February 26, 2026
The Department of Labor released a revised WH-347 certified payroll form in January
2025. For general contractors managing federally funded projects, these changes
directly impact how compliance is documented, how subcontractor payrolls are tracked,
and how projects are closed out.
2025. For general contractors managing federally funded projects, these changes
directly impact how compliance is documented, how subcontractor payrolls are tracked,
and how projects are closed out.
Here's what's different and what it means for daily operations.
New Fringe Benefit Transparency Requirements
The revised form introduces two new fields in the wage section that require contractorsto break down exactly how fringe benefits are being paid:
Total Fringe Benefit Credit (Column 6B): This captures the total contributions to bona
fide fringe benefit plans, funds, or programs. According to the DOL's instructions, this
amount should equal the worker's total hours worked multiplied by the hourly credit
claimed for fringe benefits. This total is also listed on page 2 of the form under "Hourly
Credit for Fringe Benefits."
Payment in Lieu of Fringe Benefits (Column 6C): Cash payments made directly to
workers instead of funding benefit plans. This field makes it immediately clear whether a
contractor is paying fringes through plans or as cash equivalents.
Why it matters: This level of detail eliminates ambiguity around how fringe obligations
are being met. GCs reviewing subcontractor payrolls can now verify at a glance whether
subs are contributing to actual benefit programs or simply paying cash in lieu. It also
means subs need to be tracking this data accurately from the start. If these
requirements haven't already been communicated to subcontractors, now is the time.
Apprenticeship Documentation Requirements
The updated form puts apprenticeship compliance front and center with severalstructural changes:
Column 2 now requires explicit identification of whether a worker is a
Journeyworker ("J") or a Registered Apprentice ("RA"). For apprentices, the form also
requires listing their level of progression within the approved program.
The Statement of Compliance on Page 2 now includes a dedicated section for
apprenticeship program details. Contractors must list each program name for registered apprentices working on the project and indicate whether the program is registered with
apprenticeship program details. Contractors must list each program name for registered apprentices working on the project and indicate whether the program is registered with
DOL's Office of Apprenticeship or a State Apprenticeship Agency.
Why it matters: Apprentice ratios and proper registration are common audit triggers.
The new form structure makes it harder to overlook or fudge apprenticeship
documentation. For projects using apprentices, registration paperwork must be current
and progression levels accurately documented. The DOL instructions are clear:
apprentices must be "currently under an approved apprenticeship program by either the
State Apprenticeship Agency or the DOL."
The Final Payroll Checkbox and Project Closeout
The revised form includes a checkbox at the top of Page 1 to indicate "Submission of
Final DBRA Certified Payroll Form." This isn't just a formatting change; it's an explicit
acknowledgment that work on the project is complete.
Final DBRA Certified Payroll Form." This isn't just a formatting change; it's an explicit
acknowledgment that work on the project is complete.
Why it matters: Marking a payroll as final has implications for project closeout and final
payment release. It signals to the contracting agency that no additional payroll
submissions are forthcoming from that contractor or sub. For GCs, this means
coordinating with subs to ensure their final payrolls are submitted and marked correctly
before the GC submits their own final payroll. A missing or incorrectly marked final
payroll can delay closeout and hold up retainage.
The Wage Determination Number Field
The header section now requires entry of the Wage Determination Number applicable tothe project. This was always implicit in compliance, but now it's explicitly documented on
every payroll.
Why it matters: This creates an immediate paper trail linking each payroll to the
specific wage determination in effect. GCs can quickly verify that subs are using the
correct wage determination rather than an outdated one. It also eliminates the "we didn't
know" excuse. If a sub submits a payroll with the wage determination number on it,
they're affirming they know exactly which rates apply.
Recordkeeping Requirements
While not a change to the form itself, the Davis-Bacon regulations require that payrollsand basic records be preserved for at least three years after project completion. The
DOL's instructions reference 29 CFR Parts 3 and 5, which govern certified payroll
requirements and recordkeeping standards.
Why it matters: Three years is a long time for potential audits or back-wage claims to
surface. Document retention policies should align with this requirement, and
subcontractor payrolls should be collected and stored in a way that makes them
retrievable. The enhanced detail on the new form, including fringe breakdowns and apprenticeship documentation, means there's more to retain and more that could be
surface. Document retention policies should align with this requirement, and
subcontractor payrolls should be collected and stored in a way that makes them
retrievable. The enhanced detail on the new form, including fringe breakdowns and apprenticeship documentation, means there's more to retain and more that could be
scrutinized.
What Got Removed
The Number of Withholding Exemptions column has been eliminated from the new
form. Additionally, the WH-348 (the standalone Statement of Compliance) has been
consolidated into Page 2 of the WH-347, so everything is now on one form.
Transition Timeline
consolidated into Page 2 of the WH-347, so everything is now on one form.
Transition Timeline
The revised form is dated January 2025 and is valid through January 31, 2028. The
previous version of the WH-347, which expires September 30, 2026, can still be used
temporarily. However, the DOL encourages contractors to begin using the updated form
immediately, and some project owners or contracting agencies may require it sooner.
Contractors should check with their project administrator to confirm which version is
expected.
previous version of the WH-347, which expires September 30, 2026, can still be used
temporarily. However, the DOL encourages contractors to begin using the updated form
immediately, and some project owners or contracting agencies may require it sooner.
Contractors should check with their project administrator to confirm which version is
expected.
Stay Ahead with eMars
eMars is one of the only certified payroll providers in the industry offering the capability
to automatically populate and produce the new WH-347 Certified Payroll Form, giving
contractors and subcontractors a faster, easier, and fully compliant way to submit
weekly payrolls under the Davis-Bacon and Related Acts (DBRA).
to automatically populate and produce the new WH-347 Certified Payroll Form, giving
contractors and subcontractors a faster, easier, and fully compliant way to submit
weekly payrolls under the Davis-Bacon and Related Acts (DBRA).
While use of the new Form WH-347 is not required on all projects, some agencies are
beginning to mandate it, making early adoption a major advantage for contractors who
want to stay ahead of compliance updates. All covered contractors and subcontractors
must submit weekly certified payrolls, and the WH-347 provides the standardized fields
needed to document employee wages, work classifications, and fringe benefits. It also
includes the mandatory Statement of Compliance, ensuring that workers were paid
correctly.
beginning to mandate it, making early adoption a major advantage for contractors who
want to stay ahead of compliance updates. All covered contractors and subcontractors
must submit weekly certified payrolls, and the WH-347 provides the standardized fields
needed to document employee wages, work classifications, and fringe benefits. It also
includes the mandatory Statement of Compliance, ensuring that workers were paid
correctly.
The Bottom Line
The 2025 WH-347 revision reflects a push for greater transparency and accountability
on federally funded construction projects. For general contractors, that means tighter
documentation requirements and less room for error, both in their own reporting and in
the payrolls collected from subcontractors.
Contactors with solid compliance processes should find adapting to the new form
straightforward. For those who don't, this is a good opportunity to tighten things up
before an audit does it for them.
documentation requirements and less room for error, both in their own reporting and in
the payrolls collected from subcontractors.
Contactors with solid compliance processes should find adapting to the new form
straightforward. For those who don't, this is a good opportunity to tighten things up
before an audit does it for them.
