Legal & Regulatory

Mastering Certified Payroll: A General Contractor's Comprehensive Guide

9 min read

Certified payroll is the weekly payroll report that general contractors and subcontractors must submit on federally funded construction projects. The U.S. Department of Labor requires these reports on every project covered by the Davis-Bacon Act. In 2025, federal construction spending topped $198 billion, and every dollar of it required certified payroll documentation.

This pillar guide covers everything a GC needs to know about certified payroll. We break down the reporting requirements, walk through the WH-347 form, explain state-level variations, and show how the right systems keep you compliant without slowing down your projects.

What Certified Payroll Actually Requires

Certified payroll goes beyond a standard payroll report. It is a sworn statement that you paid workers the correct prevailing wage rates for their classification on a specific project.

Weekly submission. Contractors must submit certified payroll reports within seven days of each pay period. Late submissions trigger DOL scrutiny and can lead to payment holds on the project.

WH-347 form. The standard form captures employee names, classifications, hours worked daily, total hours, rate of pay, gross pay, deductions, and net pay. Each report includes a Statement of Compliance signed under penalty of perjury.

All tiers report. The GC is responsible for collecting certified payroll from every subcontractor and sub-tier contractor on the project. A 2024 DOL enforcement report found that 43% of Davis-Bacon violations originated at the sub-tier level.

Accurate classifications. Each worker must be classified according to the wage determination for the project. Misclassification is the most common violation. Laborers classified as helpers, or carpenters classified as general laborers, cost contractors an average of $12,400 per violation in back wages and penalties.

How the WH-347 Form Works

The WH-347 is a two-page form. Page one captures payroll data. Page two is the Statement of Compliance.

Page one fields. Contractor name, project and contract number, payroll number (sequential), week ending date. Then a row for each employee showing name, last four of SSN (or full if required by the agency), work classification, hours worked each day, total hours (straight time and overtime), rate of pay, gross earnings, deductions (FICA, withholding, other), and net wages paid.

Fringe benefits. You can pay fringe benefits in cash, contribute to approved plans, or use a combination. The form has columns for both. If you pay fringes in cash, they appear as part of the hourly rate. If you contribute to a plan, you list the plan details separately.

Page two certification. The authorized officer signs a statement confirming that the payroll is correct, all workers were paid the applicable prevailing wage, and no prohibited deductions were made. False certification carries penalties up to $1,100 per falsified statement and potential debarment from federal contracts.

Certified Payroll Software Options

Managing certified payroll with spreadsheets works on small projects. It breaks down when you run multiple prevailing wage projects with dozens of subcontractors.

Certified payroll software automates WH-347 generation, validates wage rates against published determinations, and flags discrepancies before submission. The best platforms integrate with your existing payroll system and pull data directly.

Key features to look for include automatic wage determination lookups, multi-project tracking, electronic submission to contracting agencies, and sub-tier collection workflows.

We compare the leading platforms in Certified Payroll Software Explained.

Federal vs. State Certified Payroll Requirements

Federal requirements under Davis-Bacon set the floor. Many states add their own prevailing wage laws with additional reporting requirements.

RequirementFederal (Davis-Bacon)CaliforniaNew YorkOregonWashington
ThresholdAll federal projects$1,000+ public works$250,000+ public works$50,000+ public worksAll public works
Reporting frequencyWeeklyWeeklyWeeklyMonthly or weeklyWeekly
Form requiredWH-347DIR eCPRPW-16/PW-16.1WH-347 or BOLI formL&I certified form
Apprentice ratiosProject-specificMandatory 1:5Varies by trade1:5 minimum15% apprentice hours
Penalty for violationsUp to $1,100/violationUp to $200/day per workerUp to $5,000/violationUp to $5,000 + debarmentUp to $5,000 + debarment
Electronic filingAllowedRequired (eCPR)Required (NYSDOL)AllowedRequired (LNI)

Building a Certified Payroll Compliance Program

Compliance is not a one-time setup. It requires ongoing processes across your organization.

Certified payroll compliance starts with three foundations: accurate wage determinations, correct worker classifications, and timely report submission.

Pre-project setup. Before work begins, obtain the wage determination for the project. Map every trade you will use to the published classifications. Share wage schedules with subcontractors and require written acknowledgment.

Weekly workflow. Each week, collect payroll data, verify hours and rates, generate WH-347 forms, obtain authorized signatures, and submit to the contracting agency. Build a 3-day buffer into your submission timeline to handle corrections.

Audit readiness. Store certified payroll records for at least three years after project completion. Federal agencies can audit up to three years back. Some states extend that to five years.

See our step-by-step breakdown in How to Handle Certified Payroll Compliance.

Common Certified Payroll Mistakes

The most expensive mistakes happen before the first report gets filed. Choosing the wrong wage determination, misclassifying workers, or failing to collect sub-tier reports creates problems that compound weekly.

Atlas certified payroll and similar platforms can prevent these errors through automation. But you still need to understand what goes wrong manually.

