Certified Payroll: A Construction Contractor's Guide to Davis-Bacon Compliance and the WH-347

Certified payroll is a weekly report that contractors on federally funded or assisted construction projects must submit to prove every worker was paid the prevailing wage and fringe benefits the Davis-Bacon Act requires. Each report lists every worker on the job with their classification, daily hours, and rate of pay. It also shows deductions and net wages, and it goes to the contracting agency on U.S. Department of Labor Form WH-347 or a state equivalent, with a signed Statement of Compliance. The requirement applies to Davis-Bacon-covered contracts over $2,000, according to the DOL's Wage and Hour Division. Get it wrong and the consequences arrive fast: payments stop, and repeat offenders lose access to federal work entirely.

Most construction payroll and AP teams meet certified payroll the hard way, in the weeks after their firm wins its first public job. The learning curve is steep because the stakes are asymmetric — the report is due weekly whether or not you have a compliance specialist, and the person assembling it is usually the same overloaded admin chasing subcontractor invoices. It's one piece of the broader construction payment management discipline, and like the rest of that discipline, it gets easier in direct proportion to how clean your labor and payment data is.

Key Takeaways

• Certified payroll is a weekly, signed payroll report that proves prevailing-wage compliance on covered public-works projects. It's filed on federal Form WH-347 or a state equivalent.

• Two laws drive the requirement. The Davis-Bacon Act sets the prevailing wage and fringe obligation; the Copeland Anti-Kickback Act adds the weekly certified report and the signed Statement of Compliance.

• Prime contractors and every tier of subcontractor must file. The prime collects the subs' reports and absorbs the withholding when any of them are missing or wrong.

• Penalties escalate from withheld contract payments to back-wage liability, contract termination, and debarment from federal work.

• Most violations are classification and fringe errors, not intent. Clean labor-cost and payment records are the difference between a routine weekly filing and a scramble.

What is certified payroll, and why does it exist?

Certified payroll is the federal government's proof-of-payment mechanism for public construction. It's a payroll report, filed weekly, in which the contractor lists every laborer and mechanic on a covered project and certifies, under penalty of federal law, that each was paid at least the local prevailing wage and fringe rate for their trade.

Two statutes do the work. The Davis-Bacon Act (40 U.S.C. §§ 3141-3148) establishes the prevailing-wage obligation on covered federal construction. The Copeland "Anti-Kickback" Act and its regulations at 29 CFR Part 3 supply the reporting teeth: covered contractors must submit a weekly statement of the wages actually paid, accompanied by a signed Statement of Compliance attesting that the payroll is accurate and complete. Form WH-347 is the DOL's standard vehicle for both.

The purpose is wage protection on taxpayer-funded work. Congress didn't want federal dollars used to undercut local pay scales, so it tied public construction spending to local wage floors and made contractors prove compliance every week. The sums involved explain the paperwork. U.S. construction spending ran at an annualized rate above $2 trillion in 2025, per the U.S. Census Bureau's Construction Spending survey, and the public share of that market comes with these strings attached.

What is the difference between regular construction payroll and certified payroll?

Regular payroll pays your people; certified payroll proves you paid them correctly. The pay run itself doesn't change. What changes is the compliance layer on top: each worker must be classified to the trade they actually performed, paid at least the published prevailing rate and fringe for that classification, and reported weekly to the contracting agency under a signed attestation.

That distinction matters for staffing. Running certified payroll doesn't require a separate pay cycle or new pay rules for private work. It requires somebody who can defend the classification of every hour on the job — which is why the burden tends to land on whoever owns labor-cost data, not just whoever cuts the checks.

What is the Davis-Bacon Act, and what does it require?

The Davis-Bacon Act requires contractors and subcontractors on federally funded or assisted construction contracts to pay laborers and mechanics no less than the locally prevailing wage and fringe benefits for corresponding work, as determined by the DOL. Congress passed it in 1931; the dollar floor for coverage was set in 1935 and has never been indexed, so in practice nearly every federal construction contract qualifies.

Beyond the original act, dozens of "Related Acts" extend the same requirement to federally assisted work — highways, water systems, housing, energy projects — anywhere federal money flows through grants, loans, loan guarantees, or insurance rather than a direct federal contract. Contractors often meet these on jobs that don't feel federal at all, like a municipal treatment-plant upgrade financed through a federal loan program.

