Certified Payroll for US Contractors: Map Field Time to WH-347

If your contract is federally funded or federally assisted and exceeds $2,000, certified payroll requirements apply to you. The single action to take now: file a certified payroll every week you have covered workers on site, using WH-347 or an equivalent format, signed with a Statement of Compliance. Everything else, classifications, fringe credits, e-signatures, is detail layered on top of that one obligation.

TL;DR:

• Contractors and subcontractors performing federally assisted construction projects over $2,000 must file weekly certified payrolls using the WH-347 form with signed statements of compliance.
• All workers, including 1099 contractors working on covered tasks, require classification and accurate wages recorded in compliance with prevailing wage determinations.
• Mistakes such as missing payrolls, misclassification, or unsigned statements can lead to penalties, debarment, or back wages, emphasizing the need for diligent weekly recordkeeping.
• Prime contractors should require weekly payroll submissions from subcontractors, verify classifications early, and include payroll accuracy as a condition of payment.
• Digital, field-to-office workflows and organized record retention streamline compliance, especially when managing multi-state projects or integrating electronic signatures.

Table of Contents

• What Are Certified Payroll Requirements, and Who Must File?
• What Goes on a Certified Payroll: WH-347 Fields Explained
• How to Complete Certified Payroll Step by Step
• Electronic Filing, E-Signatures, and Three-Year Recordkeeping
• State-Level Variations in Certified Payroll Filing
• Common Certified Payroll Mistakes and How Enforcement Works
• Prime Contractor Responsibilities for Subcontractor Compliance
• A Digital Workflow That Maps Field Time to WH-347
• What Subcontractors Should Do This Week
• Sources

What Are Certified Payroll Requirements, and Who Must File?

Certified payroll is the weekly record proving you paid workers the prevailing wage the government determined for their trade and location. The rule comes from the Davis-Bacon and Related Acts (DBRA), and it applies to any contractor or subcontractor performing construction, alteration, or repair work on a federal or federally assisted contract worth more than $2,000. That threshold has stayed fixed for decades, so it catches nearly every job that qualifies as federal construction work, not just the mega-projects.

Here’s the checklist to run against your own contract this week:

• Does the contract dollar amount exceed $2,000? If yes, DBRA coverage almost certainly applies, per 29 CFR §3.3, which explicitly exempts smaller jobs.
• Are you a prime contractor or any tier of subcontractor on that job? Both are required to file. There’s no size exemption for subs, and no “we’re just doing one trade” carve-out.
• Is the work performed by anyone classified as covered labor, including 1099 workers doing covered tasks? The Department of Labor’s own guidance confirms 1099 workers count when the work itself is covered, regardless of how you classify them for tax purposes.
• Have you assigned sequential payroll numbers starting at “1” for the project? Gaps in numbering are one of the first things auditors flag.
• Do you know who receives the payroll? Submission usually goes to the contracting agency, the funding sponsor, or the contracting officer named in your contract, not to the Department of Labor directly in most cases.

Cadence matters as much as content. You file weekly, for every week you have covered employees on the job, even during slow weeks. A “no work performed” payroll still needs to go in if the contract is active. Skipping a week because nobody logged hours is a common mistake that turns into a compliance flag later.

What Goes on a Certified Payroll: WH-347 Fields Explained

WH-347 is the Department of Labor’s standard template, and using it is optional. What’s not optional is including every field it requires, in whatever format you submit, along with a signed Statement of Compliance using DOL’s exact language.

Each line of a compliant certified payroll needs to show:

• Employee name and an identifying number (last four of the Social Security number is standard practice, not a full SSN)
• Work classification, matched to the wage determination for that trade and county
• Daily hours, broken into straight time and overtime, for every day worked that week
• Total hours for the week
• Hourly rate of pay, both base and any applicable overtime rate
• Gross amount earned on the project
• Deductions taken
• Net wages paid

Pro Tip: Classification is where most payroll errors start. If a worker’s actual duties don’t cleanly match a listed classification on the wage determination, don’t guess. File a conformance request with the Wage and Hour Division before that person works another hour under an assumed rate.

Fringe benefits get their own set of rules. You can pay the fringe portion of the prevailing wage as cash added to the hourly rate, or you can fund it through a bona fide benefit plan (health insurance, retirement contributions, and similar). Either way, the certified payroll has to show how the fringe obligation was met, because an auditor cannot infer it from a lump gross wage figure.

A data point worth internalizing: contracts exceeding $2,000 trigger the requirement, and violations can lead to debarment for up to three years, a consequence that shuts a contractor out of federal work entirely, not just the current job.

