Certified payroll is a weekly federal reporting requirement for contractors and subcontractors working on government-funded construction projects, documenting that every worker was paid at least the prevailing wage set by the U.S. Department of Labor.
Any construction company working on a federal contract worth more than $2,000 must submit these reports — and the stakes for missing them or getting them wrong include contract payment holds, back wage liability and a three-year ban from federal contracting.
This guide breaks down what certified payroll is, who needs to file, how Form WH-347 works, state-specific rules in California, New York, Illinois and beyond, the most common mistakes that trigger compliance violations and how construction companies use Fingercheck to automate the entire process from time tracking to report submission.
What is certified payroll?
Certified payroll is a weekly payroll report that contractors and subcontractors submit to the government agency overseeing a federally funded construction project. The report documents each worker’s name, job classification, daily and weekly hours, base wage, fringe benefits, deductions and net pay — and certifies, under penalty of federal law, that every employee was paid at least the prevailing wage rate for their trade and location.
The word “certified” carries real legal weight. Each report includes a Statement of Compliance — a declaration signed by the contractor or subcontractor affirming that all information is accurate and that all wages meet or exceed federal requirements. That signature subjects the report to penalties under 18 U.S.C. § 1001, the federal statute governing false statements to the government. A falsified report isn’t a paperwork problem; it’s a federal compliance violation.
One clarification worth making early: you don’t need to be a Certified Payroll Professional (CPP) to file certified payroll reports. The CPP is a professional credential for payroll practitioners — it’s unrelated to whether your business can prepare and submit certified payroll. Any payroll administrator who understands the requirements can file them.
Certified payroll is also distinct from your standard payroll process. Normal payroll is the act of paying your employees. Certified payroll is the formal documentation — submitted weekly, with legal attestation — proving to a federal agency that those employees were paid in compliance with prevailing wage law.
The Davis-Bacon Act and prevailing wage
Certified payroll reporting exists because of the Davis-Bacon and Related Acts, a set of federal labor laws requiring contractors on public works projects to pay workers the locally prevailing wage for their trade and location. Congress passed the original Davis-Bacon Act in 1931 during the Great Depression to protect construction workers on public projects from wage undercutting. In 2023, the Department of Labor issued the most significant revisions to the Act in decades — updating prevailing wage survey methodologies, expanding electronic reporting requirements and strengthening protections for apprenticeship programs.
Prevailing wage is the minimum hourly compensation — base wage plus fringe benefits — determined by the DOL’s Wage and Hour Division for each construction trade classification and geographic area. It isn’t the federal minimum wage. A carpenter in one county may have a prevailing wage of $40 per hour in base wages plus $14 per hour in fringe benefits. A carpenter in a neighboring county may have a different rate entirely, because prevailing wage reflects what workers in that specific trade are actually paid in that local market.
You can look up current prevailing wage determinations for any project location and trade through SAM.gov’s wage determination portal before work begins.
Prevailing wage and certified payroll are related but not the same thing. Prevailing wage is the standard — what workers must be paid. Certified payroll is the weekly report that proves you met that standard. Many contractors conflate them. The practical distinction: your obligation to pay prevailing wages exists regardless of reporting. Certified payroll is the accountability mechanism that makes compliance verifiable.
More than 30 states have enacted “Little Davis-Bacon” laws — state-level prevailing wage requirements that apply to state- and locally funded public works projects, even when no federal dollars are involved. These state laws have their own wage rates, thresholds, forms and enforcement agencies. The state-specific section below covers the key variations.
Who needs to file certified payroll?
The Davis-Bacon Act applies to any construction contract valued at more than $2,000 that receives federal funding or assistance. That threshold is lower than many contractors expect, and it covers a wide range of project types:
- Federal buildings, highways, bridges and military installations
- Schools and government facilities funded through federal grants
- Public housing and community development projects funded through the Department of Housing and Urban Development (HUD)
- Infrastructure funded through the Department of Transportation and similar agencies
- State and local projects that receive federal financial assistance (varies by state law)
Both prime contractors and all subcontractors on a covered project must file their own certified payroll reports. A subcontractor’s obligation is independent of the prime contractor’s. Subcontractors submit their reports to the prime contractor, who compiles and forwards the full package to the contracting agency. The prime contractor is responsible for ensuring all subcontractor reports are included — but that responsibility doesn’t replace each subcontractor’s obligation to prepare accurate reports.
