Guides · Updated July 24, 2026
Certified payroll for construction subs
Certified payroll is the administrative price of prevailing-wage work, and it is the compliance obligation most likely to hold up your money. The rules themselves are short: submit weekly, classify honestly, sign a statement you'd be comfortable defending. The trouble comes from treating it as an afterthought rather than a line in your overhead.
Who has to file, and to whom
Every contractor and subcontractor performing covered work on a federal or federally assisted construction contract has to submit weekly certified payrolls. There is no small-sub exemption: once the prime contract carries Davis-Bacon, coverage flows all the way down, and a two-week scope is covered exactly like a two-year one.
Payrolls go to the federal agency if it's a party to the contract; on federally assisted work they go to the applicant, sponsor, owner, or whichever entity maintains the records for transmission to the agency. In practice, as a sub, you'll submit to your prime — and it's worth knowing why they chase you so hard for them: the prime contractor is responsible for the submission of all certified payrolls, including yours. Your late payroll is their compliance problem, which is why it becomes their payment lever.
If prevailing wages are new to you, start with Davis-Bacon prevailing wages — certified payroll is the reporting half of the obligations described there.
What's on the form
Form WH-347 is the Department of Labor's optional-use form, and when properly completed it satisfies the certified payroll requirements of 29 CFR parts 3 and 5. You can use your own format or your payroll software's output — plenty of contractors do — as long as it captures the same information and the compliance statement uses identical wording.
| Field | The detail that trips people up |
|---|---|
| Worker name and identifying number | Submitted payrolls use an individually identifying number, such as the last four digits of the SSN — not the full number |
| Work classification | Must match a classification on the wage determination; a trade the WD doesn't list requires a conformance request, not a guess |
| Hours worked, by day and total | Split by classification when a worker performs more than one trade in a week |
| Rate of pay and gross earned | The base rate from the determination — the fringe is reported separately, not folded in |
| Fringe benefits | Show whether paid in cash or into bona fide plans; the annualized hourly-equivalent is what counts |
| Deductions and net paid | Only deductions permitted under the Copeland Act anti-kickback rules |
| Statement of Compliance | Signed by the contractor or an officer or employee who supervises the payment of wages |
The weekly clock, and the records behind it
Certified payrolls are due weekly, within seven days after the regular payment date for that payroll period. A payroll week with no covered work still gets reported — file a no-work payroll rather than a gap, because gaps read as missing records during a review.
Behind the submitted payroll sits a larger recordkeeping obligation. You have to maintain the underlying payroll records — including each worker's name, address, and contact information, classification, hourly rates including fringe contributions, daily and weekly hours, deductions, and actual wages paid — and preserve them for three years after all the work on the prime contract is completed. Those records have to be available for inspection, and the contractor has to permit interviews with workers during working hours on the job.
The Statement of Compliance is the part to take seriously. It certifies that the payroll is accurate and complete and that every laborer and mechanic has been paid not less than the applicable prevailing wage including fringes. It has to be executed by you or by an officer or employee who supervises the payment of wages — not by whoever happens to be at the desk.
The findings that actually get written
Investigations rarely turn up dramatic fraud. They turn up the same four ordinary errors, all of which are cheaper to prevent than to remediate:
- Misclassification — paying a journeyman's scope at a helper's or laborer's rate. This is the classic back-wage finding, and it's usually carelessness rather than intent.
- Fringe folded into the base — treating the wage determination's total as the hourly rate instead of paying the base plus the fringe obligation.
- Overtime miscounted — time-and-a-half is owed for hours over 40 in a workweek on contracts over $100,000, measured by the workweek, not the pay period.
- Apprentices without registration — apprentice rates only apply to workers registered in a bona fide apprenticeship program, at the program's permitted ratio.
Build the hour into your overhead
The right way to think about certified payroll is as a known, predictable cost of public work rather than a surprise. One person, a couple of hours a week, doing it the same way every time; payroll software that produces the format your primes accept; a calendar reminder tied to your regular pay date. Shops that do this find it disappears into routine within a month or two.
The shops that struggle are the ones that treat each job's compliance as a fresh improvisation — and then discover that a held progress payment costs far more than the administrative hour would have. Payment and compliance are directly coupled on public work; see getting paid on federal construction for how the money actually moves and what your leverage is when it stops.
This is an orientation to the requirements as of July 2026, not legal advice. Your contract's own clauses control, and the Department of Labor's Wage and Hour Division is the authority on close questions.
Frequently asked questions
- Who has to submit certified payroll?
- Every contractor and subcontractor performing covered work on a federal or federally assisted construction contract subject to Davis-Bacon, regardless of the size of their scope. Subcontractors typically submit to the prime, because the prime contractor is responsible for the submission of all certified payrolls on the job, including its subcontractors'.
- How often is certified payroll due?
- Weekly. Each certified payroll is due within seven days after the regular payment date for that payroll period, and it must be accompanied by a signed Statement of Compliance. Weeks with no covered work should be reported as no-work payrolls rather than skipped, so the record has no gaps.
- Do I have to use Form WH-347?
- No. Form WH-347 is optional — when properly completed it satisfies the certified payroll requirements, but any format carrying the same information is acceptable as long as the Statement of Compliance uses identical wording. Most payroll software can produce a compliant output for the projects you run.
Put this on autopilot.
JobsiteBids watches SAM.gov plus state & local portals across 20+ states, parses every packet, and emails your strong matches at 6 AM — ranked against your trade, service area, and bid size.