# Certified Payroll (WH-347)

> The weekly, certified record proving that workers on a covered public project were paid at least the required prevailing wage and fringe — a legal compliance filing, not just a payroll report.

- Source: https://briq.ai/acu/object/certified-payroll
- Department: Contracts, Compliance & Risk (https://briq.ai/acu/department/contracts)
- Catalog code: CON 301 · Level: Advanced · Track: Finance · 12 min read
- Also known as: CPR, WH-347, Certified Payroll Report, Prevailing Wage Report, Davis-Bacon Payroll

## Definition

Certified payroll is a weekly payroll record that a contractor on a prevailing-wage public project submits, under a signed statement of compliance, to prove that every worker was paid at least the applicable prevailing wage and fringe benefit rate for the classification of work they performed. On federal and federally assisted projects it is required by the Davis-Bacon and Related Acts and is most commonly filed on federal Form WH-347, which pairs the payroll data with a statement of compliance signed under penalty of perjury. State and local prevailing-wage laws impose parallel requirements, sometimes on their own forms and portals. Certified payroll is not an ordinary payroll register — it is a legal certification, and a false or materially inaccurate one can trigger withholding of contract payments, debarment from public work, and civil or criminal liability, which is why its accuracy carries far heavier consequences than a routine payroll report.

## Why it matters

Certified payroll is the proof that prevailing-wage law was actually obeyed, and payment on the project is conditioned on it. Contracting agencies withhold contract funds when certified payrolls are missing, late, or deficient, so a payroll problem becomes a cash-flow problem immediately. The report is not paperwork filed after the fact; it is a gate that must clear each week for money to keep moving.

The certification exposes the signer to serious legal liability, which is what distinguishes it from ordinary payroll. The statement of compliance is signed under penalty of perjury, and knowingly submitting a false certified payroll — misclassifying workers to a lower wage rate, underreporting hours, or overstating fringe credits — can lead to withheld payments, restitution to underpaid workers, liquidated damages, debarment from federal contracting, and False Claims Act exposure. The stakes make accuracy a compliance obligation, not a clerical preference.

Correct worker classification is the crux, and it is where most violations originate. Each hour must be reported under the labor classification that matches the work actually performed, at that classification's prevailing rate, and workers who split time across classifications must be split-reported. Misclassifying a journeyman as a laborer, or ignoring the higher rate that applies when a worker crosses trades, is the classic underpayment that certified payroll is designed to expose.

It protects workers and levels the bidding field. Prevailing-wage requirements exist so that public spending does not depress local construction wages and so that contractors compete on efficiency rather than on who can pay the least. Certified payroll is the enforcement mechanism behind that policy: it makes underpayment visible and gives underpaid workers and enforcement agencies a documented basis to recover what is owed.

## Lifecycle

1. **Wage determination incorporated** — The applicable prevailing-wage determination — the schedule of rates by classification for the project's locality — is incorporated into the contract at award. Every reported rate must trace back to it, so the correct, current determination must be identified first.
2. **Worker classification setup** — Each worker's labor classification is established based on the work they will actually perform, mapped to the wage determination's classifications and rates. Misalignment here propagates into every weekly report.
3. **Time capture by classification** — Hours are captured daily by classification, including split time when a worker performs multiple classifications, and overtime. Vague or classification-blind timekeeping is the root cause of most certified-payroll errors.
4. **Payroll processing with fringe treatment** — Gross pay is computed at the prevailing rate, and fringe benefits are either paid in cash or provided as bona fide benefits, with the fringe credit documented. Whether fringes are paid in cash or as benefits changes the reporting and the math.
5. **Report preparation** — The weekly WH-347 (or state equivalent) is prepared: each worker, classification, hours, rates, gross, deductions, net, and the fringe treatment. The data must reconcile to the actual paychecks issued.
6. **Certification and signature** — An authorized officer signs the statement of compliance under penalty of perjury, attesting that workers were paid correctly and that no unlawful deductions or kickbacks occurred. This signature is the legal core of the document.
7. **Submission and lower-tier collection** — The report is submitted to the agency or general contractor, often through a specific portal, on the required weekly schedule. The GC must also collect and verify subcontractors' certified payrolls, because it is responsible for the whole project's compliance.
8. **Review, correction, and retention** — The agency or GC reviews for classification, rate, and math errors and may require corrected reports. Records are retained for the statutory period (three years under Davis-Bacon) because audits and investigations can arrive long after completion.

