Certified payroll and Form WH-347: how prevailing-wage reporting works for a trade subcontractor
If your HVAC, plumbing or electrical company just picked up a subcontract on a federal building, a HUD-funded housing rehab, a school bond project, or a heat-pump or EV-charger job funded through a federal clean-energy program, you owe a certified payroll every week your crew is on that site, starting with the first week. The form is Form WH-347, and the Department of Labor just redesigned it: the old layout stops being accepted on September 30, 2026, nine days from this page's last check date, and the new one becomes the only valid version. This guide walks through what triggers the requirement, how to read a wage determination, how to fill out the new WH-347 correctly, the fringe benefit math that causes the most audit findings, apprentice ratio rules, and what getting it wrong actually costs.
Deadline on this page's check date. The DOL published a redesigned WH-347 in January 2025 (OMB Control No. 1235-0008, expires 01/31/2028). The prior version remains accepted only through September 30, 2026; on October 1, 2026 the new form — with its restructured Journeyworker/Registered Apprentice column, consolidated fringe benefit detail, and Worker Entry Number scheme — becomes mandatory. If your payroll software, spreadsheet template, or subcontractor's template still produces the old layout, that is the first thing to fix, not a task for next quarter.
Who this is for
Owner-operators and office managers at HVAC, plumbing, electrical, landscaping and pest control businesses who have taken on, or are bidding, work covered by the Davis-Bacon Act or one of the roughly 70 Related Acts: a federal building mechanical contract, a HUD-financed housing rehab, a public school or municipal water project, or a residential energy-efficiency job funded through a federal clean-energy program. It is written for the subcontractor filling out its own weekly payroll, not for a general contractor building an enterprise-wide compliance program across dozens of subs.
It is not a substitute for advice from the contracting officer on your specific contract, and it does not cover everything nearby. Whether a technician belongs on W-2 payroll or a 1099 in the first place is covered in the W-2 vs 1099 field technicians guide — certified payroll assumes that question is already settled, since Davis-Bacon coverage follows the work regardless of how you label the worker. Payroll software that can actually produce the new WH-347 without manual transcription is covered in the Gusto vs Rippling for trade contractors comparison. Whether your dispatcher or office manager is overtime-exempt under the FLSA is a related but separate question, covered in the FLSA overtime exemption audit for trades.
What actually triggers certified payroll
The Davis-Bacon Act itself applies to federal contracts over $2,000 for the construction, alteration or repair of public buildings or public works. The Davis-Bacon and Related Acts (DBRA) extend the same prevailing-wage and reporting obligations to construction work financed, insured or assisted by roughly 70 other federal statutes — meaning the money does not have to come directly from a federal agency for the requirement to attach. For a trade contractor, the projects most likely to trigger it are:
- A direct federal construction, renovation or mechanical contract over $2,000.
- A HUD-financed housing or community-development project (HOME, CDBG, public housing rehab).
- A public school, municipal building or water/wastewater project financed in part with federal-aid highway funds or an EPA State Revolving Fund loan.
- A residential or commercial clean-energy installation — heat pumps, electrical service upgrades, EV charging infrastructure — financed through a federal program that ties eligibility, or a bonus incentive, to Davis-Bacon prevailing wage compliance (see the IRA layer below).
The obligation runs to every tier. If the prime contract is covered, every subcontractor and sub-subcontractor performing construction work on the site owes its own weekly certified payroll for its own laborers and mechanics — the size of the sub or the dollar value of its scope does not create an exemption. The Copeland Act (40 U.S.C. § 3145) is the statute that actually requires the weekly wage statement; DOL's regulations at 29 CFR § 5.5(a)(3)(ii) require it to be submitted to the contracting or administering agency, accompanied by a signed Statement of Compliance.
Reading the wage determination
The prevailing wage on a Davis-Bacon job is not one number. Every wage determination lists two components for each labor classification — a basic hourly rate and a fringe benefit amount — and the two together are the floor for that classification. Pull the active general wage determination for the project's county and construction type (building, residential, heavy or highway) from SAM.gov before you bid; a project that mixes construction types can require more than one determination, and rates that increase after the bid-opening or contract-award date generally do not flow through to a contract already awarded.
If the classification you actually need is not listed on the determination, you cannot self-classify a worker into the closest-sounding category and hope it holds up. The contracting agency has to request a conformance — historically done on Form SF-1444 — and DOL has to approve the new classification and rate before that work proceeds. Skipping this step and paying an invented rate is one of the more common findings on smaller mechanical and electrical subcontracts, where a wage determination written around general building trades sometimes omits a classification the job actually needs.