How is prevailing wage determined?

The DOL's Wage and Hour Division sets prevailing wage rates through wage determinations, the county-by-county schedules listing the minimum base rate plus fringe for each labor classification and construction type. Every covered contract incorporates one, and the current schedules are published at SAM.gov.

The methodology changed recently. In 2023, the DOL published its first full overhaul of the Davis-Bacon regulations in nearly 40 years, returning to the pre-1983 definition under which a rate "prevails" when at least 30 percent of surveyed workers in a classification earn it, rather than requiring a strict majority. If you priced prevailing-wage work off old determinations, it's worth re-pulling the schedules before your next bid; rates on many schedules moved with the new survey math.

Who must file certified payroll?

Every contractor and subcontractor with laborers or mechanics on a Davis-Bacon-covered project must file certified payroll, at every tier, for every week worked. The scale surprises people. The DOL estimated its 2023 rulemaking would affect roughly $217 billion in federal and federally assisted construction spending annually and the wages of about 1.2 million U.S. construction workers, per the department's final-rule announcement.

Four groups carry the obligation.

1. Prime contractors on covered federal or federally assisted construction contracts, filing weekly with the contracting agency.

2. Subcontractors at every tier of a covered project. Subs file through the prime, which reviews and forwards each report.

3. Contractors on Related Acts projects, meaning work funded through federal highway, water, housing, or energy programs, including projects several steps removed from any federal agency.

4. Contractors on state and local prevailing-wage jobs in states with "little Davis-Bacon" laws, which run their own forms, portals, and deadlines.

The prime carries more than its own filings. A prime contractor is responsible for collecting, reviewing, and submitting certified payrolls from every sub on the job, and the agency withholds from the prime when any tier's reports are missing or wrong. On a project with 30 subcontractors, that's 30 weekly reports to chase, which is why the burden shows up in AP capacity long before anyone budgets for it. A general contractor's accounting lead described the resulting workload on a construction accounting forum as an AP person "at capacity" and a firm "on the verge of having to hire another."

The covered pool keeps growing, too. The Bipartisan Infrastructure Law directed roughly $1.2 trillion toward infrastructure programs, most of it Davis-Bacon-covered work, according to U.S. Department of Transportation program summaries, meaning thousands of contractors are filing their first WH-347 on jobs it funds.

How do state prevailing-wage rules differ from federal?

Many states run their own prevailing-wage systems on top of the federal one, with separate forms, separate portals, and often higher wage floors. California requires electronic certified payroll submission to its Department of Industrial Relations for public works. New York enforces its own prevailing-wage schedules, with New York City's Comptroller setting citywide rates. Illinois and Ohio maintain their own filing requirements through state portals and contracting authorities. When a project draws both federal and state money, you follow both sets of rules and pay whichever rate is higher.

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How do you complete the WH-347 certified payroll form?

Form WH-347 is two pages: a payroll grid on page one listing every worker's classification, hours, and pay for the week, and a Statement of Compliance on page two that an officer signs. Strictly speaking, using the WH-347 itself is optional — the weekly data and the signed statement are what's mandatory, per the DOL's form instructions — but nearly everyone uses it because it's pre-approved and agencies recognize it on sight.

The header trips up more first-time filers than the math does. Six fields identify the filing.

• Whether you're the prime contractor or a subcontractor (a checkbox)

• Business name and address

• Payroll number, starting at 1 and running sequentially through the job, with the last one marked "final"

• Week-ending date

• Project name and location

• Project or contract number

The grid below the header is where the compliance substance lives, one row per worker.

Field-by-field contents of Form WH-347, per the DOL Wage and Hour Division's form instructions.

Fringe benefits get their own logic. The prevailing rate for each classification is really two numbers, a base hourly rate and a fringe rate, and you can satisfy the fringe portion either by paying into bona fide benefit plans or by paying it as cash on the paycheck. The Statement of Compliance asks you to declare the method. Section 4(a) covers payments into approved plans or programs, 4(b) covers cash paid in lieu of benefits, and 4(c) records exceptions worker by worker.

Classification is where most honest mistakes happen. The entry in column 3 must match the work each person performed that week, not their title or hiring category, and the only workers who may be paid below the listed journeyman rate are apprentices registered in an approved program, within that program's allowed ratio. When an electrician spends Tuesday operating a lift, somebody has to decide — and be able to defend — how those hours were classified.

