How to Fill Out Certified Payroll: WH-347 Form and Compliance

To fill out Certified Payroll Form WH-347, you enter each worker’s identity, trade classification, daily and weekly hours, pay rate and fringe benefits, gross earnings, and deductions on page 1, then sign the Statement of Compliance on page 2 certifying the payroll under penalty of perjury. The form itself is optional. You can submit certified payroll in any format, but WH-347 is what most contracting agencies expect, and using it reduces the odds your submission gets kicked back for missing information.¹ The requirement to file weekly applies to any contractor or subcontractor on a federal or federally assisted construction contract worth more than $2,000.²

What to Have Ready Before You Start

You can’t fill a column you don’t have data for. Before opening the form, pull together the following for every worker who performed covered work that week:

Identity. Full legal name and a unique identifying number, typically the last four digits of the Social Security number. Keep the full SSN and address in your own files; only the abbreviated number goes on the submitted payroll.³
Classification. The exact trade title from the wage determination attached to your contract. This controls the minimum hourly rate, so an error here throws off the pay calculation from the start.⁴
Hours. Daily and weekly totals for each classification, with straight time and overtime separated. Overtime under the Contract Work Hours and Safety Standards Act kicks in after 40 hours in a workweek at one-and-a-half times the basic rate.⁵
Pay rates. The hourly wage rate and any fringe benefit amount, whether paid into a benefit plan or paid as cash.
Deductions. Federal and state income tax, FICA, and any voluntary or court-ordered deductions, each identified separately.

If a worker performed two different classifications in the same week, such as carpentry on Monday and general labor on Tuesday, that worker gets a separate line entry for each classification, but keeps the same identifying number on both lines.

Page 1: The Header

Page 1 is a grid. Start with the contractor or subcontractor name, address, and payroll number. Number your payrolls sequentially starting from the first week of covered work: payroll 1, then 2, then 3, and so on. Sequential numbering shows the agency there are no gaps in reporting. Fill in the project name and number, the contract number, and the week ending date. The week ending date is the last day of the pay period covered by that submission.

Columns 1 Through 3: Who Did What

Column 1 captures each worker’s entry number (starting at 1), name, and identifying number.⁴ Column 2 marks whether the worker is a journeyworker (“J”) or a registered apprentice (“RA”), and for apprentices, the progression level within their approved program.¹ Column 3 lists the work classification. Use the exact title that appears on the wage determination for your contract, not a generic job title.

Apprentices can be paid less than the full journeyworker rate only if they are enrolled in a program registered with the DOL’s Office of Apprenticeship or a state apprenticeship agency. An unregistered apprentice must be paid the full journeyworker rate for whatever classification the work falls under. Registered apprentices are paid the percentage of the journeyworker rate set in their apprenticeship agreement, and the number of apprentices allowed on the project is capped by the ratio in the registered program, checked daily rather than averaged over the week.⁶

Classification is where mistakes cluster. Listing a worker as a “helper” when no helper classification exists on the wage determination, or slotting work under a lower-paid trade than it actually belongs to, are the kinds of errors that turn a routine review into a back-wage investigation.

Columns 4 and 5: Hours Worked

Column 4 breaks hours down by each day of the workweek. Enter straight time and overtime hours separately for each day. Column 5 totals those daily figures into weekly straight time and weekly overtime.⁴ All hours over 40 in a single workweek go in as overtime. That’s the federal floor. If your state law or a collective bargaining agreement triggers overtime earlier, such as daily overtime, you still need to comply with whichever standard is more generous to the worker.

Column 6: Rate of Pay and Fringe Benefits

Column 6 has three sub-fields. Column 6(a) is the basic hourly wage rate. Column 6(b) shows the amounts paid for straight time and overtime. Column 6(c) is the fringe benefit credit, meaning the hourly value of contributions to approved benefit plans that count toward the prevailing wage.⁴

Here’s the math that trips people up. The prevailing wage is the total of the basic hourly rate plus fringe benefits. If the wage determination for electricians is $45.00 per hour with $15.00 in fringes, you can satisfy that by paying $45.00 cash plus $15.00 to benefit plans, or $60.00 all in cash, or any split that adds up to at least $60.00 per hour. Whatever combination you choose, column 6 has to show how the numbers add up.

Columns 7 Through 9: Earnings and Deductions

Column 7 shows the gross amount earned on the specific federal project that week. Column 8 shows the worker’s total gross from all work that week, including any non-federal projects. Column 9 itemizes every deduction: tax withholdings, FICA, and any “other” deductions, which you have to identify by name.⁴ Total deductions subtracted from gross gives you net wages paid.