Craft classification for HVAC, plumbing and electrical work
The wage determination sets the classification, not the contractor and not the worker's trade license. The table below shows the classifications a field-service business most often ends up mapping its crew against, but treat it as a starting point for the conformance conversation, not a lookup table you can rely on without checking the actual determination for your project and locality.
| Field role | Typical wage-determination classification | Notes |
|---|---|---|
| HVAC installer / service tech | Sheet Metal Worker, or Steamfitter/Pipefitter for piping-heavy work | Duct and casing work is usually sheet metal; hydronic and refrigerant piping often falls under pipefitter depending on the area determination. |
| Refrigeration mechanic | Refrigeration Mechanic (where listed) or Steamfitter/Pipefitter | Not every determination lists a stand-alone refrigeration classification; check before assuming one exists. |
| Journeyman plumber | Plumber | Distinct from Pipefitter on most determinations even though the work can overlap on a mechanical room job. |
| Journeyman electrician | Electrician | Low-voltage, controls and fire-alarm work sometimes has its own classification on the determination — verify separately. |
| Helper / general laborer | Laborer | Only for genuinely unskilled work with no tools of the trade. An employee who picks up trade tools and does trade work must be paid the trade rate for those hours. |
If a worker performs more than one classification of work in a week, DOL requires an accurate breakdown of hours by classification on separate payroll rows. If you did not keep that breakdown, the rule defaults against you: the worker must be paid for all hours at the highest applicable rate among the classifications performed.
Filling out the new WH-347, section by section
The instructions below follow DOL's own annotated guide for the redesigned form. Completing WH-347 itself is technically optional — you can use another format — but it has to capture identical information, and in practice almost every contracting agency expects the DOL form or its online fillable version.
- Header fields. Mark whether this is the final payroll for the project, and whether you are the prime or a subcontractor. Enter the project name, project or contract number, your certified payroll number (starting at 1 and incrementing weekly), your business's legal name and address, the project location (full address, or at minimum the county and state), every wage determination number and revision that applies, and the week-ending date.
- Column 1 — worker identification. Each worker gets a Worker Entry Number starting at 1, plus last name, first name, middle initial, and an individual identifying number such as the last four digits of the Social Security number. Full Social Security numbers must never appear on the form.
- Column 2 — Journeyworker or Registered Apprentice. New on the redesigned form. Enter "J" for a journeyworker or "RA" for a registered apprentice, and for an apprentice, list their level of progression in the approved program.
- Column 3 — labor classification. Use the classification and wording exactly as it appears on the wage determination. If a worker performed more than one classification, use a separate row per classification with an accurate hours breakdown.
- Column 4 — daily hours. Label each day of your workweek across the top and log straight-time and overtime hours separately. Any hours over 40 in the week — counting both on-site and off-site hours on the covered contract — count as overtime for Contract Work Hours and Safety Standards Act (CWHSSA) purposes.
- Columns 6A–6C — pay rate, fringe credit, and cash in lieu. 6A is the actual straight-time and overtime rate paid, excluding any cash paid in lieu of fringes. 6B is the fringe benefit credit — total hours this period multiplied by the hourly credit claimed on page 2. 6C is any cash paid directly to the worker instead of a fringe benefit, calculated the same way.
- Columns 7–9 — gross pay, deductions and net pay. 7A is gross pay for this project only; 7B is gross pay for all work that week if the worker also worked off this contract. Deductions must comply with the Copeland Act regulations at 29 CFR Part 3, and anything beyond the standard categories in 29 CFR 3.5 needs prior DOL approval.
- Page 2 — the Statement of Compliance. Six certification boxes. Boxes 1, 2, 3 and 6 must always be checked. Box 4 (apprentices) is required if any worker was paid an apprentice rate this period, and must name each registered program and confirm registration with DOL's Office of Apprenticeship or a State Apprenticeship Agency. Box 5 (fringe benefit credit) requires the plan name, type, plan number, funded/unfunded status, and hourly credit per worker if you are not simply paying cash in lieu.
- Signature. The certifying official signs, dates, and provides phone and email. The certification is made under penalty of perjury under 18 U.S.C. § 1001 — a fine, up to five years' imprisonment, or both for a knowingly false statement. Photocopied or scanned signatures do not satisfy the requirement; a legally valid electronic signature does.
Submit even in a week with no covered work. A "no-work" payroll for that week keeps the submission chain unbroken and heads off the assumption an investigator or contracting officer might otherwise make from a gap in the record.
