Last updated: October 2026

Certified Payroll and Form WH-347: What Contractors File, and When

A false certified payroll can bring federal criminal and False Claims Act penalties.

Certified payroll is the weekly wage report a contractor on a federally funded construction job files, together with a signed Statement of Compliance. Optional Form WH-347 carries a January 2025 revision, cleared by the Office of Management and Budget on 6 January 2025 under control number 1235-0008, and that clearance runs to 31 January 2028.

What follows is the rule for each field, the section of the Code of Federal Regulations it comes from, and the arithmetic, because arithmetic is where this goes wrong.

What you are actually signing

The regulated act is the certification itself. Wage data is what the certification vouches for. Under 29 CFR 5.5(a)(3)(ii)(C), every weekly submission must arrive with a signed Statement of Compliance. The signer is the contractor, the subcontractor, or the agent who pays or supervises payment.

That statement certifies three separate things. First, that the payroll for the period holds the required information and that the information and records are correct and complete. Second, that every laborer and mechanic, including helpers and apprentices, has been paid the full weekly wages earned without rebate, direct or indirect, with no deductions beyond those permitted by 29 CFR part 3. Third, that each worker was paid at least the applicable rates and fringe benefits, or cash equivalents, for the classifications of work actually performed under the determination incorporated into the contract.

Each of the three is a separate promise, and each can be false on its own. A payroll can be arithmetically perfect and still fail the second certification because of one unauthorized deduction. It can survive the second and fail the third because a worker was booked under the wrong trade.

The statement itself sits on the reverse side of Form WH-347. Under 29 CFR 5.5(a)(3)(ii)(D), submitting that certification properly executed satisfies the requirement outright, which is the whole reason the two-page form exists.

Filling out WH-347, field by field

Start from the fact that the form is optional and the duty is not. Under 29 CFR 5.5(a)(3)(ii)(B), the required weekly information may be submitted on Optional Form WH-347 or in any other format desired. An agency or a prime may impose its own portal, and many do. What cannot vary is the content, which part 5 fixes at 29 CFR 5.5(a)(3)(i)(B).

What goes on a certified payroll report

Six data elements are fixed by rule:

• The worker's name.
• The worker's correct classification or classifications of work actually performed.
• Hourly rates of wages paid, including the rates of contributions or costs anticipated for bona fide fringe benefits, or the cash equivalents.
• Daily and weekly hours actually worked, both in total and on each covered contract.
• Deductions made.
• Actual wages paid.

Two of those trip people up. Hours worked in total and on each covered contract means a worker splitting a week between a federal job and private work needs both figures, since the total is what proves the deductions and the net. The plural in "classification or classifications" anticipates that one person may hold two trades in one week.

How to fill out certified payroll without leaking identifiers

The identity fields work differently on the record than on the report. Your own payroll records must hold the full Social Security number plus last known address, telephone number and email. The weekly transmittal must not. Under 29 CFR 5.5(a)(3)(ii)(B), full Social Security numbers and those contact details cannot appear on weekly transmittals, and the submission need only carry an individually identifying number for each worker, such as the last four digits.

Signatures are looser than the paper suggests. Under 29 CFR 5.5(a)(3)(ii)(E), the signature may be an original handwritten one or a legally valid electronic one. An agency or a prime may also require electronic submission, provided the system takes a valid electronic signature and preserves access for three years.

The fringe math, worked

Fringe is where the money leaks, so this section is the long one. A wage determination gives two numbers per classification, a basic hourly rate and a fringe rate. Under 29 CFR 5.31(a), a contractor may discharge both by paying cash, by making payments or incurring costs for bona fide fringe benefits, or by a combination of the two.

A worked certified payroll example, using the regulation's own numbers

Part 5 runs its own illustration, and it is worth using because the figures are the government's. For the classification "Laborer: common or general," 29 CFR 5.31 uses a basic hourly rate of $21.93 and a fringe rate of $6.27. The combined obligation is therefore $28.20 an hour.

Note the discrepancy before relying on the published text. Paragraphs (b)(2) and (b)(3) both print the combined figure as "$28.60 ($21.93 basic hourly rate plus $6.27 for fringe benefits)." Those two components sum to $28.20. The wage table they point to, Figure 1 to 29 CFR 5.30(c), is published as an image, so the text never discloses which of the three numbers carries the typo. The arithmetic below uses the two component rates, since those are the ones a wage determination actually gives you.

Route one, under 29 CFR 5.31(b)(1): pay the $21.93 in cash and make contributions of at least $6.27 an hour to bona fide plans. Over a 40-hour week that is $877.20 in cash wages and $250.80 in contributions, $1,128.00 in total.