## Anatomy

- **Contractor/subcontractor identity and tier** — Who prepared the payroll and its position in the chain. The GC must collect and reconcile every lower tier's reports, not just its own.
- **Project and contract identification** — The covered project and contract number tying the payroll to the wage determination that governs it. Wrong project linkage means wrong rates.
- **Payroll number and week ending** — The sequential weekly number and period. Gaps in the sequence signal missing weeks that agencies will withhold payment over.
- **Worker name and identifier** — Each covered worker, identified per current rules (which limit full SSNs on the form). Owner-operators and working supervisors have special treatment.
- **Labor classification** — The classification for the work performed, matched to the wage determination. The most error-prone and most consequential field on the report.
- **Hours worked by day** — Daily straight-time and overtime hours, by classification when split. Overtime rules (including the Contract Work Hours and Safety Standards Act) apply on covered work.
- **Rate of pay** — The base hourly rate paid, which must meet or exceed the wage determination for the classification. The number auditors check first.
- **Fringe benefits** — Whether fringes are paid in cash or as bona fide benefits, and the documented value. Overstated or undocumented fringe credits are a common violation.
- **Gross, deductions, and net pay** — Total earnings, itemized deductions, and net. Unexplained or unauthorized deductions can indicate an illegal kickback in violation of the Copeland Act.
- **Apprentice/trainee status and ratios** — Registered apprentices may be paid a percentage of the journeyman rate, but only within registered-program ratios. Unregistered apprentices must be paid full rate.
- **Statement of compliance** — The signed, penalty-of-perjury certification of correct payment and lawful deductions. The legal heart of the entire filing.
- **Signatory and authority** — The authorized officer who signs. Signing without authority, or without verifying the data, is a serious and personal exposure.

## Failure modes

- **Worker misclassification** — Hours are reported under a lower-paid classification than the work performed, whether by error or to cut cost. It is the central prevailing-wage violation, and it produces back-wage restitution, penalties, and — if knowing — debarment and False Claims Act exposure.
- **Ignored split-classification work** — A worker who performs two classifications in a week is reported entirely at the lower rate rather than split by hours. The higher-rate hours are underpaid, and the report is materially inaccurate even if every other field is right.
- **Overstated or undocumented fringe credit** — The contractor claims a fringe-benefit credit larger than the bona fide benefits actually provided, or cannot document them. The effective wage falls below the determination, and the fringe overstatement is a frequent audit finding.
- **Missing or late weekly reports** — A week's certified payroll is skipped or filed late, breaking the sequence. The agency withholds contract payment until the gap is cured, turning a paperwork lapse into an immediate cash squeeze.
- **Unregistered apprentices paid apprentice rates** — Workers are paid reduced apprentice rates without being enrolled in a bona fide registered apprenticeship program or beyond allowed ratios. Those workers are owed the full journeyman rate, and the shortfall is a violation.
- **GC not reconciling lower-tier payrolls** — The general contractor collects subcontractor certified payrolls but never verifies them against the wage determination or the workers actually on-site. The GC remains responsible for the whole project's compliance and inherits every sub's underpayment.
- **Certification signed without verification** — An officer signs the statement of compliance without actually confirming the classifications, rates, and fringe treatment are correct. The penalty-of-perjury signature is now attached to data no one validated, which is exactly the exposure the certification is meant to prevent.

## Metrics

- **On-time submission rate** — Share of weekly certified payrolls filed by the deadline. Directly tied to whether contract payments are withheld.
- **Classification accuracy rate** — Share of worker-hours reported under the correct classification for the work performed. The core compliance-quality metric.
- **Rate-compliance rate** — Share of reported rates meeting or exceeding the applicable wage determination. Any shortfall is a potential back-wage liability.
- **Fringe-documentation completeness** — Share of claimed fringe credits backed by documented bona fide benefits. Measures exposure on the most-audited element.
- **Correction/rejection rate** — Share of reports returned by the agency or GC for correction. High rates signal upstream timekeeping and classification problems.
- **Lower-tier collection and reconciliation rate** — Share of subcontractor payrolls collected and actually reconciled by the GC. Measures whether project-wide compliance is real or nominal.
- **Restitution and penalty exposure** — Cumulative computed underpayment plus potential penalties on open findings. Converts compliance quality into a dollar risk figure.