The “other” column needs attention. Only certain deductions are allowed without prior DOL approval: federal and state taxes, court-ordered payments such as garnishments, and voluntary contributions the worker authorized in writing before the work period began, like retirement savings or union dues.⁷ Anything else — tool purchases charged to the worker, uniform costs, damage deductions — needs written approval from the Secretary of Labor. Taking unauthorized deductions violates the Copeland Act whether the worker agreed to them or not.

Page 2: The Statement of Compliance

Page 2 is the certification that gives the form its legal weight. The person who paid or supervised payment of the workers during that period prints their name, title, and the date, then signs. The signature is a sworn statement that the payroll is complete and accurate, that every worker received at least the applicable prevailing wage, and that no impermissible deductions were taken.¹

The fringe benefit section on page 2 asks you to check one of several options explaining how fringes were handled: paid in cash, contributed to approved plans, or some combination. If you’re claiming credit for contributions to a benefit plan, identify each plan by name and indicate whether it’s funded or unfunded.⁴ Checking the wrong box or leaving this section blank is one of the fastest ways to draw a call from a compliance officer.

The certification is made under penalty of perjury. Knowingly submitting false information is a federal crime carrying fines and up to five years in prison.⁸ DOL investigators regularly cross-reference certified payrolls with on-site worker interviews, so the risk isn’t theoretical.

Submitting the Payroll

You have to submit a certified payroll for every week in which any covered work is performed on the project.⁹ The regulation requires weekly submission but doesn’t fix an exact number of days after the pay date; your contract or contracting agency may impose its own deadline, so check the project’s labor standards requirements. Falling behind is a common reason agencies withhold progress payments.

Some agencies accept paper submissions, while others require electronic filing through platforms like LCPtracker.¹⁰ Confirm the method with your contracting officer before your first submission. Whatever the delivery, the Statement of Compliance has to accompany every payroll. An unsigned or missing certification makes the whole submission incomplete.

For weeks when no covered work is performed, the general rule is that you don’t need to submit a payroll report, provided your payrolls are numbered sequentially so the agency can see there’s no missing week.¹¹ Some agencies deviate and require a “no work performed” report for every inactive week, so check your project-specific requirements. If work will be suspended for an extended period, a written heads-up to the agency prevents confusion when the gap shows up in your payroll numbering.

Records to Keep

Keep all payroll records and supporting documentation for at least three years after all work on the prime contract is completed.⁹ Supporting documentation includes time cards, tax forms, benefit plan contribution records, apprenticeship registration paperwork, and written authorizations for any voluntary deductions. The full Social Security number and last known address, phone number, and email address for each worker must also be retained in your files, even though only the abbreviated number appears on the submitted payroll. These records must be available for inspection by authorized representatives at any time during that period.

Common Errors That Cause Problems

Most rejected or scrutinized WH-347 submissions fail on the same handful of issues. Classification errors, as covered above, are the biggest single source of back-wage findings. After that:

Missing sequential payroll numbers, which make gaps look like unreported weeks.
Fringe benefit math on column 6 that doesn’t add up to the total prevailing wage on the determination.
Unspecified “other” deductions in column 9, or deductions that fall outside the categories allowed without DOL approval.
An incomplete or unsigned page 2, including the fringe-benefit checkbox left blank.
Apprentices listed without a registered program or beyond the allowed ratio.

If you’re a prime contractor, remember that subcontractor payrolls at any tier flow through you, and the prime is ultimately liable for prevailing wage violations by subs it never contracted with directly.¹² Reviewing each sub’s WH-347 before forwarding it to the contracting agency is the cheapest audit protection available. Catching a classification error or missing fringe credit early costs a phone call. Catching it during a DOL investigation costs money and, potentially, withheld contract payments while the issue gets resolved.

1
U.S. Department of Labor. Instructions for Completing Payroll Form WH-347
2
U.S. Department of Labor. Fact Sheet 66 – The Davis-Bacon and Related Acts
3
Acquisition.GOV. FAR 52.222-8 – Payrolls and Basic Records
4
U.S. Department of Labor. How to Correctly Fill Out the WH-347 Form
5
eCFR. 29 CFR 5.8 – Liquidated Damages Under the Contract Work Hours and Safety Standards Act
6
U.S. Department of Labor. Davis-Bacon Compliance Principles
7
eCFR. 29 CFR Part 3 – Contractors and Subcontractors on Public Building or Public Work
8
Office of the Law Revision Counsel. 18 USC 1001 – Statements or Entries Generally
9
eCFR. 29 CFR 5.5 – Contract Provisions and Related Matters
10
U.S. Department of Energy. Weekly DBA Payroll Tracking With LCPtracker
11
Department of Housing and Urban Development (HUD). Handbook 1344.1 REV-3 Chapter 4 – Payroll Reporting Davis-Bacon Compliance Requirements
12
U.S. Department of Labor. Fact Sheet 66C – The DBRA Labor Standards Clauses and Subcontract Agreements