Certified Payroll: What WH-347 Requires Each Week
Certified payroll is a weekly WH-347 filing with a signed compliance statement. What each column needs, the revised form, and the transition deadline.
Certified Payroll
The weekly filing that proves you paid prevailing wage, why the statement of compliance is the part with teeth, what the revised form now asks about fringe treatment and apprentices, the transition deadline that retires the old version, and how to correct a filing you have already signed
Certified payroll is the only payroll document most contractors will ever sign under penalty. That single fact should change how it gets produced, and at most small contractors it does not, because it is treated as a report rather than as a certification.
There is also a version change in progress that is easy to miss. A revised form replaced the earlier one, the old version is being retired on a fixed date, and the new fields ask for information a lot of payroll processes were never capturing: specifically, whether the fringe obligation was met in cash or through a plan.
This covers what goes on the form, why the fringe column is the one that gets audited, what the statement of compliance actually commits you to, how to correct a filing you have already signed, and the filing discipline that keeps a job clean. I build the people and records tooling for businesses without an HR department at FirstHR, and FirstHR is an onboarding and HR platform rather than a payroll provider. This is general information, not legal advice.
What Certified Payroll Is
Certified payroll is a weekly submission proving that everyone on a covered public construction job was paid at least the applicable prevailing wage. It is a report plus a certification, and the certification is the part that matters.
The statutory basis requires contractors on covered contracts to furnish weekly statements of the wages paid to each employee during the preceding week (40 U.S.C. 3145). The reporting mechanics and the permitted deductions that show up in the deduction column are set out in the implementing regulations (29 CFR 3.3).
What makes it operationally different from any other payroll report is the classification column. Ordinary payroll knows who worked and for how long. Certified payroll needs to know what work they were doing, hour by hour, and most payroll systems have no field for that at all.
Who Has to File
Everyone performing covered work, at every tier, from the first week to the last.
| Party | Files certified payroll? | Where it goes |
|---|---|---|
| Prime contractor on a covered federal contract | Yes, weekly | To the contracting agency |
| Subcontractor at any tier | Yes, weekly | Up through the prime contractor |
| A contractor in a week with no covered work | Yes, marked no work performed | Same route, to keep the sequence intact |
| Material supplier not performing site work | Generally no | The obligation attaches to laborers and mechanics on site |
| Contractor on state or local public works | Depends on state law | To whichever state agency the law names |
| Owner-operators and working owners | Usually yes for hours worked in a covered classification | Confirm the treatment for your entity type |
The third row is the one small contractors skip, reasonably enough, because filing a report showing nothing feels absurd. It is not: an unexplained gap in a numbered sequence reads as a missing submission rather than an idle week, and answering that question later is more work than the filing would have been.
The Form Changed
A revised WH-347 replaced the earlier version, and this is not a cosmetic update. The changes ask for information that a lot of contractors were not previously recording.
The substantive additions are the fringe treatment designation, clearer apprenticeship documentation, separate gross and net pay fields, and the consolidation of the statement of compliance into the payroll form itself rather than a separate sheet.
What Goes on the Form
Three groups of information, and the third is a different kind of thing from the first two.
The daily hours requirement is what forces a change in timekeeping. A weekly total per employee is not enough, because the form is organised by day and by classification, and reconstructing that split from memory at the end of the week is both unreliable and exactly the kind of thing a reviewer probes.
The deduction column has its own constraint: deductions must be permissible ones, and the certification includes a statement that no unlawful deductions were made (29 CFR 3.4). A deduction that would be routine on ordinary payroll is not automatically acceptable here.
The Fringe Column
This is where certified payroll and prevailing wage meet, and it is where most findings originate. The wage determination sets a base rate and a separate fringe rate, and the form now expects you to say how the fringe half was satisfied.
Three answers are acceptable: paid in cash as additional wages, contributed to approved plans, or a combination reaching the listed amount. What is not acceptable is a filing that shows the base rate and leaves the fringe question implied, because that reads as a base-rate-only payment, which would be an underpayment on every covered hour.
Where you satisfy the obligation with benefits, be ready to show the hourly equivalent per employee. A health plan costing a fixed monthly amount converts into an hourly figure that depends on hours worked, which means the same benefit produces a different hourly value in a busy month than in a quiet one.
The Statement of Compliance
The certification states that the payroll is correct and complete, that each worker received not less than the applicable rate for the classification of work performed, and that no unlawful deductions were made. It is signed under penalty.
That last phrase is the reason to care about who signs. A knowingly false certification is a materially different matter from an arithmetic error, and the person putting their name on it should be somebody who can actually vouch for the classifications and the fringe figures rather than somebody forwarding a document produced elsewhere.
In a small contracting business that person is usually the owner, which is uncomfortable and correct. The practical response is not to avoid signing but to build a two-minute check before signing: classifications match what the crew actually did, fringe column is populated and reaches the determination, hours reconcile to the timesheets.
Filing Discipline
Five habits separate a clean job from one that generates questions, and none of them are difficult once they are routine.