Fringe benefits and the annualization rule
Under 29 CFR Part 5, Subpart B, a contractor can satisfy the fringe portion of the prevailing wage three ways: pay it in cash on every paycheck, contribute to a bona fide fringe benefit plan (health insurance, pension, life insurance, vacation, holiday pay, an apprenticeship training fund), or split the obligation between cash and a plan.
The rule that causes the most trouble is annualization. You cannot simply divide a monthly premium by monthly hours on the covered project. You divide the plan's annual cost — or reasonably anticipated annual cost — by the worker's total annual hours across all jobs, covered and non-covered alike, to get the hourly credit you can claim against the required fringe rate:
FringeCredit_hr = C_annual / H_annual_total
CashShortfall_hr = max(0, F_required_hr − FringeCredit_hr)
- C_annual
- Employer's annual contribution to, or reasonably anticipated annual cost of, the bona fide fringe benefit plan for that worker.
- H_annual_total
- The worker's total annual hours across all work, not just hours on this Davis-Bacon project.
- F_required_hr
- The fringe benefit rate for the worker's classification on the applicable wage determination.
A concrete example: a $500-per-month health plan for a technician who logs 2,000 hours a year credits at $3.00 an hour — not the $3.13 you would get from dividing $500 by a 160-hour month. If the wage determination requires $6.50 an hour in fringe and your plan only credits $3.00, you owe the $3.50 difference in cash on every hour the worker spends on the covered project, not on all their hours generally.
There is one useful carve-out: a defined-contribution pension plan is exempt from annualization if it provides for immediate participation and essentially immediate vesting, within the worker's first 500 hours. That lets a contractor credit the full contribution against covered hours without spreading it across a worker's non-covered time — worth discussing with your plan administrator if your workforce splits time between federal and private jobs. If you are instead claiming a credit for a benefit you fund directly rather than through a third-party plan (an "unfunded plan"), you need prior written approval from DOL under 29 CFR 5.28 before claiming that credit on any payroll.
Fringe credit calculator
This estimates the annualized hourly fringe credit and any cash shortfall for one worker on one plan. It does not model the defined-contribution pension carve-out described above — if that applies to your plan, talk to your plan administrator about crediting against covered hours only rather than annual hours. Nothing you enter leaves your browser, and this is an estimate for planning purposes, not a substitute for your plan documents or a WHD compliance review.
Credited fringe rate: —
Cash shortfall owed: — on every covered hour
Estimated annual shortfall on this project: —
Apprentice-to-journeyworker ratios
An apprentice can be paid a percentage of the journeyworker rate, but only if two things are both true: the apprentice is individually registered in a bona fide apprenticeship program registered with DOL's Office of Apprenticeship or a recognized State Apprenticeship Agency, and the on-site ratio of apprentices to journeyworkers does not exceed the ratio in the program standards or in the applicable wage determination, whichever is lower (29 CFR 5.5(a)(4)(i)). Anyone carried on the payroll at an apprentice rate who does not meet both conditions must be paid the full rate for the classification of work actually performed.
The detail that catches contractors off guard: ratio compliance is measured daily on the job site, not as a weekly average across the crew. If three journeyworkers leave a job at noon and an apprentice keeps working alone into the afternoon, the afternoon hours can exceed the allowed ratio even though the morning crew was fully in ratio — and the over-ratio hours have to be paid at the journeyworker rate. This is consistently one of the most common findings in Davis-Bacon audits, typically caught by comparing time-card punch times against the daily roster rather than a weekly summary. Trade-by-trade ratios vary by locality and program: electrical programs commonly run one apprentice per one to three journeyworkers, plumbing one per two to three, and HVAC programs anywhere from one-to-one up to one apprentice per four journeyworkers. Pull the actual ratio from the registered program's standards before building the crew roster, not after.
Weekly reporting and the Statement of Compliance
Certified payroll is due weekly, for every week a covered contractor or subcontractor has laborers or mechanics on the site, for the life of the project. The requirement comes from two overlapping sources: the Copeland Act's requirement to "furnish weekly a statement with respect to the wages paid each employee," and DOL's regulation at 29 CFR 5.5(a)(3)(ii) directing that the certified payroll be submitted to the contracting or administering agency.
The Statement of Compliance on page 2 is where personal liability attaches. The signing official — typically an owner, office manager, or whoever supervised payroll for that week — certifies under penalty of perjury that every laborer and mechanic was paid at least the required Davis-Bacon rate including fringes, that no rebates or kickbacks were collected from any worker's wages, and that any apprentices on the payroll were properly registered. A false certification carries exposure under 18 U.S.C. § 1001 independent of any wage-and-hour penalty.
