What information a certified payroll must contain

29 CFR 5.5(a)(3)(i) is the paragraph that governs what your payroll records must contain. It reads: "Such records must contain the name; Social Security number; last known address, telephone number, and email address of each such worker; each worker's correct classification(s) of work actually performed; hourly rates of wages paid (including rates of contributions or costs anticipated for bona fide fringe benefits or cash equivalents thereof of the types described in 40 U.S.C. 3141(2)(B) of the Davis-Bacon Act); daily and weekly number of hours actually worked in total and on each covered contract; deductions made; and actual wages paid." Read it as a checklist and almost every dispute about whether a payroll is complete answers itself.

Here is the distinction that catches people out, and it is worth being precise about. The paragraph above governs the records you keep. It does require the Social Security number. The payroll you submit is a different document, and Form WH-347 asks for something narrower: column (1E) is headed "WORKER IDENTIFYING NO.", not "Social Security number". Contractors commonly put the last four digits there. Sending a full Social Security number to an agency when the form asks only for an identifying number creates an exposure you gain nothing from, and certified payrolls can be subject to disclosure — the WH-347 itself warns that information reported in certified payrolls may be released in response to a Freedom of Information Act request. Keep the complete records. Submit the identifying number.

The regulation asks for "each worker's correct classification(s) of work actually performed". Note both halves. It is the classification of the work performed, not the job title you use internally, and the plural matters: a worker who spent Monday and Tuesday as an electrician and Thursday as a foreman has performed two classifications and belongs on two rows of the form, each with its own hours and its own rate. This is the column an agency compares against the wage determination incorporated into your contract, so a vague or invented classification makes the whole row unreviewable and is a common reason payrolls come back.

The wording is "daily and weekly number of hours actually worked in total and on each covered contract". Form WH-347 reflects this directly: column (4) is a grid of the seven days, and column (5) is the total for the week. Both have to be right, and they have to agree with each other — if the days add to 41 and the weekly total says 40, one of them is wrong and a reviewer cannot tell which. The "in total and on each covered contract" phrase is why columns (7A) and (7B) exist separately: gross earned on this project, and gross earned for all work in the period. The first is part of the second, so it can never be the larger number.

The regulation asks for "hourly rates of wages paid (including rates of contributions or costs anticipated for bona fide fringe benefits or cash equivalents thereof)". On the form this splits across columns (6A), (6B) and (6C): the hourly wage rate, the total fringe benefit credit, and any payment made in lieu of fringe benefits. If you pay fringes in cash rather than into a plan, that cash is paid above the base rate, not folded into it. Page 2 of the January 2025 revision of the form asks you to name each plan, give its type and number, say whether it is funded or unfunded, and state the hourly credit claimed for each worker.

The regulation requires "deductions made", and Form WH-347's column (8) breaks these into tax withholdings, FICA, other, and a total. The "other" column is printed with the instruction "MUST SPECIFY". That is not decoration: page 2 of the form points to 29 CFR part 3, which defines what deductions are permissible, and a reviewer cannot check an unnamed deduction against that list. If you withhold union dues, say so. The individual amounts also have to add up to the total you state, and gross minus total deductions has to equal the net pay you report.

If anyone on the payroll is paid less than the predetermined rate because they are an apprentice, 29 CFR 5.5(a)(4)(i) sets the condition: apprentices may work at less than the predetermined rate "when they are employed pursuant to and individually registered in a bona fide apprenticeship program registered with the U.S. Department of Labor, Employment and Training Administration, Office of Apprenticeship (OA), or with a State Apprenticeship Agency recognized by the OA." Two words carry weight there: "individually registered", and "bona fide". Page 2 of the form asks you to name the programme and tick whether it is registered with OA or with a State Apprenticeship Agency.