — not simply the higher total. See CBA vs. PW rate comparison.
Related resources
- California DIR Compliance — eCPR, registration, apprentice ratios
- Prevailing Wage Rate Management — Rate lookups and CBA vs PW
- Prevailing Wage Guide — Davis-Bacon and state PW laws
- Certified Payroll Guide — Additional WH-347 details
- Certified Payroll Compliance Workflow — Step-by-step procedure