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 is a payroll document you sign under penalty for every week of covered work. 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. I would raise the signature first with any founder taking on public construction work.
This guide covers what goes on the form, why the fringe column is a frequent source of audit findings, 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.
There is also a version change that is easy to miss. The previous WH-347 expired on September 30, 2026, and the revised form that replaced it asks for information a lot of payroll processes were never capturing: how much of each worker's fringe obligation went to plans and how much was paid in cash.
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 requirement comes from statute: contractors on covered contracts must furnish weekly statements of the wages paid to each employee during the preceding week (40 U.S.C. 3145). The reporting mechanics sit in the regulation that implements it, 29 CFR 3.3, which also exempts contracts of $2,000 or less from the whole exercise.
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
Every contractor doing covered work has to file, at every tier of subcontracting, for each week in which that work was performed.
| 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 | Often, where the agency asks for one | Same route, marked no work performed, 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 agency the state law names |
| Owner-operators and working owners | Not if they own 20 percent or more and actively manage; otherwise yes for covered hours | Same route; independent truck owner-operators appear with the notation owner-operator only |
The third row is the one small contractors skip, reasonably enough, because filing a report showing nothing feels absurd. The regulation does not demand it, but 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.
Davis-Bacon, the federal prevailing wage requirement for construction, attaches to federally funded or assisted contracts in excess of $2,000, the threshold that triggers certified payroll. A second threshold sits above it: prime contracts over $100,000 also pull in the Contract Work Hours and Safety Standards Act, which requires time and a half above 40 hours in a workweek.
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 separate columns for each worker's fringe credit and for cash paid in lieu of fringe benefits, a box naming each registered apprenticeship program, and check boxes with fillable fields. The statement of compliance stays on page 2, where the earlier version had it too.
Pay is reported in more than one place on the form. Column 7A carries what was earned on this project, 7B what was earned on all work that week, and column 9 the net payment to the worker for all work, so gross and net pay never share a field.
Where to Get the WH-347 PDF
The form comes from the Department of Labor (DOL) rather than from your payroll software. The Wage and Hour Division publishes it on dol.gov in three shapes: a downloadable PDF, an annotated guide to the form, and an online fillable version that runs in a browser. It carries OMB control number 1235-0008.
Using the form itself is optional, which surprises most contractors. The Wage and Hour Division says it plainly: while use of Form WH-347 is optional, covered contractors and subcontractors are required by the regulations and the contract clauses to submit payroll information weekly.
The regulation is equally direct, accepting the WH-347 or any form with identical wording, so a payroll register carrying every required field satisfies the rule.
Two details of that regulation trip people up. The signature has to be an original handwritten one or a legally valid electronic signature, and the certified payroll must reach the agency within seven days after the regular payment date of the pay period it covers.
What Goes on the Form
The form asks for 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 organized 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. The certification includes a statement that no unlawful deductions were made, and the deductions you may take without applying to the Secretary of Labor are listed in a closed set at 29 CFR 3.5.
The list has ten entries, including taxes, court-ordered payments, voluntary benefit and credit union deductions, union dues, and the reasonable cost of board and lodging. A deduction that would be routine on ordinary payroll is not automatically acceptable here.
The Fringe Column
The fringe column is where certified payroll and prevailing wage meet, and it is a frequent source of findings. The wage determination, the schedule of prevailing rates that applies to the job, 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 bona fide benefit 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. Under the annualization rule at 29 CFR 5.25, that figure is the plan's cost divided by every hour the employee worked in the period the cost covers, including hours on private jobs. A fixed monthly premium therefore cannot be credited against the covered hours alone.
The Statement of Compliance
The statement of compliance certifies 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.
The statement is signed under penalty, and the form names the statutes: 18 U.S.C. 1001, the federal false statements statute, and 31 U.S.C. 3729, the False Claims Act. Those penalties are 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 in a two-minute check first: classifications match what the crew actually did, the fringe column is populated and reaches the determination, and hours reconcile to the timesheets.
Here is that check written out, one page per payroll. Whoever prepares the payroll works down it, and the person who signs reads the exceptions box before putting their name on anything.
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. A subcontractor error becomes your restitution, so check two things on each submission: 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 is the unglamorous half. The contract clauses set the retention period at not less than three years after all the work on the prime contract is completed, which on a long job is considerably further out than three years from the payroll date.
That record 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.
A register makes the sequence visible at a glance, which is the point: a missing number is obvious on a log and invisible in a folder of files. One row per week per job, a second sheet for the subcontractors, and a third for anything you had to correct.
| A | B | C | D | E | F | G | H | I | J | K | L | |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 1 | Project | Payroll no. | Week ending | Covered work this week | Submitted on | Submitted to | How it was sent | Form version used | Marked final | Pre-signature check done by | Correction filed for this week | Notes |
| 2 | 1 | Yes | No | No | ||||||||
| 3 | 2 | No work performed | No | No | Filed so the sequence stays intact | |||||||
| 4 | 3 | Yes | No | No | ||||||||
| 5 | ||||||||||||
| 6 | ||||||||||||
| 7 | ||||||||||||
| 8 | ||||||||||||
| 9 | ||||||||||||
| 10 | Number the payrolls in sequence from the first week of work on the contract, and mark the last one final | |||||||||||
| 11 | A week with no covered work still gets a row and a number, marked no work performed |
Dwight SchruteSales3 people
Darryl PhilbinWarehouse1 person
Kelly KapoorCustomer Service1 personCorrecting a Filing
Correct a filing openly and promptly, with a marked corrected payroll and any back wages paid, rather than quietly and later. Errors happen, and the way they are handled matters more than the error.