Business owners who personally perform physical labor on a federal project must also report their own wages, even if they don’t draw a salary through standard payroll.
Who is generally exempt from certified payroll:
Certified payroll requirements are designed to protect hourly construction workers performing manual labor on job sites. The following are generally not covered:
- Salaried employees in executive, administrative or professional roles who aren’t performing manual work at the project site
- Purely clerical staff working off-site
- Workers enrolled in DOL-registered apprenticeship programs are still workers on covered projects but may be paid at different wage tiers based on their apprenticeship stage
If you’re unsure whether a specific role or project is covered, the contracting agency or a labor compliance specialist can clarify before you start.
Government contracts require certified payroll. We handle it.
Fingercheck automates certified payroll reporting for construction teams — from GPS time tracking to compliant WH-347 PDFs.
What goes on Form WH-347
The standard federal certified payroll form is Form WH-347, a two-page document issued by the Department of Labor. It’s technically optional under federal law — contractors may use any equivalent format — but in practice WH-347 is the standard that contracting agencies expect, and most require it or a state-specific equivalent.
Page 1: Payroll data
The first page documents the wage and hour information for every worker on the project during the pay period. For each employee, you report:
- Name and last four digits of their Social Security number (not the full SSN)
- Work classification — the specific trade category matching the DOL wage determination for this project and county (carpenter, electrician, laborer, pipefitter, ironworker, etc.)
- Hours worked each day and total hours for the week, broken out by regular and overtime
- Base hourly wage rate and hourly fringe benefit rate, reported separately
- Gross wages earned on the project during the period
- Itemized deductions: federal withholding, FICA, Medicare, state taxes, union dues, garnishments and any other deductions
- Net wages paid
At the top of the form: contractor or subcontractor name and address, payroll number (sequential from “1” per project), the week-ending date and the project name, location and contract number.
Worker classification requires precision. If a worker performs duties under more than one trade classification in the same week — an electrician who also works as a general laborer, for example — each classification and its corresponding hours must be entered as separate line items, each at the applicable prevailing wage rate. Using the wrong classification is the most common certified payroll violation.
Fringe benefits must be reported at their per-hour equivalent value, separate from the base wage. If you provide health insurance, retirement contributions and vacation accrual, you calculate the per-hour cost of those benefits and report it on the form. If you don’t provide qualifying benefit plans, the full fringe benefit amount from the prevailing wage determination must be paid in cash directly to the worker and reported accordingly.
Page 2: Statement of Compliance
The second page is the signed Statement of Compliance. This legal declaration confirms that all wages and fringe benefits listed on the form meet or exceed the applicable prevailing wage requirements, and that all information is accurate and complete. It’s signed by the contractor or subcontractor — it doesn’t require notarization, but it is legally binding, and submitting a falsified statement is a federal offense.
The statement also specifies how fringe benefits are being provided: through a qualified benefit plan, through a union trust fund or paid directly in cash to workers. Misrepresenting the fringe benefit method is a reportable violation.
Some agencies require a submission even for weeks with no work performed on the project — a “no work performed” report. Confirm your contracting agency’s requirement on this before assuming a blank week doesn’t need a filing.
How to submit certified payroll reports
Certified payroll reports are due within seven days after each weekly pay period ends. For subcontractors, that means submitting to the prime contractor in time for the prime to compile and meet the agency deadline.
Submission methods vary by agency and state. Options include email, fax, mail and electronic portal. Some states now require electronic submission — California mandates it through a state-specific system for most public works projects. When a project is subject to both federal and state requirements, you must satisfy both.
How long to keep records: Under the Davis-Bacon Act and state prevailing wage laws, contractors must retain certified payroll reports and all supporting documentation for a minimum of three years after the prime contract is completed, and records must be available for Department of Labor audit on request. State-specific projects may require retaining these records for four years or longer. California requires five years; New York requires six. For multi-state contractors, the safest approach is to apply the most stringent standard across the board.
A practical note on payroll scheduling: because certified payroll is filed weekly, running payroll on a weekly schedule simplifies the process significantly. Biweekly or semi-monthly payroll cycles require more work to align hours with the weekly certified payroll format — and more room for errors.