Page two is the part with legal weight. The Statement of Compliance is signed by the contractor, the subcontractor, or an officer who supervises the payment of wages, and it attests that the payroll is correct and complete, that every worker was paid no less than the applicable wage-determination rate for the work performed, and that deductions follow the Copeland rules. The form's own fine print notes that falsification can bring civil or criminal prosecution. That signature is why it's called certified payroll rather than just payroll.

Where do you get the WH-347, and is there a fillable version?

The form and its instructions live on the DOL's Wage and Hour Division site, including a fillable PDF that totals hours and wages as you type. States with their own systems increasingly skip paper and take submissions through electronic portals instead. Before your first covered pay period, run a dry week — pull one set of real timecards and complete the form end to end, because the first live filing is a bad time to discover your time tracking doesn't capture daily hours by classification.

How often do you submit certified payroll, and to whom?

Weekly, within seven days of the regular pay date, to the contracting agency or the funding recipient administering the project. Subcontractors route reports through the prime. The cadence doesn't pause when work does; many agencies expect a "no work" payroll for idle weeks so the numbering stays continuous, and the numbering itself matters because gaps are the first thing a compliance reviewer scans for.

What are the penalties for certified payroll non-compliance?

Penalties for certified payroll violations start with money and end with market access. The enforcement sequence typically runs six deep.

1. Withheld contract payments until violations are corrected, including withholding from the prime for a subcontractor's failure.

2. Back-wage liability for every underpaid worker, computed against the correct classification and rate.

3. Liquidated damages and interest on top of the back wages.

4. Contract termination for cause.

5. Debarment from federal contracts for up to three years under 29 CFR 5.12.

6. Reputational damage that follows the firm onto future bid lists, since debarment records are public.

Withholding is the lever that bites first, and it bites the whole job. Funds held over a payroll problem behave like retainage that never releases, stacked on top of the retention you're already financing, and the squeeze lands directly on construction cash flow, often on projects where margins were thin to begin with. Most findings aren't fraud, though. They're classification errors, fringe miscalculations, and missing reports, which is why the durable fix is usually better data rather than better lawyers.

How does clean payment and AP data make certified payroll manageable?

The form is the easy part. The weekly lift is the data behind it — who worked, in what classification, at what rate, with what deductions, paid through which channel — and being able to prove all of it months later when a reviewer asks. Contractors who treat certified payroll as a data problem rather than a paperwork problem spend less time on both.

Fragmented payment operations make that harder than it should be. When subs get paid by check from one system, ACH from another, and card from a third, reconciling labor cost to payment records means stitching three ledgers together every Friday. One VP of accounting, writing in a peer forum, described how "different approval routing for different payment methods can interfere with each other." Certified payroll inherits every one of those seams.

Centralizing payments fixes the reporting problem at its source. When subcontractor and supplier payments run through one platform, every disbursement carries an approval trail, a timestamp, and a project tag, and the same controls that deter accounts payable fraud double as compliance evidence. That's the quiet payoff of AP automation for public-works contractors; the audit trail exists before anyone asks for it. It also keeps adjacent compliance paperwork close at hand, since the conditional and unconditional lien waivers you're already exchanging with subs each pay cycle sit beside the payment records your certified payroll draws from.

How does labor cost tracking connect to certified payroll?

They're the same data viewed from two directions. Job costing allocates each worker's hours to cost codes so you know what the labor cost; certified payroll reports those same hours by classification so the agency knows what the labor paid. If your cost codes can't tell an operator's hours from a laborer's on the same crew, your WH-347 classifications are guesses. The connection gets tested every time a change order adds scope mid-project — new crews, new classifications, sometimes a classification that isn't on the wage determination yet and has to be requested from the agency before the work starts.

What should a contractor look for in certified payroll software or a payment platform?

Start from the failure modes rather than the feature lists. The reporting burden usually lands on people who weren't hired for it. One construction accountant's lament that "the annoying part of the AR/AP process is done by the PMs" rings true across the trades, so the tooling has to close gaps a specialist would otherwise catch by hand.

Whatever combination of payroll tool and payment platform you run, the checklist is short.