The top five mistakes include using outdated wage determinations (updated quarterly), classifying workers below their actual trade, omitting fringe benefit details, missing the weekly submission deadline, and failing to collect from lower-tier subcontractors.

Read the full analysis in Top Atlas Certified Payroll Mistakes GCs Make.

Contractor Compliance Checklists

A contractor certified payroll compliance checklist keeps your team on track week after week. It should cover pre-project setup, weekly reporting steps, and post-project retention requirements.

We built a practical checklist that covers all three phases in Contractor Certified Payroll Compliance: A Practical Checklist.

State Focus: Oregon Requirements

Oregon's Bureau of Labor and Industries (BOLI) enforces state prevailing wage law on public works projects over $50,000. Oregon requires contractors to submit certified payroll statements and maintains its own wage rate schedules separate from federal rates.

Contractor certified payroll compliance in Oregon involves additional requirements around apprenticeship utilization and prompt payment.

Get the Oregon-specific breakdown in Why Contractor Certified Payroll Compliance Oregon Matters.

State Focus: Washington Requirements

Washington's Department of Labor and Industries (L&I) requires certified payroll on all public works projects regardless of dollar amount. The state mandates 15% apprenticeship utilization on projects over $1 million and requires electronic filing.

Read the full Washington compliance guide in Contractor Certified Payroll Compliance Washington: Best Practices and the state-by-state comparison in Washington Requirements: State-by-State Guide.

Certified Payroll Best Practices

The GCs that handle certified payroll well share common habits. They assign a dedicated compliance person, automate wage rate lookups, build sub-tier collection into contract language, and run internal audits quarterly.

We detail these strategies in The GC's Guide to Certified Payroll Best Practices.

For answers to the most common certified payroll questions, visit Certified Payroll Best Practices: Common Questions.

Certified Payroll Record Retention

Federal law requires certified payroll records to be kept for three years after project completion. Several states extend this period.

StateRetention PeriodAdditional Notes
Federal3 yearsFrom project completion date
California3 yearsDIR may request at any time
New York6 yearsStatute of limitations for wage claims
Texas3 yearsMatches federal standard
Florida5 yearsPublic records law applies
Oregon3 yearsBOLI audit window
Washington3 yearsL&I standard retention
Illinois5 yearsExtended by state law

Measuring Certified Payroll Compliance

Track these metrics to gauge your compliance program's effectiveness.

Submission timeliness. Percentage of reports submitted within the seven-day window. Target: 100%. Industry average: 87%.

Classification accuracy. Percentage of workers correctly classified on first submission. Target: 98%+. Average GC scores 91% before implementing automated checks.

Sub-tier collection rate. Percentage of sub-tier payrolls collected on time. Target: 95%+. GCs without automated collection average 72%.

Audit findings. Number of wage violations found per $1M in payroll processed. Best-in-class GCs report fewer than 0.5 violations per $1M. The national average is 2.3.

Use Our Free Prevailing Wage Lookup Tool

Before starting any prevailing wage project, verify the applicable wage rates. Our Prevailing Wage Lookup Tool helps you find federal and state wage determinations by project location and trade classification.

FAQs

What is certified payroll and who must submit it? Certified payroll is a weekly payroll report required on federally funded construction projects under the Davis-Bacon Act. Every contractor and subcontractor performing work on the project must submit it. The GC is responsible for collecting reports from all tiers of subcontractors and submitting them to the contracting agency.

What form do I use for certified payroll? The standard federal form is the WH-347. You can download it from the Department of Labor website. Some states require their own forms instead of or in addition to the WH-347. California uses the eCPR electronic system. New York requires the PW-16 form. Check your state's requirements before starting a project.

What happens if I submit certified payroll late? Late submissions can trigger contract payment holds, agency investigations, and penalties. The federal penalty for falsifying certified payroll is up to $1,100 per statement. Repeated late submissions can lead to debarment from future federal contracts for up to three years.

How do I determine the correct prevailing wage rate for my workers? Wage determinations are published by the DOL for federal projects and by state agencies for state-funded projects. Each determination lists hourly rates and fringe benefits by trade classification for a specific geographic area. You must use the determination included in your contract or the most current published rate, whichever is higher.

Do I need certified payroll software, or can I use spreadsheets? Spreadsheets work on small projects with few subcontractors. Once you manage more than two or three prevailing wage projects with 10+ subcontractors each, software pays for itself in time savings and error reduction. The average GC spends 8.5 hours per week on manual certified payroll. Software reduces that to 2.1 hours.

What records do I need to keep and for how long? Keep all certified payroll reports, time cards, wage determinations, worker classification records, and fringe benefit contribution records. Federal law requires three years of retention after project completion. Some states require up to six years. Store records in a format that allows quick retrieval during an audit.

Take Control of Certified Payroll Compliance

SubcontractorAudit helps general contractors track subcontractor compliance across every project. Request a demo to see how our platform simplifies certified payroll collection, wage verification, and audit-ready record keeping.

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Javier Sanz

Founder & CEO

Founder and CEO of SubcontractorAudit. Building AI-powered compliance tools that help general contractors automate insurance tracking, pay application auditing, and lien waiver management.