State-specific certified payroll requirements
Federal rules cover federally funded projects. Most states layer additional requirements on top through their own prevailing wage laws — with different forms, portals, thresholds and retention periods. Here’s what construction contractors need to know in the states with the highest compliance complexity.
California
California maintains highly complex certified payroll compliance requirements, mandating that public works contractors file through the California Department of Industrial Relations (DIR) eCPR (Electronic Certified Payroll Reporting) system. Paper and email submissions aren’t accepted on most covered projects. The California Labor Commissioner actively enforces prevailing wage compliance, and record retention is five years.
New York
New York has separate requirements for state projects and New York City contracts. NYC projects use the NYC Certified Payroll Report form administered by the NYC Comptroller’s office — not the standard WH-347. State-funded projects outside NYC may involve both the New York State Department of Labor and, in some circumstances, the State Comptroller. Record retention in New York is six years. Fingercheck supports both the federal WH-347 and the NYC Certified Payroll Report, which matters for contractors working across the five boroughs.
Illinois
The Illinois Department of Labor (IDOL) administers the state’s Prevailing Wage Act independently of federal Davis-Bacon. Contractors on Illinois public works projects must submit their payroll data electronically through the IDOL Certified Transcript of Payroll portal rather than using the federal WH-347. Prevailing wage rates are set by county and updated annually. Illinois enforcement includes mandatory posting requirements and escalating penalties for repeat violations.
New Jersey
New Jersey requires contractors to register under the Public Works Contractor Registration Act before starting any public project. Certified payroll is filed with the NJ Division of Wage and Hour Compliance using state-specific forms. New Jersey’s prevailing wage rates are among the higher rates in the Northeast, making accurate fringe benefit documentation particularly important.
Washington state
Washington’s Prevailing Wage Act is administered by the Department of Labor & Industries (L&I). Rather than weekly WH-347 reports, Washington uses a project-lifecycle approach: contractors file an Intent to Pay Prevailing Wages before work begins and an Affidavit of Wages Paid upon completion through L&I’s online portal. Payroll records must still be maintained for audit.
For construction businesses managing crews across multiple states simultaneously, the variation in forms, portals and deadlines multiplies quickly. Fingercheck’s certified payroll technology supports multi-jurisdiction reporting — the same payroll system that runs your GPS time tracking generates the right form for the right agency.
One platform for every state your crews work in.
From California’s DIR eCPR to the NYC Comptroller’s form, Fingercheck handles multi-jurisdiction certified payroll in a single platform.
Common certified payroll mistakes
Most certified payroll violations aren’t deliberate — they’re process failures. These are the errors that generate audit flags, contract payment holds and back wage liability most often.
1. Misclassifying workers Worker classifications must match the specific trade categories in the DOL wage determination for the project’s county and scope of work — not your internal job titles. If a worker performs tasks under more than one classification in the same week, each classification and its hours must be reported separately at the correct prevailing wage rate.
2. Using outdated prevailing wage rates Wage determinations are project-specific and change over time. Using rates from a previous contract, the wrong county or an expired determination is a common and costly error. Pull the current determination directly from SAM.gov at the start of each new project.
3. Missing weekly submissions A single missing week creates a compliance gap. Some agencies require a “no work performed” filing even for weeks with no activity on the project. Consistent weekly filing — ideally aligned with a weekly payroll schedule — is the simplest way to stay current.
4. Incorrect fringe benefit calculation or reporting Fringe benefits must be listed at their per-hour equivalent, separately from base wages. Baking fringe into the base rate without proper disclosure, or understating the fringe value, is a reportable violation that can trigger back wage liability.
5. Out-of-sequence payroll numbering Each project and contract starts at payroll number “1” and increments by week. Out-of-order numbering — restarting, skipping numbers or duplicating — creates audit flags and makes records harder to trace.
6. Missing or unsigned Statement of Compliance A certified payroll report without a signed Statement of Compliance isn’t, technically, a certified payroll report. No signature means no compliance certification, regardless of how accurate the wage data is.
Certified payroll for subcontractors
Every subcontractor working on a federally funded construction project must file their own certified payroll reports. The obligation applies regardless of the size of your subcontract — if the prime contract is federally funded and you’re performing covered work, you file.