State-level ("mini-Davis-Bacon") coordination
A project funded partly with state money and partly with federal money is not a one-form problem. At least eight states plus the District of Columbia run their own prevailing-wage laws on state-funded public works — California, Connecticut, Hawaii, Illinois, Massachusetts, New Jersey, New York and Washington are commonly cited as running the strictest versions — and where both federal and state rates apply to the same classification, the contractor pays whichever is higher. Some of these states also require a separate state-specific certified payroll submission on top of the federal WH-347: California requires uploads through the Department of Industrial Relations' own system, and New York requires its own Form PW-3 alongside the federal form. Treat any project with mixed state and federal funding as a two-track compliance obligation from the day you sign the subcontract, not something to reconcile after the first payroll is due.
The IRA layer for clean-energy trade work
This is the part of certified payroll most likely to surprise an HVAC or electrical contractor who has never touched a federal building contract. The Inflation Reduction Act ties a five-times bonus multiplier on several clean-energy tax credits and deductions — covering categories that include heat pump and other qualifying equipment installations, EV charging infrastructure, and larger renewable-energy and efficiency projects — to satisfying Davis-Bacon prevailing wage and apprenticeship requirements. Treasury and the IRS adopted DOL's prevailing wage framework for this purpose and layered their own tax-specific rules on top, including:
- Prevailing wage applies for the full recapture window on the underlying credit — up to ten years for some production credits and five years for some investment credits — so a wage shortfall discovered years after the installation can claw back the multiplier retroactively.
- An apprenticeship labor-hours test requires registered apprentices to perform a minimum percentage of total labor hours on the project, on top of the daily on-site ratio rule described above.
- A good-faith exception exists if you requested apprentices from a registered program and the program denied the request or did not respond within a set window.
- Underpayments can be cured with a correction payment — the wage shortfall plus interest, plus a per-worker penalty to the IRS — to preserve the bonus multiplier rather than losing it outright.
If your company is bidding heat pump, panel-upgrade or EV-charger work through a program that advertises the enhanced credit, confirm with the developer or general contractor up front whether Davis-Bacon compliance is a condition of that specific job — the IRA rules layer certified payroll and apprenticeship documentation onto jobs that otherwise look like ordinary residential or light-commercial work.
What a violation actually costs
Three separate exposures stack on top of each other, and they are not interchangeable:
| Exposure | Citation | What it looks like |
|---|---|---|
| Backwages | Underlying Davis-Bacon or Related Act | The difference between what was paid and the required prevailing rate (including fringes), owed to the affected workers directly. No statutory cap — it scales with the number of workers and weeks affected. |
| CWHSSA liquidated damages | 40 U.S.C. § 3702(c); 29 CFR 5.8(a) | A per-day, per-affected-worker penalty for failing to pay time-and-a-half on hours over 40. Currently $33 per violation as of the 2026 penalty table — a modest per-day figure, but it accrues across every affected worker and every day of the violation. |
| Debarment | 29 CFR 5.12 | Up to three years' ineligibility for any federal or federally assisted contract, for the firm, its responsible officers, and any related entity in which they have an interest — triggered by falsified certified payrolls, kickbacks, repeat or serious violations, or willful misclassification. |
The debarment exposure is the one that actually ends a small subcontractor's access to this line of work, and it is explicitly triggered by conduct like a falsified Statement of Compliance or a pattern of misclassification, not just an honest wage-determination reading error. Practically, that argues for keeping four things in order from the start of any covered job: the wage determination and its modification number, time cards that support the classification breakdown on the payroll, fringe benefit plan documents that support every credit claimed, and apprenticeship registration paperwork for every worker paid below the journeyworker rate.
Methodology and sources
This page draws primarily on the Department of Labor's own WH-347 form, annotated instructions, and published civil penalty table, cross-checked against independent secondary reporting on the January 2025 form redesign and its October 1, 2026 mandatory-use date. Figures were checked on .