The Statement of Compliance sits at the bottom of WH-347 or attaches as a separate signed page if you’re using a custom export. It has to carry a handwritten signature or a legally valid electronic signature, and the person signing needs to be someone with actual authority over payroll, not a field supervisor rubber-stamping numbers they didn’t verify.

How to Complete Certified Payroll Step by Step

Producing a clean, audit-ready certified payroll every week comes down to a repeatable sequence. Here’s the workflow that holds up under DOL review:

1. Collect daily field time first. Before anything else, get accurate start and stop times, broken by task, from every worker on the covered project. This is the raw input everything downstream depends on.
2. Classify each hour against the wage determination. Match the work performed, not the job title, to the correct classification listed for that county and trade. A carpenter doing electrical rough-in gets paid the electrical rate for those hours.
3. Map hours and rates into the WH-347 columns. Straight time, overtime, gross wages, deductions, net pay, each field gets populated from the classified daily data, not estimated after the fact.
4. Calculate fringe credits. Apply the fringe portion either as cash-in-lieu on the hourly rate or as documented contributions to a benefit plan, and note which method you used.
5. Complete and sign the Statement of Compliance. Someone with payroll authority reviews the whole document for accuracy, then signs it by hand or with a valid e-signature.
6. Submit to the party named in your contract. That’s typically the contracting agency, the funding recipient, or the general contractor acting as the flow-down point, depending on how your contract is structured.
7. Archive the payroll and its backup documentation. Keep the certified payroll, time records, and wage determination reference together, not scattered across separate systems.

Special cases trip up otherwise careful contractors. A week with zero covered work still needs a payroll marked “no work performed,” filed on schedule. Workers paid as 1099 contractors still show up on the certified payroll if their work is covered labor, per DOL’s own FAQ guidance. Apprentices get paid at the apprentice rate only if they’re enrolled in a registered program recognized by the Department of Labor or a state apprenticeship agency, otherwise they default to the full journeyman rate. And if a worker’s actual role doesn’t match any classification on the wage determination, that’s a conformance request, submitted to WHD, approved before the rate is used, not after the fact when someone notices the mismatch.

Pro Tip: Build your weekly certified payroll around the same source data you use for job costing. When field hours, classifications, and pay rates flow from one system instead of getting re-keyed three times, the numbers on your certified payroll match your internal cost reports automatically. That consistency is exactly what an auditor wants to see.

Electronic Filing, E-Signatures, and Three-Year Recordkeeping

The Department of Labor allows certified payrolls to be submitted electronically, and it accepts legally valid electronic signatures on the Statement of Compliance. This isn’t a gray area. 29 CFR §3.3 explicitly permits e-signatures, and WHD’s own administrative guidance confirms electronic submission is acceptable practice.

Retention is where contractors get careless. You need to keep certified payroll records, and the ability to produce them, for at least three years after the contract completes. That’s not three years from when you filed each individual payroll, it’s three years from project completion, which for a multi-year job means holding onto week-one records long after that phase of work is a distant memory.

• Store certified payrolls together with the underlying time records and the wage determination that governed the project.
• Keep the records accessible, not just archived. An agency can request them without an active investigation underway, and you need to produce them promptly.
• Confirm your e-signature method meets the standard your contracting agency expects, since some state and local recipients layer on additional requirements beyond the federal baseline.
• Back up digital records the same way you’d back up any financial data, redundantly, and somewhere outside your primary field devices.

Pro Tip: Don’t assume a generic e-signature tool satisfies every recipient. Some state portals require re-keying data into their own proprietary system regardless of how clean your electronic submission already is, so budget time for that second step rather than discovering it the week a payroll is due.

A digital time-tracking workflow with a built-in audit trail solves most of this retention problem before it becomes one, because the record exists the moment the hour is logged, not reconstructed from memory three weeks later.

State-Level Variations in Certified Payroll Filing

Federal rules set the floor, but plenty of states layer their own requirements on top, and missing that layer is one of the more common ways contractors fall out of compliance without realizing it. Some states require submission through a proprietary online portal instead of accepting a WH-347-style document by email. Others maintain their own state prevailing wage forms with slightly different fields than the federal template, and a few set filing cadences or dollar thresholds that diverge from the federal $2,000 mark on state-funded work.

Before you assume your standard process covers a new job, check the following:

• The state labor department’s website for the project’s jurisdiction, since most publish their own prevailing wage forms and portal instructions directly.
• Whether the funding source is federal, state, or a blend, because state-funded prevailing wage laws sometimes apply even when federal DBRA doesn’t, or vice versa.
• The specific portal login and submission format required, rather than assuming your existing certified payroll export will upload cleanly.
• Filing frequency, since a handful of states allow biweekly submission where federal contracts require weekly.

