SUBCONTRACTORS

Certified payroll for subcontractors: what the prime expects every week

On a Davis-Bacon project the prime contractor is responsible to the agency for every subcontractor's compliance. That is why primes chase subs for payrolls, reject the ones that do not reconcile, and hold progress payments until the stack is complete. Understanding what the prime has to deliver makes the weekly routine far less adversarial.

6 min read · Updated September 2026

The weekly chain

Each subcontractor prepares a certified payroll for each week it performs covered work and submits it to the prime (or the next-tier contractor above it). The prime reviews it, adds its own payroll, and submits the set to the contracting agency. The regulation requires submission weekly, within seven days after the regular pay date for the payroll period. Agencies and primes often set earlier internal deadlines so they can review before their own deadline.

Numbering, no-work weeks and the final payroll

Payrolls are numbered consecutively per contractor per project from the first week of work. Weeks with no covered work should be documented — either a payroll marked “no work” or a non-performance statement, depending on the recipient — so the sequence has no gaps. The final payroll is marked as such; the 2025 revision of the WH-347 has a checkbox for it. Primes cannot close out until every sub's final payroll is in.

Portals and formats

Many primes and agencies require electronic submission through a labor compliance portal such as LCPtracker, eMars or Elation, or through a state system such as California's DIR eCPR. The portal defines the format; the underlying content is the same as the WH-347. Confirm with the prime at contract signing which system and format they require, whether a signed PDF is also needed, and who at the prime reviews submissions.

Corrections

When a payroll is wrong — a rate, a classification, missed hours — the fix is a corrected payroll that clearly supersedes the original, with any back wages paid and shown. The original is not altered or withdrawn; both remain in the record. Agencies look for the correction trail, and a clean one is the difference between a routine fix and an investigation.

Retention and consequences

Payroll records must be kept for three years after all work on the prime contract is completed and made available to the agency or the Department of Labor on request. Late or missing payrolls lead to withheld progress payments; underpayments lead to withheld funds and back wages; falsified certifications can lead to debarment and criminal referral. Most problems never get that far — they are caught by the prime's review and fixed — which is exactly why the prime's review is thorough.

In PaidReady

PaidReady records the facts these rules depend on — determination versions by date, classifications, hours by day, fringe and apprentice facts — and reviews them with explainable checks before you prepare and sign the WH-347. It does not decide which laws apply to your project and does not replace your payroll provider.

How PaidReady tracks weeks, corrections and the signed record →

Sources

This guide is general information current as of September 2026. It is not legal advice. Requirements vary by contract, agency and state; confirm them with the contracting agency or qualified counsel.