| Source | Used for | Type | Checked |
|---|---|---|---|
| DOL: Instructions for Completing Form WH-347 | Column-by-column walkthrough, Statement of Compliance requirements, current OMB expiration (01/31/2028) | Primary | September 21, 2026 |
| DOL: Civil Money Penalty Inflation Adjustments | Current CWHSSA liquidated-damages amount ($33/violation), confirmation that 2026 penalties are unchanged from 2025 | Primary | September 21, 2026 |
| Federal Register, 91 FR 31358 (May 27, 2026) | Reason 2026 penalty amounts were not adjusted for inflation (missing October 2025 CPI-U data) | Primary | September 21, 2026 |
| 29 CFR § 5.12 (debarment) | Three-year debarment standard and triggering conduct | Primary (regulation text) | September 21, 2026 |
| DOL Prevailing Wage Seminar slides, "Laborers and Mechanics" / apprenticeship ratio sessions | 29 CFR 5.5(a)(4)(i) apprentice ratio text and daily-measurement standard | Primary (agency training material) | September 21, 2026 |
| Independent secondary reporting on the January 2025 WH-347 redesign (two unaffiliated sources: an HR-compliance vendor blog and a certified-payroll software vendor FAQ) | Confirmation that the old form is accepted only through September 30, 2026 and the new form becomes mandatory October 1, 2026 | Secondary, cross-checked across two sources | September 21, 2026 |
| Secondary compliance-guide summary of the fringe annualization rule, the DC-pension carve-out, apprentice ratio ranges by trade, and the IRA prevailing-wage layer | Worked explanation of annualization, typical trade apprentice ratios, and the IRA five-times multiplier mechanics | Secondary | September 21, 2026 |
What we could not fully verify
- The $13,500-range civil penalty figure some vendor blogs cite for Davis-Bacon violations. DOL's own current penalty table lists the CWHSSA per-violation liquidated-damages amount at $33, not a four-figure sum. We use the DOL primary figure and flag the discrepancy rather than reproduce an unverified number.
- Exact apprentice-to-journeyworker ratios by trade and locality. These vary by registered program and by the wage determination's own ratio language; the ranges given here are illustrative, not a substitute for pulling the actual program standard.
- SF-1444 as the current conformance-request form name and process. Multiple secondary sources describe this process consistently, but we did not locate a current primary-source DOL page confirming the form number is still in active use versus a successor process.
- Whether the 2024 federal court injunction affecting truck-driver and material-supplier coverage under the 2023 final rule has since been resolved. As of this check it remained unresolved in the sources we reviewed; confirm current status before relying on the pre-2023 truck-driver standard.
Where a primary source and a secondary source conflict, the primary source wins. If you find an error, tell us through the about page and we will re-verify.
Frequently asked questions
Does certified payroll apply to a small HVAC, plumbing or electrical subcontractor, or only to big general contractors?
It applies at every tier. If the prime contract is covered by the Davis-Bacon Act or a Related Act, every subcontractor and sub-subcontractor performing construction work on the site owes a weekly certified payroll for its own laborers and mechanics, regardless of the size of the sub or the dollar value of its portion of the job.
Do I still have to submit a certified payroll for a week when no one worked on the project?
Best practice is yes. A "no-work" payroll for that week keeps the weekly submission chain unbroken. Contracting agencies and prime contractors commonly require it, and a gap in the record is one of the first things a Wage and Hour Division investigator will ask about.
Can I keep using the old WH-347 form?
Only until September 30, 2026. The Department of Labor released a redesigned WH-347 in January 2025, and after that date the old layout is no longer accepted; the new version becomes the only valid form for federal certified payroll reporting. If your payroll system or spreadsheet template has not been updated, that is the first thing to fix.
What happens if I pay a technician on 1099 instead of putting them on certified payroll?
The Davis-Bacon obligation follows the work, not the pay type. A worker performing laborer or mechanic duties on the site is covered regardless of how you classify them for tax purposes, and paying them as a 1099 subcontractor does not remove the prevailing wage or certified payroll requirement. Genuinely independent specialty subcontractors still owe their own certified payroll for their own crew.
How is the apprentice-to-journeyworker ratio actually measured?
On a daily basis, on the job site, not as a weekly average across the workforce. If your journeyworkers leave at noon and an apprentice keeps working alone into the afternoon, the ratio for those afternoon hours can exceed what the registered program allows, and DOL's position is that the over-ratio hours must be paid at the full journeyworker rate even though the same crew was in ratio that morning.
Does installing heat pumps or EV chargers under an Inflation Reduction Act program trigger the same paperwork as a federal building contract?
It can. The IRA ties a five-times bonus credit multiplier on several clean-energy tax credits to satisfying Davis-Bacon prevailing wage and apprenticeship requirements, so a residential-facing job funded through certain federal clean-energy programs can carry the same wage-determination, fringe and apprenticeship-ratio obligations as a public building project, layered with Treasury's own recordkeeping and correction rules.