• Pulls current wage determinations so rates and classifications aren't keyed by hand

• Produces WH-347-formatted output plus the state formats you file in

• Files electronically where portals exist, with confirmations you can store

• Flags rate and classification mismatches before submission, not after a finding

• Ties into job costing and your construction ERP so hours carry cost codes and classifications from the field forward

• Keeps an audit trail of who approved what, on both the payroll and the payment side

The same evaluation logic applies on the payment side, where choosing construction payment software turns on data quality and integration depth more than on feature count. And since payroll automation keeps absorbing more of this reporting work each year, favor systems that expose data cleanly over systems that trap it.

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Corpay gives construction finance teams one place to run subcontractor and supplier payments. Approvals, disbursement, and payment records live in one workflow with an audit trail on every transaction. Corpay's AP automation covers invoice capture through payment across ACH, virtual card, and check, and its ERP integrations connect to the systems contractors already run — CMiC, Computer Guidance, Sage 300 CRE, and Acumatica Construction among 180+ supported platforms. Virtual card payments can also generate rebate income on eligible spend, which quietly offsets some of the overhead public work carries.

The WH-347 stays with your payroll and compliance workflow; Corpay's job is the layer underneath, keeping the subcontractor payment and vendor data your filings draw from clean, centralized, and provable. More than 800,000 businesses run payments on Corpay, the #1 commercial Mastercard issuer in North America. If weekly compliance reporting is stretching your AP team, see how Corpay consolidates payment records into one auditable operation.

Frequently Asked Questions

What is certified payroll?

A weekly payroll report that contractors and subcontractors on covered public-works projects file to prove workers were paid the required prevailing wage and fringe benefits. It's submitted on federal Form WH-347 or a state equivalent and includes a signed Statement of Compliance.

What is the difference between construction payroll and certified payroll?

Construction payroll is the act of paying your workers. Certified payroll is the compliance report layered on top for public jobs. The same wage data gets classified by trade, checked against prevailing rates, and certified weekly to the contracting agency under a signing officer's attestation.

Who has to submit certified payroll?

Prime contractors and subcontractors at every tier of a Davis-Bacon-covered project, plus contractors on federally assisted Related Acts work and on state prevailing-wage jobs. The prime collects and forwards each sub's weekly reports and answers to the agency when any are missing.

What is the WH-347 form?

The U.S. Department of Labor's standard certified payroll form. Page one is a grid reporting each worker's classification, daily hours, and pay for the week, gross through net; page two is the signed Statement of Compliance. Using this exact form is optional, but reporting the data weekly isn't.

How often do you have to submit certified payroll?

Every week, due shortly after each regular pay date, for as long as covered work continues. Reports go to the contracting agency or the funding recipient administering the project, and subcontractors submit theirs through the prime contractor, which reviews and forwards them.

What is prevailing wage, and how is it determined?

The minimum hourly wage plus fringe benefits that the DOL determines workers in each labor classification earn in a given county, published as wage determinations that covered contracts incorporate. The Wage and Hour Division sets rates through wage surveys, under the methodology updated by its 2023 final rule.

What is the Davis-Bacon Act?

A Depression-era federal law requiring contractors and subcontractors on federally funded or assisted construction contracts to pay locally prevailing wages and fringe benefits. It's the legal foundation of certified payroll, enforced by the DOL's Wage and Hour Division alongside the Copeland Act's weekly reporting requirement.

What are the penalties for not filing certified payroll?

Contracting agencies withhold payments until reports are current and violations are cured. Beyond withholding, contractors face back-wage liability, liquidated damages, contract termination, and debarment from federal contracting. Falsified reports carry criminal exposure, since the Statement of Compliance is a federal certification.

Do I need certified payroll software?

Not strictly. A small crew on one covered job can manage with the fillable WH-347 and careful timekeeping. Software earns its cost once multiple projects, states, or subcontractor tiers are involved, mostly by pulling current rates automatically and flagging classification mismatches before an agency finds them.

Does Corpay file certified payroll for me?

No. Certified payroll is filed on the WH-347 or your state's system through your payroll workflow. Corpay supports the operation around it by keeping subcontractor payments, approvals, and payment records in one auditable system, so the data behind your filings is accurate and easy to prove.

David Luther

Product Marketing Program Manager

David Luther, MBA is a product marketing program manager with years of experience in commercial banking, finance, and technology sectors, with research and writing appearing in financial publications.

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