Route two, under 29 CFR 5.31(b)(2): pay the whole thing in cash, at $28.20 an hour. Over 40 hours it comes to the same $1,128.00, all of it wages.

Route three, under 29 CFR 5.31(b)(3), is any mix reaching that total. Contribute $4.00 an hour to a plan and the remaining $2.27 has to go to the worker in cash, because $21.93 plus $4.00 plus $2.27 is $28.20. What matters is the total. The proportions are yours to choose.

Where the money actually leaks

A contractor takes the plan credit of $6.27 an hour on the report, but the plan actually costs $4.10 an hour per worker. The gap is $2.17 for every hour worked. On one laborer that is $86.80 a week, which nobody notices. On a crew of eight it is $694.40 a week. Across a 30-week project it is $20,832 in underpaid wages, every dollar of it certified as paid.

That figure is why the annualization question matters. A credit has to reflect what the benefit actually costs per hour of covered work. A plan whose cost is spread across a worker's whole year, private jobs included, does not deliver $6.27 of value to a Davis-Bacon hour merely because the plan document says so.

The reporting consequence is straightforward. Whichever route you take, the report has to show the rate of contributions or anticipated costs alongside the cash rate, because 29 CFR 5.5(a)(3)(i)(B) treats the fringe figure as part of the hourly rates of wages paid. A form showing a single combined number with no breakdown does not tell a reviewer which route was used.

Classification follows the work performed

Job titles have no standing under the determination. Under 29 CFR 5.5(a)(1)(i), workers must be paid for the classifications of work actually performed, without regard to skill. A company can call someone a foreman, a helper, or a technician, and the rate will still be set by what the hands did.

Splitting a week between trades is allowed, with one condition attached. The same section lets a worker in more than one classification be paid each classification's rate for the time actually worked in it, provided the employer's payroll records accurately set forth the time spent in each. The permission and the record-keeping duty arrive in a single sentence, joined by that proviso.

The cost of getting this wrong compounds, because a misclassification repeats on every report until someone catches it. A worker booked one classification low for six months generates twenty-six defective certifications. The prevailing wage guide covers how the Department of Labor sets those rates by trade and county in the first place.

Overtime sits on a separate track from all of this, governed by its own statute and its own weekly threshold, and a report can be correct on classification and rate while the overtime premium underneath it is wrong. The overtime guide covers how the regular rate is built.

Classification is a separate question from permission

Correct classification settles what an hour is worth. Whether a given worker may perform that hour at all is a different question with a different regulator. Some construction scopes carry their own credential. Removing or closing a regulated underground storage tank is one. The determination prices a laborer or an equipment operator on that site, and the state decides separately whether the firm may touch the tank at all.

A published state-by-state survey of which states require a credentialed contractor for underground tank work shows the requirement varying by jurisdiction, with several states applying narrower rules. A certified report showing correct rates for an uncredentialed crew documents that problem and settles nothing.

The determination and the Davis-Bacon poster, WH-1321, also have to be posted at the site at all times under 29 CFR 5.5(a)(1)(i), somewhere prominent enough that workers can read them.

Certified payroll for subcontractors

Subcontractors carry the same duty and the prime carries the consequences. Under 29 CFR 5.5(a)(3)(ii)(A), the prime contractor is responsible for the submission of all certified payrolls by every subcontractor. A sub that files late has not created a problem for itself alone.

That allocation moves the prime's work to Monday morning, weeks before closeout. A prime running several subs on one job is effectively operating a collection process with a seven-day clock on it, and the practical answer is a standing internal deadline set earlier than the regulatory one.

Retention makes the asymmetry worse. Records must be kept for three years after all work on the prime contract is completed, under 29 CFR 5.5(a)(3)(i)(A) and 29 CFR 3.4(b). The clock ignores both the sub's last day and the pay date. A drywall sub who demobilizes in month three of a thirty-month job is still holding records at month sixty-six, long after that project has left everyone's active file. Subs bidding federal work should price that storage obligation into overhead before discovering it during a document request.

Subs should also know what they can decline to hand over. A prime may require full Social Security numbers and contact details for its own records under 29 CFR 5.5(a)(3)(ii)(B). Nothing in that section makes those details part of the agency submission, and the same paragraph keeps them off weekly transmittals. A sub asked to put full numbers on the transmittal itself is being asked for the wrong thing.

Certified payroll requirements: deadlines, retention, and the weeks you do not file

Seven days, and the clock starts at a date that is easy to get wrong. Under 29 CFR 3.4(a), each report must be delivered within seven days after the regular payment date of the payroll period. The trigger is the date the workers were paid, and not the date the pay period closed. A firm running a five-day lag between period end and payday has twelve days from period end, and a firm paying on the following Friday has fourteen. Guidance counting from the end of the payroll period describes a stricter deadline than the regulation sets, which stays harmless until someone builds a process on the wrong anchor and then moves pay dates.

