Certified payroll by state: California, New York and Illinois

Davis-Bacon and its related Acts create the federal obligation: on a covered contract, submit a payroll every week to the agency contracting for or financing the work, accompanied by a signed statement of compliance. That is 29 CFR 5.5(a)(3)(ii)(A), and Form WH-347 is the optional form the Department of Labor publishes for it. States with their own prevailing wage laws add a second obligation on top, with its own statute, its own administering agency, its own format and its own portal. On a job funded both ways you owe both, for the same week and the same workers, in two places.

California's public works requirements sit in the Public Works chapter of the Labor Code and are administered by the Department of Industrial Relations. The Director of DIR determines the prevailing wage, and workers on covered projects must be paid it. Certified payroll is filed electronically through DIR's own system at services.dir.ca.gov/pw, either by entering payroll online or by uploading an eCPR XML file against DIR's published schema. Two things catch people out. The project is identified by a DIR project ID looked up in the state's registry, not by your contract number. And the XML schema asks for each worker's full nine-digit Social Security number, where the federal WH-347 asks only for an identifying number — which is a real difference in what you must hold and protect, not a formatting detail.

New York's prevailing wage requirements are in Articles 8 and 9 of the Labor Law, enforced by the Bureau of Public Work and Prevailing Wage Enforcement. The change worth knowing is recent and firm: the Department of Labor states that beginning December 31, 2025, all contractors and subcontractors on projects covered by Article 8 must provide certified payroll records electronically through the Certified Payroll portal on MPWR. That date has passed. Paper is no longer the fallback it was. Projects are identified by a Prevailing Rate Case number — the PRC — which appears on your portal dashboard, and contractors with more than a handful of workers can upload a pre-formatted XML file rather than keying every week in by hand.

Illinois operates under the Prevailing Wage Act, 820 ILCS 130, with implementing rules at 56 Ill. Adm. Code 100, administered by the Illinois Department of Labor. Certified payroll is filed as a Certified Transcript of Payroll through IDOL's own portal, a requirement introduced by Public Act 100-1177 and codified at 820 ILCS 130/5.1. Access requires an Illinois Public ID account created with a business email address. Illinois asks for more than the federal form does in two respects that are worth planning for: worker demographic fields, and a split of hours between prevailing and non-prevailing work, which is a distinction the WH-347 does not draw and your payroll system may not record.

It does not list dollar thresholds. Whether a project is covered, and above what contract value, is the question contractors most want answered and the one most often answered wrongly by pages like this — the figures differ by state, differ between construction and maintenance, and are amended. We could not verify current thresholds from primary sources at the time of writing, so we have not published numbers we could not stand behind. Coverage is a determination the awarding body makes for your specific contract, and it should be in your contract documents. If it is not, ask before the first payroll is due rather than after.

Roughly half of US states have a prevailing wage law of some kind, often called a "little Davis-Bacon" Act, and several more have local ordinances that apply within a city or county. Rather than guess, ask the awarding body four questions in writing before work starts: which prevailing wage law applies to this contract, federal, state or both; which agency receives the certified payroll; which portal and file format they require; and what identifier the portal uses for this project. Those four answers determine everything else, and getting them in writing at the start is the difference between a routine first filing and a late one.

A contractor working across state lines files in each state's own system, under each state's own rules, for the same crews. The underlying payroll facts are identical — who worked, in what classification, for how many hours, at what rate, with what deducted — and the difference is entirely in transcription and identifiers. That is worth knowing when choosing how to keep records: a system organised around the facts travels between states, and one organised around a single state's form does not.