Certified payroll requirements under the
revised WH-347 come down to what your records can prove. The form asks for
worker identification, work classifications, daily straight-time and overtime
hours, fringe benefit detail at the worker level, itemized deductions, and a
signed certification covering all of it. None of that is new law. What is new
is how much of it now has to be visible on the form itself, which means gaps in
your source data show up at submission rather than at audit.
This article covers the records and fields
payroll teams need to have in hand. For the change log itself, including what
was removed from the form and the transition dates, see our breakdown of what changed on the 2025 WH-347.
The WH-347 Is Optional. The Reporting Requirement Is
Not.
Start here, because it is the most commonly
misunderstood point in certified payroll.
The Department of Labor makes the WH-347
available for the convenience of contractors and subcontractors. Use of the
actual form is optional. What is required is that covered contractors and
subcontractors submit weekly certified payroll information satisfying
Davis-Bacon and Related Acts requirements, accompanied by a signed Statement of
Compliance containing the required information and certification.
That distinction matters in practice. A
contractor using a payroll system that outputs its own format is not out of
compliance for skipping the WH-347. A contractor whose records cannot produce
the underlying information is out of compliance regardless of which form they
use. The form is a container. The requirement is the data.
Worker Identification Requirements
The revised form separates worker
identification into five fields: worker entry number, last name, first name,
middle initial, and worker identifying number.
DOL instructs contractors not to include full
Social Security numbers. A worker-specific identifying number, such as the last
four digits of a Social Security number or another unique identifier assigned
by the employer, may be used instead. If your payroll export still carries full
SSNs into the certified payroll record, that needs to change before submission.
The worker entry number does more work than it
appears to. When an employee performs work in more than one classification
during the same week, that employee occupies multiple rows on the payroll, one
per classification, while keeping the same worker entry number throughout.
Consider a laborer who spends Monday through
Wednesday on general labor and Thursday and Friday operating equipment. That
worker appears twice on the form, at two different classifications and two
different rates, under one entry number. If your timekeeping system records
only a weekly total for that employee, you cannot produce those rows
accurately, and the consequence is covered next.
Work Classification Requirements and the Highest-Rate
Rule
The classification reported must correspond to
the work the employee actually performed. When an employee works across
multiple classifications in a week, hours must be broken down accurately
between them.
Here is the part worth circulating internally.
DOL states that if an accurate breakdown of hours is not maintained, the worker
must be paid using the highest applicable prevailing wage rate for all hours
worked.
Read that as a cost, not a formality. Take the
laborer above. If the equipment operator rate is meaningfully higher than the
general labor rate and the daily split was never recorded, the full week is
owed at the operator rate. The exposure is not a citation for bad paperwork. It
is back wages on hours that were correctly paid at the time, lost because the
records could not demonstrate it.
The question to ask internally is not whether
a classification was entered on the payroll. It is whether the classifications
reflect the work performed, and whether the timekeeping records can prove it.
Hour Requirements: Straight-Time and Overtime, Reported Daily
The revised form directs contractors to report straight-time and overtime hours by day, which is similar to the old form. For contracts subject to the Contract Work Hours and Safety Standards Act, DOL instructs contractors to report hours over 40 in the workweek as overtime, and to count covered hours worked both on and off the site of the covered contract when determining whether the overtime requirement is triggered.
That second point catches contractors who
track only on-site hours. An employee who works 30 hours on the covered project
and 15 hours on other covered work has crossed 40 for the week. If the two are
tracked in separate systems that never reconcile, the overtime calculation on
the certified payroll will be wrong even though each individual record looks
correct.
Fringe Benefit Records You Need at the Worker Level
The revised form distinguishes
employer-provided bona fide fringe benefits from cash paid to the employee in
lieu of fringe benefits, and it splits gross earnings into the amount earned on
the covered project and the amount earned for all work.
When a contractor claims credit for
contributions to bona fide fringe benefit plans, Page 2 requires supporting
detail: the plan name, the plan type, the plan number, whether the plan is
funded or unfunded, the hourly amount of credit claimed for each worker, and
the total hourly fringe benefit credit.