## The AI shift

- **Conversational** — You can interrogate the payroll record against the wage determination: which workers were paid below the required rate for their reported classification, which weeks are missing from the sequence, which fringe credits lack documentation, and which subcontractors' reports have not been reconciled — with the specific worker, week, and rate cited.
- **Generative** — The WH-347 and its statement of compliance are drafted from the underlying time and payroll data, with classifications mapped to the wage determination, split-classification hours allocated, fringe treatment computed, and the sequence checked — so an officer reviews a report that is already reconciled rather than assembling it by hand and hoping the math holds.
- **Orchestrated** — Certified payroll is checked against everything it must agree with: reported rates validated against the incorporated wage determination, classifications reconciled against the workers and scope actually on-site, the weekly sequence tracked for gaps, lower-tier subcontractor payrolls collected and cross-checked, and submission tied to the agency's portal and payment schedule.
- **Autonomous** — The routine preparation and monitoring runs within guardrails: weekly reports drafted and reconciled from time data, rate and classification checks run against the current determination, missing-week and lower-tier-collection gaps escalated, and fringe-documentation flags raised — while a human verifies classifications, resolves any underpayment, and personally reviews and signs the penalty-of-perjury certification, which is never delegated to the system.

## Prompts

### Conversational — Checking a week's certified payroll against the wage determination before you sign it.

```text
Review this week's certified payroll for our federal project against the incorporated Davis-Bacon wage determination. For each worker, confirm the reported labor classification matches the work described, that the base rate meets or exceeds the determination for that classification, and that any split-classification hours are allocated to the correct higher rates. Verify overtime is computed correctly under the applicable rules, that fringe credits do not exceed documented bona fide benefits, and that no deduction looks unauthorized. Confirm this is the correct sequential payroll number with no missing prior weeks. List every discrepancy with the worker, the issue, and the computed underpayment, and tell me plainly whether this report is safe to certify.
```

**Expected output:** A worker-by-worker compliance review against the wage determination with each rate, classification, split, fringe, and sequence issue itemized and quantified, and a clear statement of whether the report is safe to certify.

**Follow-ups:**

- Compute the total back-wage restitution owed across the discrepancies.
- Which workers appear to have crossed classifications without split reporting?
- Draft the corrected report once I confirm the right classifications.

### Generative — Preparing the weekly WH-347 from time and payroll data.

```text
Prepare this week's WH-347 certified payroll from the attached time records and payroll data for our prevailing-wage project. Map each worker's hours to the correct labor classification from the incorporated wage determination, splitting hours where a worker performed more than one classification and applying each classification's rate. Compute gross pay, itemize deductions, show net, and reflect the fringe treatment — cash or bona fide benefits — with the fringe credit documented. Populate the correct sequential payroll number and week-ending date, and prepare the statement of compliance for signature. Do not sign it. Flag any worker whose reported rate would fall below the determination or whose classification you are uncertain about, so I can resolve it before certifying.
```

**Expected output:** A reconciled, unsigned WH-347 with correct classifications, split hours, rates, and fringe treatment, plus an explicit list of classification uncertainties and any below-determination rates for human resolution before certification.

**Follow-ups:**

- Show me every assumption you made about classification so I can verify it.
- Reconcile the report totals against the actual net paychecks issued.
- Prepare the state-form equivalent for our other project.

### Orchestrated — A GC reconciling project-wide certified-payroll compliance across all subs.

```text
Reconcile certified-payroll compliance across every contractor and subcontractor on this federal project. For each tier, confirm weekly reports were submitted for every week of on-site work with no gaps in the sequence, that reported classifications and rates match the incorporated wage determination, and that fringe credits are documented. Cross-check the workers reported against site records where available to catch unreported or misclassified labor. Identify every subcontractor whose payrolls we have not collected or reconciled, and quantify the potential back-wage and penalty exposure the project carries from any deficiency. Return one project-wide compliance report tying each finding to the specific tier, week, and worker.
```

**Expected output:** A project-wide reconciliation across all tiers identifying missing reports, classification and rate deficiencies, undocumented fringes, and uncollected subs, with back-wage and penalty exposure quantified and tied to source.