Contracting agencies keep their own copies for the same three years under 29 CFR 3.4(a).

Does a week with no work need a report?

Under 29 CFR 5.5(a)(3)(ii)(A), submission is required weekly for each week in which any covered work is performed. The trigger is a week containing covered work. A week with none does not meet the condition, and no report is owed for it.

Ask the contracting officer what the contract requires and get the answer in writing before the first payroll runs.

What happens when the certification is wrong

There is no flat civil penalty for a defective report.

What exists instead is worse. Under 29 CFR 5.5(a)(3)(ii)(F), falsification of any of those certifications may subject a contractor or subcontractor to civil or criminal prosecution under 18 U.S.C. 1001 and 31 U.S.C. 3729, the False Claims Act. The statutory hook is 40 U.S.C. 3145(b), a provision one sentence long: Section 1001 of title 18 applies to the statements.

Each submission is a separate certification, so a recurring error produces a series of them.

Alongside that sit the ordinary contract remedies: back wages with no ceiling, withholding of contract funds, termination, and debarment from future federal work. Overtime violations carry their own liquidated damages under 29 CFR 5.5(b)(2) and 29 CFR 5.8(a), which are an overtime remedy and not a paperwork fine.

Set against all of that, the $20,832 fringe gap from the crew of eight is the cheap version of this problem. It is a wage underpayment, and wage underpayments get repaid. The expensive version is the same gap certified as correct for thirty consecutive weeks, which converts one payroll error into thirty statements the government can characterize as false.

Why Government Contract Reporting Costs More Than Contractors Expect

Under 40 U.S.C. 3142(a), the Davis-Bacon contract clauses go into every covered construction contract in excess of $2,000. The Davis-Bacon certified payroll reporting requirement extends to every subcontractor on the project, regardless of their individual contract size. A framing crew with three workers on a major highway job files the same weekly report as the general contractor.

The real cost is time, not paperwork. Each weekly report requires line-by-line wage data for every worker: hours by day, pay rate, fringe benefits, deductions, and net pay. For a contractor running two government jobs, that is a separate worker-line entry for every worker on every site, every week, for the life of the project. The weekly time commitment scales with crew size and with the number of concurrent government jobs.

Late reports cost more than late concrete.

Reporting Software vs Doing It by Hand

You can complete the WH-347 by hand or in a spreadsheet. For a contractor with five workers on one government project, that approach works. The form is straightforward, and at that scale the weekly entry is short enough to handle without building a process around it.

The math changes with crew size. As headcount rises and projects with different wage determinations run concurrently, manual entry becomes a source of errors, not savings. Prevailing wage compliance software like Payroll4Construction, LCPtracker, and Elation Systems automates wage determination lookups, calculates fringe benefit splits, flags underpayments before you sign the Statement of Compliance, and generates submission-ready reports.

Compliance reporting software is priced as a monthly subscription that scales with employee count and project volume. Payroll4Construction bundles the reporting into its construction payroll platform, handling both regular payroll processing and prevailing wage compliance in one system.

Software calculates. It does not verify.

If you enter the wrong classification code, the software will calculate wages perfectly at the wrong rate. Every report still needs human review before the Statement of Compliance is signed. For contractors who handle fewer than two government projects per year, a well-built spreadsheet template with the correct wage determination rates entered manually handles the occasional government contract at zero software cost. The tradeoff is that spreadsheets do not flag errors, and you carry the full audit risk yourself.

Your Next Steps for Government Contract Payroll

Pull the wage determination for your project from the federal wage determination search at SAM.gov before the first worker sets foot on the job site. Verify every classification and fringe benefit rate against the contract documents.

Set up your weekly reporting schedule on day one. Anchor that schedule to your regular payment date, not to the close of the payroll period, and block standing time to compile each week's data once payday clears.

If you run more than one government project or employ more than 10 workers on prevailing wage jobs, evaluate whether a dedicated construction payroll platform saves enough time to justify the monthly cost. For most contractors above that threshold, it does.

Review your worker classifications against the wage determination quarterly. Rates update, and a classification that was correct in January may fall short by summer.

For questions beyond prevailing wage reporting, the construction payroll hub covers union payroll processing. If your workers earn overtime on government projects, prevailing wage overtime calculations differ from standard FLSA rules. The payroll provider directory lists platforms that handle construction-specific compliance alongside standard payroll.

This is not legal or financial advice. Consult a qualified professional for your specific situation.