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.
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 contractors to 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 several structural 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
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.
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 to the 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 payrolls and 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 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
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.
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).
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.
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.
Source: U.S. Department of Labor, Wage and Hour
Division, "Instructions For Completing Davis-Bacon and Related Acts Weekly
Certified Payroll Form, WH-347." Available at: https://www.dol.gov/agencies/whd/forms/wh347