Part of this
redesign traces back to enforcement findings: DOL investigators repeatedly
found contractors taking fringe credit for costs that didn't actually benefit
the worker. For example, administrative fees, contributions to industry
association or marketing funds, or amounts simply labeled "fringe"
without a plan behind them at all. The added detail fields make it harder to
claim credit for anything that isn't a legitimate, worker-directed benefit.
Acceptable bona fide fringes under Davis-Bacon include employer contributions
to health or medical insurance, life and disability insurance, pension or
retirement plans, vacation and holiday pay, and bona fide apprenticeship or
training fund contributions. A bona fide fringe is one that benefits the
employee, not an industry or political fund.
The practical requirement is worker-level
fringe data. A single company-wide contribution total, or an annual figure
divided by headcount, will not support the per-worker hourly credit the form
asks for. If fringe benefits are administered by a third party and reported
back quarterly, the reporting cadence itself becomes a compliance problem.
Deduction Requirements
The revised WH-347 provides fields for tax
withholding, FICA, other deductions, and total deductions.
If "Other" represents a single deduction, DOL instructs contractors to describe it in the Additional Remarks section. If it represents multiple deductions, an addendum should itemize and describe each one. eMars will prepare this addendum for you. It may require several additional pages depending on the number of deductions and employees. DOL also reminds contractors that deductions must comply with Copeland Act regulations, which govern what may permissibly be withheld from a worker's wages on covered projects.
For payroll teams, the takeaway is that a
lumped "other deductions" total no longer carries enough information
to support the record. Union dues, equipment charges, advances, and
garnishments each need to be identifiable, and any deduction that is not
permissible under Copeland does not become permissible by being aggregated.
What the Statement of Compliance Actually Certifies
The Statement of Compliance contains six
certification areas: the accuracy of the payroll, maintenance of required
records, correct work classifications, registered apprentices, fringe benefits,
and payment of full wages without improper deductions or rebates.
Certain certifications must always be checked. The apprentice and fringe benefit sections are completed when applicable.
Apprenticeship reporting carries its own set of requirements on the new form. This section was tightened in part because contractors were reporting workers as apprentices, and paying the reduced apprentice wage rate, without registration in an approved program on file. The form now requires the registration number and the name of the apprenticeship program for each apprentice claimed, so the certification can be tied back to an actual, verifiable registration rather than an unsupported classification.
The signature line deserves more attention
than it usually gets. The certification is subject to the penalties provided
under 18 U.S.C. 1001, the federal false statements statute. The person signing
is personally attesting to records they may not have assembled. If the signer
cannot trace how a number on the form was produced, they are certifying
something they cannot verify.
A Readiness Check Before Your Next Submission
Run your current process against the
requirements above. Can your timekeeping system produce daily hours split by
classification for an employee who worked two classifications in one week? Does
your payroll export carry a worker identifying number rather than a full Social
Security number? Can you separate straight-time from overtime by day, and does
that calculation account for covered hours worked off the site? Do you have
hourly fringe benefit credit at the worker level, and can you name the plan, its
type, its number, and whether it is funded? Are individual deductions
identifiable rather than lumped? And does the person signing understand what
each of the six certifications means?
If any of those answers depend on a
spreadsheet, a manual reconciliation, or one person's recollection, the
requirement was already there. The revised form simply makes the gap visible.
Where Certified Payroll Requirements Break Down
In most cases the failure point is not the
form. It is source data assembled from systems that were never designed to talk
to each other: time tracked in one place, wages calculated in another, fringes
administered by a third party, classifications assigned by a foreman on a paper
sheet.
Certified payroll software reduces the
administrative burden of pulling that together, but it cannot make inaccurate
inputs accurate. At eMars, compliance checks run after certified payrolls are
submitted, identifying issues that need attention and revision before overall
project compliance is finalized. That review step is the part that catches what
a form generator will happily reproduce.
The Bottom Line
The revised WH-347 turned certified payroll
into a disclosure document. Where the old form let a contractor report totals,
the new one asks how those totals were reached, worker by worker and day by
day.
The practical standard is straightforward:
what you cannot document, you cannot certify. Contractors whose records already
answer these questions have a formatting exercise ahead of them. Contractors
whose records do not have a data problem, and the form is where it becomes
apparent.
About eMars
eMars helps contractors manage certified payroll compliance by providing centralized visibility into submitted payrolls and identifying compliance issues that require attention before overall project compliance is finalized. Contact us today to schedule a demo.
