WH-347: the federal certified payroll form, line by line

What WH-347 is, and who has to use it

WH-347 is the U.S. Department of Labor's certified payroll form for federally covered construction contracts. It exists because the Davis-Bacon Act (40 U.S.C. §3141 et seq.) requires contractors and subcontractors on covered federal and federally-assisted construction contracts to pay locally prevailing wages, and a related law — the Copeland "Anti-Kickback" Act (40 U.S.C. §3145, implemented at 29 CFR Part 3) — requires them to submit a weekly statement proving it. WH-347, published by DOL and available at dol.gov, is the standard form contractors use to satisfy that requirement, though the regulations at 29 CFR §5.5(a)(3) allow an equivalent format as long as it captures the same information.

When it's required

If a contract is directly with a federal agency for construction, alteration, or repair over the Davis-Bacon threshold, WH-347 is required. It is also required on the much larger population of projects funded or assisted by federal dollars flowing through a state or local agency — highway funds, HUD-assisted housing, many infrastructure grants — under the family of statutes known as the Davis-Bacon Related Acts, which extend the same wage and reporting requirements to that money. On a California public-works job that also carries federal funding, WH-347 is filed in addition to, not instead of, the state's eCPR filing, and the two rarely map perfectly onto each other — see our piece on prevailing wage vs. Davis-Bacon for how the classifications and rates reconcile.

The columns, in order

Reading left to right, WH-347 asks for, per worker, per week. The form is dense on purpose — it is designed so a contracting officer or Wage and Hour investigator can reconstruct exactly what a worker was owed and what they were actually paid without asking a single follow-up question. Each column has to stand on its own; a total that looks right but can't be traced back through the individual fields is treated as unsupported, not as close enough.

• Name and an identifying number (typically the last four digits of a Social Security number, not the full number)
• Work classification — the specific craft the worker actually performed, which drives which wage rate applies
• Hours worked each day of the week, broken into straight time and overtime
• Total hours for the week
• Rate of pay, shown separately for straight time and overtime
• Gross amount earned, including any work on other, non-covered projects that week
• Deductions, itemized or referenced to a standard, previously-approved deduction schedule
• Net wages paid

The Statement of Compliance

Every WH-347 submission is accompanied by a Statement of Compliance — printed on the back of the form or attached separately — signed by the contractor or an authorized officer. It certifies, under the false-statement provisions of 18 U.S.C. §1001, that the payroll is correct and complete, that each worker was paid no less than the applicable Davis-Bacon rate for the classification worked, and states how fringe benefits were paid. An unsigned Statement of Compliance is treated the same as no submission at all: the certified payroll requirement is not just the data on the form, it is the sworn attestation attached to it, and a contracting officer or auditor will flag it before looking at anything else.

Fringe: cash vs. bona fide plans

Under 29 CFR §5.5(a)(1)(iv), a contractor can satisfy the fringe benefit portion of the Davis-Bacon rate two ways: pay it as additional cash wages on top of the basic hourly rate, or contribute it to a bona fide fringe benefit plan — health insurance, pension, an apprenticeship or training fund — on the worker's behalf. WH-347's Statement of Compliance requires the contractor to state which method was used for each worker. Mixing the two without documenting it — paying partial cash and partial plan contributions that don't add up to the required total — is one of the fastest ways to fail a Davis-Bacon audit, because the reviewer has no way to confirm the worker actually received full value either way.

A contractor that runs its own health plan for office staff cannot assume the same plan automatically qualifies for Davis-Bacon fringe credit on a field crew; the plan has to actually cover the worker in question, on terms the worker can enforce, for the contribution to count. When in doubt, paying the fringe difference in cash and itemizing it is the safer default — it is harder to get wrong than a plan-crediting calculation done without the underlying trust documents in hand.

Errors that actually stop a payment

• Missing signature on the Statement of Compliance
• Work classification that doesn't match the actual work performed, or doesn't exist on the applicable wage determination
• Apprentices listed without a valid registration number from a DOL-recognized program, which reclassifies them as laborers owed the full journeyman rate
• Deductions that aren't itemized or don't match an approved schedule
• Math that doesn't reconcile — hours multiplied by rate not matching gross, or gross minus deductions not matching net
• Fringe benefits claimed as paid to a plan with no supporting plan documentation on file

Weekly, without exception

The Copeland Act's implementing regulations require certified payroll to be submitted weekly, generally within a set number of days after the regular pay date for that workweek, for the entire duration of the contract — including weeks with no covered work, which are typically reported as such rather than skipped entirely. Records supporting the payroll have to be retained for a period specified in 29 CFR Part 3 (commonly cited as at least three years after project completion), because a Davis-Bacon audit can reach back well after final payment has cleared. Treat WH-347 as a weekly operating discipline, not a closeout task you assemble once the job is finished.

The practical failure mode is not a contractor who refuses to file — it's a contractor who falls one or two weeks behind during a busy stretch and then tries to reconstruct several weeks of hours, classifications, and deductions from memory and scattered timesheets at once. Reconstructed payroll is where classification drift and math errors concentrate, and it's exactly the pattern an auditor is trained to look for. The form is simple enough to fill out correctly the week the work happens; it gets considerably harder a month later.

This article is educational and does not constitute legal or tax advice. Statutes and agency requirements change; confirm current rules with the California DIR, the U.S. Department of Labor, the IRS, or qualified counsel before relying on them. Aeternus Dynamics is a compliance and advisory firm, not a law or accounting firm.