The last one is worth doing even though it feels like policing a business partner. Subcontractor payrolls flow up through you, a subcontractor error becomes your restitution, and the two things worth checking on each submission are the classifications used and whether the fringe column is populated. That is a minute per payroll.
Keeping the filed payrolls, the timesheets behind them, and the wage determination together for the required three-year retention is the unglamorous half. It is also the half an investigator asks for first, and the version stored across three people's laptops is the version that cannot be produced.
Correcting a Filing
Errors happen and the way they are handled matters more than the error. The rule is to correct openly and promptly rather than quietly and later.
State Certified Payroll
Many states impose their own certified payroll requirements on state and local public works, and they are separate regimes rather than variations. Different forms, different portals, different agencies, and frequently different submission frequencies.
A contractor working on both federal and state-funded projects should expect to file two different reports rather than one report twice. Some states accept the federal form; several do not, and several require submission through a specific electronic system with its own account setup and its own lead time.
The thresholds also differ and are frequently lower than the federal $2,000, which means a state requirement can attach to a job small enough that nobody thought to check. Confirming the state position at bid time, alongside the wage determination, is the cheapest moment to discover it.
Where Small Contractors Get This Wrong
Six patterns, and the first two are the ones that generate findings.
Leaving the fringe treatment implied is first. A filing showing only a base rate reads as a base-rate-only payment, which is an underpayment across every covered hour.
Recording weekly totals instead of daily hours by classification is second. The form is built around the split, and reconstructing it later is both unreliable and visibly reconstructed.
Skipping weeks with no work is third. The gap in the sequence is more conspicuous than the filing would have been.
Signing without checking is fourth. The certification is under penalty, and the signature should belong to somebody who can vouch for the numbers rather than forward them.
Passing subcontractor payrolls straight through is fifth. Their error becomes your restitution, and two checks per submission would have caught it.
And using the retired form version is last, which becomes an automatic rejection rather than a substantive finding, and is the easiest of the six to avoid.
Frequently Asked Questions
What is certified payroll?
Certified payroll is a weekly payroll report that contractors on covered public construction submit to the contracting agency, showing each worker, the classification of work performed, hours worked each day, the rate paid, deductions, and net pay, accompanied by a signed statement of compliance. Federally it is filed on Form WH-347. Its purpose is to demonstrate that everyone on the job received at least the applicable prevailing wage, and because it is signed under penalty it is a considerably more serious document than an internal payroll register.
Who has to submit certified payroll?
Contractors and subcontractors performing work on federal or federally assisted construction contracts covered by Davis-Bacon requirements, which attach above a $2,000 contract threshold. Every tier files, with subcontractor payrolls flowing up through the prime contractor to the contracting agency. Many states impose parallel requirements on state and local public works, sometimes at lower thresholds, with their own forms and their own submission portals, so a contractor working across both can be filing two different reports for two different agencies.
How often is certified payroll due?
Weekly, for each week in which covered work was performed, and the obligation runs from the first week of work on the contract to the last. Payrolls are numbered in sequence and the final one is marked as final. Weeks in which no covered work took place are normally accounted for with a payroll marked as no work performed, rather than by simply not filing, because a gap in the numbering reads to a reviewer as a missing submission rather than an idle week.
What changed on the revised WH-347?
The revised form expands fringe benefit reporting, requiring contractors to state whether the fringe obligation was satisfied in cash or through contributions to approved plans rather than leaving it implied. It asks for clearer apprenticeship documentation, adds separate gross and net pay fields, consolidates the statement of compliance that previously sat on its own form, and updates the certification language. The practical effect is that entries a contractor could previously leave vague now have a specific field expecting a specific answer.
Is the old WH-347 still accepted?
For a limited period. The Department of Labor released the revised form and set a transition date after which the previous version is no longer accepted, with the older form expiring at the end of September 2026. Contractors still using the earlier version should move across now rather than at the deadline, because the change is not only cosmetic: the new fringe and apprenticeship fields require information that some payroll processes were not previously capturing at all.
What is the statement of compliance?
It is the certification signed with each weekly payroll, stating that the payroll is correct and complete, that each worker was paid not less than the applicable wage rate for the classification of work performed, and that no unlawful deductions were made. It used to be filed on a separate form and is now consolidated into the payroll form itself. Because it is signed under penalty, a knowingly false certification is a materially more serious matter than an arithmetic error, which is why the person signing should be the person who can vouch for the numbers.
How do you correct a certified payroll already submitted?
File a corrected payroll for the affected week, clearly marked as a correction, showing the accurate figures, and pay any resulting back wages to the affected workers promptly. Do not amend a prior submission silently or fold the correction into a later week’s numbers, because both make the record harder to follow and look like concealment. Where the error caused an underpayment, documenting the restitution alongside the corrected filing is what demonstrates the issue was resolved rather than merely identified.
Can a payroll provider file certified payroll for you?
Many will produce the report, and some will file it, but the obligation and the certification remain the contractor’s. The signature on the statement of compliance is yours, which means somebody at your business has to be in a position to vouch for the classifications and the fringe figures rather than passing along a document they have not checked. Standard payroll software frequently does not capture hours by classification at all, which is the gap that makes certified payroll harder than it looks.