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. Oregon's Bureau of Labor and Industries, for one, says a federal WH-347 alone does not satisfy its filing requirements. Several states also require submission through a specific electronic system with its own account setup and its own lead time.
California differs from the federal rules in two ways at once. Contractors on most public works there submit their certified payroll records to the Labor Commissioner through a state electronic system of its own, and the state prevailing wage duty attaches above $1,000, half the federal figure.
A lower threshold is the trap, because it attaches to a job small enough that nobody thought to check. Bid time is the cheapest moment to discover it, so confirm the state position then, alongside the wage determination.
Where Small Contractors Get This Wrong
Small contractors get this wrong in six recurring ways, and the first two are frequent sources of findings.
Leaving the fringe treatment implied is first. A base rate with nothing beside it looks as if the fringe was never paid, and that would be 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 rebuilding it after the fact is unreliable and easy for a reviewer to spot.
Skipping the weeks with no work is third, wherever the contracting agency asks for a no-work payroll. 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. The old form's clearance expired on September 30, 2026, and this mistake is the easiest of the six to avoid.
Nick Anisimov, FirstHR founder
Frequently Asked Questions
What is certified payroll?
Certified payroll is the weekly payroll report a contractor on covered public construction sends to the contracting agency. It lists every worker, the classification each one worked in, their hours on each day, the rate paid, deductions, and net pay, and it comes with a signed statement of compliance. Federally the standard vehicle is the Department of Labor’s Form WH-347, although the form itself is optional. The report exists to show that each worker received no less than the prevailing wage for their work, 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 set parallel rules for 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 end up filing two different reports for two different agencies.
How often is certified payroll due?
Weekly. A certified payroll is due for every week in which covered work was done on the contract, starting with the first week on the job and ending with the last. Each one has to be in the agency’s hands no later than seven days after the regular payday for the period it reports. The payrolls carry sequential numbers starting at one, and a box on the form flags the final week. The regulation itself requires nothing for a week with no covered work, but plenty of contracting agencies want a no-work payroll anyway, since a skipped number looks to a reviewer like a payroll that never arrived.
What changed on the revised WH-347?
The revised form expands fringe benefit reporting: each worker’s fringe credit from plan contributions and anything paid in cash instead of fringe benefits now sit in separate columns, so the cash-or-plan question can no longer be left implied. Apprenticeship documentation is more explicit, with a box on the statement of compliance asking for the program name and whether it is registered with the Department of Labor or a State Apprenticeship Agency. The certification itself has not moved; the earlier version carried it on page 2 as well. The Department of Labor’s 2024 notice proposing the revision described its aims as simpler, clearer fields, check boxes and fillable entries, and more specific fringe benefit information. The practical effect is that entries a contractor could previously leave vague have a specific field expecting a specific answer.
Is the old WH-347 still accepted?
No. The information collection clearance behind the previous version of the form ran out on September 30, 2026, so from October 1, 2026 onward the revised WH-347, marked Rev. January 2025, is the only version to use. Its own clearance, under OMB control number 1235-0008, received approval on January 6, 2025 and lasts until January 31, 2028. If one of your jobs is still on the old sheet, change over with the next payroll and start with the fringe and apprenticeship entries, because some payroll processes were never capturing that information. The earlier layout had a single rate-of-pay column, with no separate column for the fringe credit or for cash paid instead of fringe benefits, so payroll software that still prints it needs updating as well.
What is the statement of compliance?
It is the certification that goes with every weekly payroll. By signing it, the signer confirms that the payroll is accurate and complete, that every worker received at least the rate for the classification they worked in, and that no unlawful deductions came out of anyone’s pay. There is no separate Wage and Hour Division form for it anymore; the statement is printed as page 2 of the WH-347. Either a handwritten original signature or a legally valid electronic one is required. Because the signature is given under penalty, knowingly certifying something false is a far bigger problem than a calculation slip, so whoever signs should be able to stand behind the figures personally.
How do you correct a certified payroll already submitted?
Submit a corrected payroll for the week that was wrong, labeled as a correction and showing the right figures, and pay any back wages it reveals to the affected workers without delay. Avoid quietly changing an earlier submission or absorbing the fix into a later week, since either one leaves a confusing trail that can read as an attempt to hide the mistake. If anyone was underpaid, keep proof of the restitution with the corrected filing, because that record is what shows the problem was fixed and not just found. Then check whether the same mistake ran through other weeks.
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 statement of compliance is signed by the contractor or by an agent who pays or supervises the payment of wages. Either way it certifies your payroll, so somebody at your business has to be in a position to stand behind the classifications and the fringe entries, rather than forwarding a document nobody on your side has 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.
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