**Follow-ups:**

- Which subcontractors must submit corrected reports before we release their payment?
- What is our aggregate restitution exposure if these findings hold?
- Draft the deficiency notices to the non-compliant subs.

### Autonomous — Standing policy for certified-payroll preparation and monitoring within guardrails.

```text
Operate certified-payroll compliance under these rules. Each week, prepare the WH-347 for our covered work from the time and payroll data, mapping classifications to the current incorporated wage determination, splitting cross-classification hours, and computing fringe treatment, and reconcile it to the actual paychecks. Validate every rate against the determination and flag any at or below it. Track the weekly sequence and escalate any missing week before the submission deadline. As the GC, collect subcontractors' certified payrolls each week and flag any not received or not reconciled. Flag any fringe credit lacking documentation and any apprentice not verified as registered. Never sign or submit the statement of compliance, never adjust a worker's classification or rate to resolve a flag, and never release or approve a payment affected by a compliance gap — route every flag and the completed report to a named human for verification and signature.
```

**Expected output:** A weekly preparation-and-monitoring process with a review-and-sign queue and an exception list, where a human verifies classifications and rates and personally signs every certification, backed by a three-year retention record.

**Follow-ups:**

- Show me every report awaiting my review and signature this week.
- Which subcontractor payrolls are missing or unreconciled?
- List all below-determination rate flags and undocumented fringe credits.

## Maturity ladder

- **Level 0 — Level 0 — Manual and risky** — Reports are hand-built from payroll with classifications guessed and the sequence loosely tracked, so misclassification and missing weeks are common and unnoticed.
- **Level 1 — Level 1 — Formatted** — The WH-347 is produced consistently and filed on schedule, but classification and rate validation against the determination is manual and error-prone.
- **Level 2 — Level 2 — Linked** — Payroll is tied to the wage determination, time by classification, and the submission portal, so rate and sequence gaps are visible and lower-tier collection is tracked.
- **Level 3 — Level 3 — Assisted** — Reports are drafted and reconciled from time data, rate and classification discrepancies and fringe-documentation gaps are surfaced, and lower-tier reconciliation is generated for review.
- **Level 4 — Level 4 — Operated** — Weekly preparation, validation, sequence tracking, and lower-tier collection run unattended within guardrails, while a human verifies classifications and personally signs every certification.

## FAQ

### Is certified payroll just a payroll report I have to file?

No, and treating it as one is where the risk begins. It is a legal certification signed under penalty of perjury attesting that every worker on a covered public project was paid at least the required prevailing wage and fringe for the classification of work performed. A false or materially inaccurate certified payroll can lead to withheld contract payments, back-wage restitution, liquidated damages, debarment from public contracting, and False Claims Act liability, so its accuracy carries consequences an ordinary payroll register never does.

### What happens when a worker performs more than one classification in a week?

Their hours must be split-reported: each block of hours is reported under the classification that matches the work actually performed during those hours, and paid at that classification's prevailing rate. Reporting all of the hours at the lower rate underpays the higher-rate work and makes the certification materially inaccurate. This split-classification handling is one of the most commonly missed requirements and a frequent source of back-wage findings, which is why timekeeping must capture work by classification rather than just total hours.

### As a general contractor, am I responsible for my subcontractors' certified payrolls?

Yes. Under Davis-Bacon and comparable state laws the general contractor is responsible for prevailing-wage compliance across the entire project, including its subcontractors at every tier. Collecting subcontractor certified payrolls is not enough; the GC must actually reconcile them against the wage determination and the workers on-site, because unremedied subcontractor underpayment can result in withholding against the prime and liability that flows up the chain. This is why lower-tier collection and reconciliation is a core GC responsibility, not a clerical courtesy.

## Related objects

- [Prevailing Wage Determination](https://briq.ai/acu/object/prevailing-wage-determination)
- [Union Payroll & Fringe Benefits](https://briq.ai/acu/object/union-payroll-fringe)
- [Timecard](https://briq.ai/acu/object/timecard)
- [Vendor Onboarding & W-9](https://briq.ai/acu/object/vendor-onboarding-w9)
- [AI Governance & Auditability](https://briq.ai/acu/object/ai-governance-audit)
- [Closeout Package](https://briq.ai/acu/object/closeout-package)