Subcontractors submit reports to the prime contractor, not directly to the contracting agency. The prime contractor compiles all reports and submits the package to the agency. Prime contractors are responsible for ensuring all subcontractor reports are filed — but this doesn’t relieve subcontractors of their individual duty to prepare accurate reports. If a subcontractor’s report is wrong, both parties face exposure.
A note on 1099 workers: Davis-Bacon prevailing wage requirements apply to employees — W-2 workers performing manual labor on covered projects. Independent contractors paid on a 1099 basis aren’t covered by the same provisions. However, worker classification on public works projects is an active area of DOL enforcement scrutiny. If a worker is performing trade work on a covered project under your direction and control, the 1099 designation is unlikely to hold up during a compliance audit. Misclassifying employees as independent contractors is one of the most common and consequential certified payroll violations.
How Fingercheck handles certified payroll
For construction companies managing multiple crews, multiple job sites and weekly government reporting deadlines, certified payroll compliance is a real operational burden — and the margin for error is slim.
Fingercheck handles the full workflow: from the moment a worker punches in on a job site to the completed certified payroll report ready for submission.
Time tracking that feeds directly into payroll
Fingercheck’s GPS-verified time tracking captures hours at the job-site level. Workers punch in via the mobile app, and those hours are immediately tied to the correct job code and cost center. Your data flows cleanly and consistently into your certified payroll reports — no manual reconciliation, no transcription errors between what the timecard says and what the form needs.
Prevailing wage setup at the worker and job-site level
Before a project starts, you configure prevailing wages in Fingercheck for each trade classification and job location. When a worker clocks in on a federal project, Fingercheck automatically applies the correct prevailing wage rate. If that same employee also works on a private project during the same week, the system tracks each set of hours separately and applies the right rate to each — the split-time scenario that trips up manual processes is handled automatically. For a step-by-step walkthrough, see how to set up prevailing wages in Fingercheck.
Certified payroll report generation
From the Reports tab, Fingercheck generates compliant Form WH-347 and NYC Certified Payroll Reports as downloadable PDFs directly from your payroll data. The report is pre-populated from the hours and wage data already in the system, ensuring full consistency between your payroll records and the form you submit. For the full step-by-step process, see the certified payroll reporting guide in the Fingercheck Help Center.
Compliance across jurisdictions
Whether you’re submitting to a federal contracting agency, California’s DIR eCPR system or the NYC Comptroller’s office, Fingercheck supports multi-jurisdiction certified payroll reporting. For construction businesses managing projects in multiple states simultaneously, that means one payroll system handling the reporting requirements rather than a separate process for every agency.
Certified payroll is also one piece of a broader compliance picture. Fingercheck’s labor cost tracking gives you real-time visibility into job-level costs alongside your payroll compliance reporting. And credential management keeps worker certifications, licenses and safety credentials organized in the same place as payroll records — because on a job site, compliance covers more than just the payroll form.
The difference most contractors notice: with a generic payroll platform, certified payroll is an extra step bolted onto your existing process. With Fingercheck, the same system that ran time tracking and payroll generates the certified payroll report from data that was already accurate.
Stop managing certified payroll as a side project
For construction companies on government contracts, certified payroll isn’t optional and it isn’t static — it’s a weekly compliance obligation with real consequences for getting it wrong.
Fingercheck is built for businesses where work happens in the field. GPS-verified time tracking on the job site, prevailing wage configuration at the worker and location level and certified payroll reports generated as compliant WH-347 and NYC Certified Payroll PDFs — all from the same system, from data that was already accurate before the report was run.
If you’re bidding on government construction projects — or already managing them — see how Fingercheck’s payroll and HR solutions for construction handle the full compliance picture: certified payroll, prevailing wage, multi-state payroll, job costing and GPS time tracking in one platform.
Certified payroll, from punch-in to PDF.
GPS time tracking, prevailing wage setup and automated WH-347 generation — built into one payroll platform for construction teams.
Certified Payroll FAQs
This article is for informational purposes only and does not constitute legal or tax advice. Certified payroll requirements vary by project type, jurisdiction and contracting agency. Consult a qualified compliance professional for guidance specific to your situation. Information is current as of June 2026 and is subject to change as laws and regulations are updated.
