Completing the WH-347 involves more than reporting workers, hours, wages, and deductions on Page 1.
Contractors must also complete Page 2, the Statement of Compliance, which certifies that the payroll is accurate and supported by the appropriate records.
As a companion to our guide, How to Complete a WH-347 Form, this blog takes a closer look at the Statement of Compliance. It explains what each section certifies, who can sign it, and what contractors should review before submitting a certified payroll report.
What Does the Statement of Compliance Certify?
Contractors and subcontractors working on projects covered by the Davis-Bacon and Related Acts must submit required certified payroll information each week. They do not have to use the WH-347 itself, but every federal DBRA certified payroll must include a signed Statement of Compliance, either Page 2 of the WH-347 or another document with identical wording.
The revised January 2025 WH-347 organizes Page 2 around checkbox certification statements and supporting sections for apprenticeships, fringe-benefit credits, remarks, and signer information. Together, these areas connect the payroll shown on Page 1 with the records, classifications, benefit arrangements, and payments behind it.
Project, Payroll, and Certifying Official Information
The fields at the top of Page 2 identify the project name and location, project or contract number, payroll number, contractor or subcontractor business name, and week-ending date. These entries should correspond to the payroll on Page 1
This area also asks for the Certifying Official’s Name and Title. DOL’s instructions say this should be the contractor or subcontractor (or their agent) who paid or supervised payment of the workers during the payroll period.
The Checkbox Certification Statements
Immediately below the identifying information, the certifying official states that they paid or supervised payment of the laborers or mechanics working on the project during the reported period. The form then presents checkbox statements covering the facts being certified.
Immediately below the identifying information, the certifying official states that they paid or supervised payment of the laborers or mechanics working on the project during the reported period. The form then presents checkbox statements covering the facts being certified.
In plain language, the first three checkboxes confirm that:
- The submitted payroll is correct and complete, and the wages and fringe benefits paid (including any credit claimed for a bona fide fringe-benefit plan) meet the applicable rates for the work actually performed.
- The required payroll and other basic records are complete, accurate, and available to the agency or DOL upon request.
- The classifications reported for the workers reflect the work they actually performed.
DOL’s instructions state that the first three checkboxes and the final full-wages checkbox must always be checked to certify compliance. The apprenticeship and fringe-benefit checkboxes are completed based on the circumstances reported for that payroll.
Apprenticeship Program Information
The apprenticeship checkbox applies when workers were paid as apprentices during the payroll period. It certifies that those workers are registered in a bona fide apprenticeship program registered with DOL’s Office of Apprenticeship or with a State Apprenticeship Agency recognized by DOL. It also connects the program information on Page 2 to apprentices identified on Page 1.
The table below that checkbox requests:
- The apprenticeship program name
- Whether the program is registered with OA or an SAA
- The name of the labor classification
If no workers were paid as apprentices, the checkbox is left unchecked and “Not Applicable” or “N/A” is entered in the apprenticeship program area.
Fringe-Benefit Certification & Hourly Credits
The next checkbox certifies that fringe benefits have been paid in cash, through bona fide fringe-benefit plans, funds, or programs, or through a combination of those methods. It is not a set of separate payment-method choices; it is one checkbox statement covering how the fringe-benefit obligation was satisfied.
The Hourly Credit for Fringe Benefits table is required when an amount is reported in Column 6B on Page 1. For each worker for whom a credit is claimed, DOL’s instructions direct the contractor to provide the worker entry number and name, identify each benefit plan by name, type, and number, indicate whether each plan is funded or unfunded, enter the hourly credit claimed under each plan, and calculate the worker’s total hourly credit.
Full Weekly Wages & Permissible Deductions
The final checkbox certifies that workers were paid the full weekly wages they earned, without direct or indirect rebates or deductions other than deductions permitted under 29 CFR part 3.
Additional Remarks
The Additional Remarks area is optional space for information about deductions, hourly fringe-benefit costs, or other explanations. For example, DOL’s instructions direct contractors to describe a single deduction entered under “Other” in Page 1 Column 8 here. If “Other” combines more than one deduction, an addendum should itemize and describe each amount.
Signature & Contact Information
The bottom row contains separate fields for the Signature of Certifying Official, Date, Telephone Number, and Email Address. The official’s printed name and title appear in the identification area at the top of Page 2, rather than beside the signature.
The Statement of Compliance may be signed by the contractor or subcontractor, or by their agent who paid or supervised payment of the workers covered by the payroll. DOL also advises that the signer should have knowledge of the facts being certified.
Remember: Federal rules require an original handwritten signature or a legally valid electronic signature.
Looking Ahead
Understanding the Statement of Compliance is an important step toward submitting accurate certified payroll reports under the revised WH-347. For a complete walkthrough of the form, including Page 1 reporting requirements, download our How to Complete a WH-347 Form guide. We’ll continue publishing compliance resources and practical insights as contractors navigate the updated federal reporting requirements.
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These materials are being issued with the understanding that LCPtracker is not engaged in rendering legal or other professional services and is providing these for informational purposes only. If legal, accounting, or tax expert assistance is required, the services of a competent legal, accounting or tax professional should be sought.