Certified Payroll for Subcontractors: What General Contractors Must Collect and File

TL;DR: On federally funded construction projects, the Davis-Bacon Act makes the prime GC legally responsible for every subcontractor's certified payroll—miss a sub's WH-347 and the contracting agency can withhold your entire progress payment. Collect signed WH-347s from every tier of subs weekly, and enforce submission deadlines in your subcontracts before work starts.

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If you've ever worked a federal or federally assisted construction job—a school, a highway, a government building—you've dealt with certified payroll. You know what it is for your own workers. But here's what trips up a lot of general contractors: you are also responsible for your subcontractors' certified payroll.

Every sub on site. Every tier under them. All the way down.

That means if your electrical sub forgets to file their WH-347 for three weeks, the contracting agency can hold your payment. Not the sub's payment—yours. This is one of the most painful surprises a GC can face on a public works project, and it happens constantly.

This post walks through why the GC holds the bag, how to actually collect certified payroll from every tier, and what to do when a sub drags their feet.

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Why GCs Are Responsible for Subcontractor Certified Payroll

The Davis-Bacon and Related Acts (DBRA) impose certified payroll obligations on every contractor and subcontractor on covered projects. But the mechanism of enforcement runs through the prime contractor.

Here's the legal reality: the contract between the federal agency and the GC requires the GC to ensure DBRA compliance throughout the entire project—every sub, every tier. If a second-tier sub (a sub of a sub) pays their laborers below prevailing wage rates or fails to submit a WH-347, the prime GC is on the hook.

The Department of Labor's regulations at 29 CFR Part 5 make this explicit. The prime contractor must:

• Incorporate DBRA requirements into all subcontracts
• Collect weekly certified payroll reports from each sub
• Submit those reports (along with its own) to the contracting agency
• Investigate and correct any violations discovered in sub reports

This isn't optional paperwork. It's a contract obligation backed by real enforcement tools. Contracting agencies can and do withhold progress payments until all outstanding certified payrolls—including those from subs—are current. On large multi-million dollar projects, payment holds for missing sub payrolls are a genuine cash-flow crisis.

For a deeper look at the underlying rules, see our full guide on certified payroll prevailing wage compliance.

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What You Need to Collect from Each Subcontractor

Each subcontractor—regardless of tier—must submit a completed WH-347 form (or approved electronic equivalent) for every week they perform work on the project.

What's in a WH-347

The WH-347 captures:

• Employee name, address, and last four digits of Social Security Number
• Work classification (Laborer, Carpenter, Electrician, etc.)
• Hours worked each day of the week, split between straight-time and overtime
• Hourly rate paid and the applicable prevailing wage rate
• Deductions (taxes, fringe benefits, etc.)
• Net wages paid
• A signed Statement of Compliance certifying the information is correct

Each WH-347 must be signed by an officer of the company or another authorized representative. An unsigned WH-347 is not compliant—agencies will reject it, and you'll still be on the hook.

Weeks With No Work

If a sub performs zero work during a given week, they still need to submit a "no work" WH-347 for that week—or at minimum a written statement confirming no work was performed. Many GCs skip this, and it creates gaps in the submission log that agencies flag during audits.

Multiple Classifications

If a sub's employee works as both a laborer and a carpenter during the week, the WH-347 must show each classification separately with hours split accordingly. A single line lumping everything together is a common mistake that triggers correction requests.

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How to Actually Collect Certified Payroll from Every Tier

Collecting certified payroll from your own company is manageable. Doing it from five subcontractors, each of whom has lower-tier subs of their own, is a coordination problem.

Here's a system that works in practice:

1. Lock It in the Subcontract Before Work Starts

Don't rely on informal agreements or verbal reminders. Your subcontract agreement for any Davis-Bacon project should explicitly state:

• The sub must submit a WH-347 (or equivalent) to you by a specific day each week (Wednesday or Thursday works well)
• The sub must flow down the same requirement to all their lower-tier subs
• Their lower-tier subs must submit WH-347s to them, which they must forward to you
• Late or missing submissions are grounds for withholding payment from the sub

If it's not in the subcontract, you have no real leverage when a sub misses a deadline.

2. Set a Submission Deadline One Day Before Your Own Deadline

If your agency requires certified payrolls by Friday, require your subs to submit by Thursday. This gives you time to review for obvious errors—missing signatures, blank fields, classification problems—and chase corrections before you miss your own deadline.

3. Map Your Tier-2 and Tier-3 Subs Before Work Starts

Before mobilization, ask every sub to list any lower-tier subs they plan to use. Get company names, contact information, and prevailing wage classifications. Update this list throughout the project.

You can't collect payroll from a company you don't know exists. Require your subs to notify you in writing before they bring anyone else on site.

4. Use a Tracking Log

Maintain a simple spreadsheet or document tracking:

• Sub company name
• Weeks worked on the project
• WH-347 submission status for each week
• Any corrections requested and their resolution status

Review this log every week. Gaps stand out immediately. When a sub is missing submissions, follow up within 24 hours—not at the end of the month when the problem has compounded.

5. Don't Pay Until Certified Payroll Is Current

Your subcontract gives you leverage. Use it. Make it clear before the project starts that you will not process a sub's pay application for a given period unless their WH-347 submissions are current through that period. This motivates subs far more than emails alone.

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What to Do When a Sub Refuses or Files Late

Some subs understand certified payroll. Others treat it like optional paperwork. Here's how to handle the common scenarios:

The Sub Says They Don't Know How

New subs who haven't worked on prevailing wage projects before often don't know how to complete a WH-347. This is fixable. Point them to the DOL's instructions, share your own example of a completed form, or sit down with them for 30 minutes and walk through it. An hour spent training a sub is worth weeks of chasing missing payrolls.