If your work spans multiple states, treat each jurisdiction as its own compliance track. Build a short reference sheet per state: which portal, which form, which signature standard, and who receives the filing. A payroll administrator juggling three states without that reference sheet is the person most likely to submit a Missouri-format payroll to a Nevada portal and get it bounced back.

Common Certified Payroll Mistakes and How Enforcement Works

Most enforcement actions trace back to a small set of recurring errors, not exotic fraud. Missing payrolls for slow weeks, misclassified workers paid at the wrong trade rate, fringe credits claimed without documentation to back them, and Statements of Compliance signed by someone who never actually reviewed the underlying numbers, these show up again and again in DOL findings.

The consequences scale with severity. Withholding of contract funds is often the first step, followed by liability for back wages owed to underpaid workers. Willful violations, especially falsified statements of compliance, can trigger civil or criminal penalties, and repeated or serious violations can lead to debarment from federal contracting for up to three years.

If you discover an error, or WHD flags one:

• Correct the payroll and pay any back wages owed as soon as the error surfaces, rather than waiting for a formal request.
• Respond promptly and completely to any DOL request for records. Guidance is clear that agencies can request certified payroll access even without an open investigation, and slow or incomplete responses read as evasive.
• Run an internal audit periodically, comparing certified payroll classifications against actual field assignments, not just against what got submitted last week.
• Document every correction with a clear paper trail showing what changed and why.

None of this requires a legal team on retainer. It requires catching your own errors before someone else does.

Prime Contractor Responsibilities for Subcontractor Compliance

If you’re the prime contractor, your compliance exposure doesn’t stop at your own payroll. 29 CFR §5.5 contract clauses have to flow down into every subcontract, along with the applicable wage determination, and you carry liability if a subcontractor underpays workers or files defective certified payrolls, even when you had no direct role in the violation.

Practical monitoring closes that gap. Require weekly certified payroll copies from every subcontractor as a contract deliverable, not an occasional courtesy. Ask for documentation on how fringe benefits are funded whenever a sub uses a benefit plan instead of cash-in-lieu.

• Build certified payroll submission into subcontract language as a condition of payment, not a side request.
• Spot-audit a sample of subcontractor payrolls against the project’s wage determination each month rather than assuming compliance because nothing’s been flagged.
• Require documentation of any fringe benefit plan a subcontractor uses to satisfy the fringe portion of the wage.
• Keep a subcontractor reliability checklist as part of your onboarding and ongoing monitoring process, since payroll accuracy correlates with the same reliability signals that predict other project risks.

A subcontractor who resists providing weekly certified payroll copies is telling you something before the audit ever happens.

A Digital Workflow That Maps Field Time to WH-347

The gap between having a policy and actually filing clean certified payrolls every week almost always comes down to how field time gets captured and moved into payroll. A workflow that closes that gap looks like this:

1. Field workers log hours daily, tagged by task and classification at the point of entry, not reconstructed from memory at week’s end.
2. A supervisor reviews and approves those hours weekly, catching classification mismatches before they reach payroll instead of after.
3. Approved hours export directly into WH-347 format, with straight time, overtime, and classification already mapped, so nobody re-types numbers from a paper timesheet.
4. Fringe credits get applied automatically based on the classification and the funding method documented for that trade.
5. The Statement of Compliance gets signed, and the completed payroll routes to whoever’s named in the contract.
6. Everything archives automatically, satisfying the three-year retention requirement without a separate filing step someone has to remember to do.

This is precisely the field-to-office problem construction labor tracking and change order management tools aim to solve, capturing daily labor data at the source and syncing it in real time so payroll isn’t reconstructing hours from paper tickets three days after the fact. When apprentices or 1099 workers are on a job, tagging their status at the point of daily entry means that documentation exists automatically rather than getting assembled under deadline pressure the morning a payroll is due. That single habit, tag it right the first time, prevents more certified payroll headaches than any after-the-fact correction process ever will.

What Subcontractors Should Do This Week

The contractors who stay clean on certified payroll aren’t the ones with the fanciest software. They’re the ones who talk to the prime contractor early about which wage determination applies and confirm classifications before the crew shows up, not after the first payroll gets kicked back. Field-to-office synchronization matters more than people expect: the moment daily hours sit in a spreadsheet waiting to be re-typed into a payroll form, errors creep in and weeks get missed.

Three things to do this week: confirm your contract’s wage determination and classifications with the prime, set up a weekly (not monthly) rhythm for certified payroll production, and organize your record retention now, before you’re three months into a project trying to reconstruct week one.

— Jen Reese

Sources

• Fact Sheet #66: The Davis-Bacon and Related Acts (DBRA) | U.S. Department of Labor
• 29 CFR 3.3 | Certified payrolls | eCFR
• Frequently Asked Questions: Government Contracts (Construction) | U.S. Department of Labor

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