WH-347 Statement of Compliance: Who Can Sign and What It Certifies
Published October 5, 2026
Page 1 of a certified payroll says who worked and what they were paid. The Statement of Compliance on page 2 is what makes it certified: a signed statement, under federal penalties, that the payroll is right and the workers were paid what the law requires.
Who can sign
The regulation says the statement is signed by "the contractor or subcontractor, or the contractor's or subcontractor's agent who pays or supervises the payment of the persons working on the contract." (Source: 29 CFR 5.5, contract provisions (certified payrolls, apprentices, overtime), (a)(3)(ii)(C).) The WH-347 instructions say the same: the contractor or subcontractor, or their agent who paid or supervised the payment of the workers. (Source: DOL Wage and Hour Division: Form WH-347 (Rev. January 2025) and its instructions, instructions.) The form's own first line reflects it: "I paid or supervised the payment of the laborers or mechanics working on the above project during the stated time period." (Source: DOL Wage and Hour Division: Form WH-347 (Rev. January 2025) and its instructions, page 2.)
So the test is the role, not the title. Someone who neither pays nor supervises payment is not the right signer, even if senior. The signature must be an original handwritten signature or a legally valid electronic signature. (Source: 29 CFR 5.5, contract provisions (certified payrolls, apprentices, overtime), (a)(3)(ii).)
The three things the signature certifies
29 CFR 5.5 lists three certifications: (Source: 29 CFR 5.5, contract provisions (certified payrolls, apprentices, overtime), (a)(3)(ii)(C).)
- The payroll is complete. It contains the information required, and the information is correct and complete.
- Full wages, no kickbacks. Each laborer or mechanic, including each helper and apprentice, was paid the full weekly wages earned, without rebate, direct or indirect, and without deductions other than permissible ones.
- At least the prevailing wage. Each laborer or mechanic was paid not less than the applicable wage rates and fringe benefits, or cash equivalents, for the classification of work actually performed, as in the wage determination in the contract.
The January 2025 form spells these out as six statements to check: the payroll and the rates paid, the underlying records, the classifications, apprentices, fringe benefits, and no rebates or deductions other than those permitted under 29 CFR part 3. (Source: DOL Wage and Hour Division: Form WH-347 (Rev. January 2025) and its instructions, page 2.) A contractor does not have to use the WH-347, but a properly executed copy of its page 2 statement satisfies the requirement. (Source: 29 CFR 5.5, contract provisions (certified payrolls, apprentices, overtime), (a)(3)(ii).)
What a false statement can cost
The regulation says falsifying any of the certifications may subject the contractor or subcontractor to civil or criminal prosecution under 18 U.S.C. 1001 and 31 U.S.C. 3729. (Source: 29 CFR 5.5, contract provisions (certified payrolls, apprentices, overtime), (a)(3)(ii).) The form prints the warning above the signature line and adds debarment from future federal and federally assisted contracts. (Source: DOL Wage and Hour Division: Form WH-347 (Rev. January 2025) and its instructions, page 2.)
- 18 U.S.C. 1001 is the federal false statements law. A conviction can bring a fine and imprisonment of not more than 5 years. (Source: 18 U.S.C. 1001, false statements, (a).)
- 31 U.S.C. 3729 covers liability for false claims made to the government. (Source: 29 CFR 5.5, contract provisions (certified payrolls, apprentices, overtime), (a)(3)(ii).)
The person signing is the one making the statement. Read page 1 before signing page 2.
Before you sign
- Check every rate in column 6A against the wage determination for the classification in column 3.
- Check that fringe credit in column 6B matches the plan detail on page 2, and cash in lieu is in column 6C.
- Check overtime: hours over 40 at 1.5 times the basic rate, with fringe left out of the multiplier.
- Check apprentices: registered, within the ratio, and box 4 filled in.
- Check deductions: only those permitted.
- Then sign, by hand or with a legally valid electronic signature.
Check the payroll before you put your name on it. The WH-347 Certified Payroll Pre-Check recomputes every row of a weekly payroll against the wage determination rates you give it: classifications, rates, fringe, overtime, apprentice rates and ratios, and the gross, deductions and net math. $25.00 per completed check, with a free test on the page. Check a payroll
A PASS is not acceptance by the contracting agency or the Department of Labor, and it is not legal advice.
Related
- How to Report Apprentices on the WH-347 (Column by Column)
- 7 WH-347 Mistakes That Get Certified Payrolls Rejected
- Davis-Bacon Fringe Annualization: the Formula With Examples
- Davis-Bacon Weighted-Average Overtime, Worked Example
- Free Davis-Bacon overtime calculator
- Free fringe benefit annualization calculator
- Free apprentice ratio checker
Sources
- 29 CFR 5.5, contract provisions (certified payrolls, apprentices, overtime)
- DOL Wage and Hour Division: Form WH-347 (Rev. January 2025) and its instructions
- 18 U.S.C. 1001, false statements
Checked October 5, 2026. SpreadRun is not affiliated with or endorsed by the Department of Labor. This is general information, not legal or compliance advice. Where this page and the regulations differ, the regulations control.