Davis-Bacon certified payroll weekly submission

First confirm Davis-Bacon coverage

Certified payroll is required on covered federal and federally assisted construction work subject to the Davis-Bacon and Related Acts (DBRA) labor standards. The contract and applicable wage determination identify covered work and required classifications. Do not assume every public job is covered or that every worker at the site has the same classification. The contracting agency determines coverage and includes the required labor clauses and wage determination in covered contracts.

Once a project is covered, the contractor and subcontractors report work and wages for laborers and mechanics performing covered work. The requirement tracks the actual workweek, classification, hours, deductions, and wages paid. It is separate from an ordinary invoice, pay application, or schedule of values. A contractor should establish payroll procedures at mobilization and flow the requirement down to every covered subcontractor.

Weekly submission and timing

The standard contract clause requires certified payrolls weekly for each week in which covered work is performed. DOL guidance describes delivery within seven days after the regular payment date for the payroll period. Keep the payment date, workweek ending date, and submission date distinct in the payroll calendar; the deadline is tied to the regular payday, not simply seven days from the final day on site. Confirm any agency-specific electronic submission system and contract instructions.

The prime contractor is responsible for the submission of certified payrolls by its subcontractors. A missing lower-tier payroll is not solved by a prime contractor submitting its own records alone. Track every subcontractor’s first covered workweek, expected payday, and submission status. Escalate late or incomplete forms early enough to correct them, and retain an audit trail of corrections and communications.

What the payroll records

The weekly report records the worker identifier, labor classification, daily and weekly hours, hourly wage rates, fringe benefits or cash equivalents, deductions, and actual wages paid. The applicable wage determination supplies the required rate for each classification. If a worker performs multiple classifications during the week, report the hours and pay under each as required rather than assigning the entire week to a single title. Keep underlying time records and payroll calculations that support the report.

Weekly transmittals must not include full Social Security numbers or certain personal contact details. The regulation allows an individually identifying number, such as the last four digits, in the payroll submission. Protect worker information in both paper and electronic files. The contracting agency, prime contractor, or electronic portal may have separate instructions for secure transfer and record access; do not email unprotected personal data unless the approved system requires and protects it.

WH-347 is optional, certification is not

The Department of Labor’s Form WH-347 is an optional format for submitting certified payroll. A contractor may use another format if it includes all required information. Each weekly payroll must be accompanied by a signed Statement of Compliance, such as the statement on page two of WH-347 or another document with identical wording. The signer certifies the information is accurate and complete and that covered workers received at least the required wages and fringe benefits.

The certifying official should have direct knowledge of the payroll period or supervise payment of the workers. Do not sign a blank or incomplete certification, or treat the form as a routine cover sheet. If a correction is needed, amend the payroll and preserve the corrected version and explanation. The signature represents an assertion about payment and records; the person signing should be able to support it with source data.

Example: subcontractor performs one covered week

An electrical subcontractor works on a covered federal project for one week, then leaves the site. It still submits a certified payroll for that week, even if it has no covered hours in a later week. The payroll reflects each employee’s classification, daily hours, base wages, fringe benefits, deductions, and total pay. The subcontractor submits by the applicable deadline with a signed Statement of Compliance, and the prime contractor confirms receipt and inclusion in the project file.

If a worker split time between electrician and laborer duties, the payroll should reflect the proper hours and wage determination for each classification. If the actual wage paid falls short, the contractor needs to correct the payment and report the correction under agency procedures. A generic job title or lump-sum weekly salary does not remove the obligation to document hours, classification, and required prevailing wage treatment.

Common errors and exam cues

Common errors include assuming WH-347 is mandatory, missing a week with only a small amount of covered work, omitting the Statement of Compliance, using a classification that does not match the work, and disclosing full Social Security numbers in weekly transmittals. Another is assuming the prime has no responsibility for subcontractor submissions. The prime must ensure all lower-tier payrolls are submitted under the standard clause.

For exam questions, recall coverage first, weekly submission second, and the seven-day timing from the regular payment date. Then distinguish required data from the optional form: the form is optional, but required payroll information and a signed compliance statement are not. Follow current contract clauses, DOL requirements, and the agency’s electronic system.

Quick review

• Submit for every workweek in which DBRA-covered work is performed.
• Submit within the applicable period—generally seven days after the regular payroll payment date.
• WH-347 is optional; required content and a signed Statement of Compliance remain mandatory.
• Use the wage determination’s classifications and rates; report hours and pay accurately.
• The prime contractor is responsible for obtaining subcontractor certified payrolls; protect worker personal information.