The Sub Files Late

Document every late submission. Note the week it covered, the date it was due, and the date you actually received it. If the contracting agency asks why there are gaps, your documentation shows you were actively managing the requirement—even if you weren't perfect.

A late WH-347 is almost always better than no WH-347. Even if you've already submitted your own payrolls for the week, you can generally submit the sub's late report with a cover letter explaining the delay.

The Sub Refuses Entirely

Flat refusal is rare but it happens, usually with subs who don't understand what they agreed to when they signed your subcontract or who are trying to conceal wage violations.

Your options:

1. Issue a formal written demand, citing the specific subcontract clause requiring submission.
2. Withhold payment for the applicable periods until the sub complies.
3. Report the violation to the contracting agency. The agency has its own enforcement tools and can pursue the sub directly. This also protects you by creating a record that you flagged the problem.
4. Consider termination for cause if the sub continues to refuse. A sub who won't comply with a basic contract requirement on a federally funded job is a liability.

Do not let a stubborn sub's refusal turn into your problem with the contracting agency. The agency doesn't care why the WH-347 is missing—they'll hold your money regardless.

The Sub's Employees Were Misclassified

This one is serious. If you review a sub's WH-347 and notice their employees are classified as laborers but are clearly performing carpenter or electrician work, you have an obligation to flag it. If you don't, and the agency or DOL audits the project later, your silence becomes evidence of knowing participation in wage fraud.

Send the sub a written correction request, document their response, and keep copies of everything.

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The Consequences If Certified Payroll Falls Apart

The enforcement tools available to contracting agencies and the DOL are significant. Here's what's actually at stake:

Payment withholding: The most immediate consequence. Agencies can hold your progress payments until all certified payroll submissions—including your subs'—are current and compliant. On a $2 million project, this could mean $200,000 or more sitting in escrow while you wait for a sub to fix a paperwork problem.

Wage restitution: If a sub paid below prevailing wages, the DOL can order back wages for all affected employees. As the prime contractor, you may be jointly liable for that restitution.

Debarment: Willful or repeated violations can result in debarment from federally funded construction work for up to three years. This is the nuclear option, but it does happen.

Contract termination: Persistent non-compliance can give the contracting agency grounds to terminate the prime contract for default.

Understanding the full scope of these obligations is why we cover certified payroll prevailing wage compliance in detail in our hub guide—the stakes are too high to learn through trial and error on a live project.

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A Pre-Project Certified Payroll Checklist for GCs

Before your first day of work on any Davis-Bacon project, run through this list:

• Confirm the project is subject to Davis-Bacon (check the contract documents for the Davis-Bacon wage determination)
• Obtain the applicable wage determination from SAM.gov and distribute to all subs
• Add certified payroll submission requirements and deadlines to all subcontracts
• Flow-down language in your subcontracts requires subs to impose the same on their lower-tier subs
• Collect a list of all planned lower-tier subs before mobilization
• Set up a tracking log for WH-347 submissions by sub and week
• Designate one person in your office as responsible for collecting and reviewing WH-347s
• Confirm the contracting agency's submission method (paper, email, LCPtracker, or other portal)
• Establish your payment-hold policy for non-compliant subs in writing before work starts
• Brief project manager and superintendent on the process so they can flag problems early

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Tools That Help

Managing certified payroll collection manually across multiple subs and tiers is doable on small projects. On larger ones with 10+ subs, it becomes a part-time job on its own.

Software like LCPtracker, Procore's certified payroll module, or dedicated compliance platforms can automate submission reminders, flag missing weeks, and track approval status across every sub.

For the broader document collection problem—COIs, W-9s, lien waivers, and certified payroll all in one place—PaperBoss is built specifically for general contractors who need to track compliance documents from every sub on every project. If you're currently managing this in spreadsheets and email, try PaperBoss free and see how much time disappears from your week.

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Frequently Asked Questions

Is the GC responsible if a subcontractor pays below prevailing wage?

Yes. As the prime contractor on a Davis-Bacon project, you can be held jointly liable for a subcontractor's wage violations—including back pay owed to their employees. This is why reviewing WH-347s for obvious classification or rate problems matters, not just confirming they were submitted.

What happens to my payment if a sub doesn't submit their WH-347?

The contracting agency can withhold your progress payment until all certified payrolls—including your subcontractors' reports for all covered weeks—are submitted and accepted. This applies even if your own payrolls are perfectly current.

Do lower-tier subcontractors (subs of subs) have to submit WH-347s?

Yes. Every contractor and subcontractor at every tier who performs work on a Davis-Bacon covered project must submit a weekly WH-347. The prime GC is responsible for collecting and forwarding these reports to the contracting agency.

Can a subcontractor use their own payroll software instead of the WH-347 form?

Some contracting agencies accept electronic certified payroll reports generated by approved software platforms as an alternative to paper WH-347 forms. The agency must specifically allow this—don't assume. Check with the contracting officer before the project starts.

What should I do if a sub submits a WH-347 with obvious errors?

Return it immediately with a written list of corrections needed. Document the date you sent the correction request and the date the corrected form came back. Do not submit a form you know to be incorrect to the contracting agency—that creates potential liability for you.

How long do certified payroll records need to be kept?

Davis-Bacon regulations require certified payroll records to be preserved for at least three years after the project is complete. Keep copies of both your own WH-347s and those submitted by your subcontractors.