The New WH-347 Form: What Construction Companies Need to Know About 2025 Certified Payroll Changes

The construction industry is facing another significant compliance shift. The U.S. Department of Labor (USDOL) has released an updated WH-347 form for certified payroll reporting, effective January 15, 2025, with validity extending through January 31, 2028. For construction companies working on federal projects, understanding these changes isn't optional—it's essential for maintaining compliance and avoiding costly penalties.

Understanding the WH-347 Form and Its Importance

The WH-347 form, officially known as the "Statement of Compliance for Payroll," serves as the cornerstone of prevailing wage compliance for federal construction projects. Every contractor and subcontractor working on federally funded projects must submit weekly certified payroll reports using this form, documenting wages, benefits, and worker classifications to ensure compliance with the Davis-Bacon Act and related prevailing wage laws.

The significance of accurate WH-347 reporting cannot be overstated. Non-compliance can result in contract suspension, debarment from future federal work, and substantial financial penalties. With federal construction spending continuing to grow through infrastructure investments, the stakes for proper compliance have never been higher.

Key Changes in the 2025 WH-347 Update

The updated form represents the most comprehensive revision to certified payroll reporting in years. These changes reflect the USDOL's commitment to enhanced transparency, improved worker protections, and more detailed reporting requirements.

Enhanced Worker Classification Requirements

One of the most significant updates involves how contractors classify their workers. The new form requires explicit identification of whether an employee is a journeyworker or a registered apprentice directly within the form structure. This change eliminates ambiguity and ensures clearer documentation of workforce composition.

Previously, worker classification could be somewhat informal or inconsistent across different contractors. The new requirements standardize this process, making it easier for government agencies to verify proper wage payments and track apprenticeship participation across federal projects.

Comprehensive Fringe Benefit Documentation

The updated WH-347 form dramatically expands fringe benefit reporting requirements. Contractors must now provide detailed documentation, including benefit names, types, plans, plan numbers, and specific hourly credit values. The form distinguishes between funded and unfunded benefits, offering unprecedented transparency into worker compensation packages.

This enhanced reporting includes dedicated fields for total fringe credit and payments made in lieu of fringes. For many contractors, this represents a significant increase in documentation requirements, particularly those with complex benefit structures or multiple benefit plans.

Improved Wage and Pay Transparency

The new form introduces updated report mapping that requires contractors to report both gross wages and net pay for all work performed. This change provides government agencies with a more complete picture of worker compensation and helps identify potential discrepancies between reported wages and actual payments.

This transparency requirement extends beyond basic hourly wages to include overtime calculations, shift differentials, and other pay adjustments. Contractors must now demonstrate clear alignment between their payroll systems and certified payroll reports.

Modernized Statement of Compliance

The Statement of Compliance (SOC) section has undergone a complete redesign. The updated SOC includes additional attestations and clearer certification language, leaving less room for the interpretation of contractor responsibilities.

Notably, certifying officials are now required to provide their contact details, including phone numbers and email addresses. This change facilitates easier communication between government agencies and contractors during audits or investigations, potentially streamlining the compliance verification process.

Apprenticeship Verification and Documentation

Reflecting the federal government's increased focus on workforce development, the new form includes dedicated fields for identifying apprenticeship programs, aligning classifications, and verifying registration types. Contractors must now clearly indicate whether apprentices are enrolled in federal or state-approved programs.

This enhanced apprenticeship documentation supports broader workforce development initiatives while ensuring that apprentices receive appropriate wages and training opportunities. For contractors participating in apprenticeship programs, these requirements represent a significant documentation upgrade.

Navigating the Federal Transition Period

The USDOL has established a transition period during which both the new and previous versions of the WH-347 form remain acceptable. However, many awarding bodies and prime contractors are already requiring the use of the updated version, creating a practical imperative for early adoption.

Construction companies should develop a clear transition strategy rather than waiting until the last minute. This includes updating internal processes, training staff on new requirements, and ensuring payroll systems can accommodate the enhanced reporting fields.

The transition period also provides an opportunity to identify and address potential compliance gaps before they become mandatory. Companies that proactively adopt the new form often discover process improvements that benefit their overall workforce management approach.

Implementation Challenges and Solutions

The enhanced reporting requirements present several implementation challenges for construction companies. Many existing payroll systems may not be able to accommodate the new data fields, requiring software updates or system replacements. Additionally, the increased documentation requirements demand more detailed record-keeping and staff training.

Successful implementation requires a systematic approach. Companies should begin by auditing their current certified payroll processes and identifying gaps between existing capabilities and new requirements. This audit should encompass payroll systems, data collection procedures, and staff training needs.

Technology solutions play a crucial role in managing these enhanced requirements. Modern workforce management platforms can automate much of the data collection and form preparation process, reducing the risk of errors and ensuring consistent compliance across all projects.

Best Practices for Compliance

Establishing robust compliance procedures is essential for managing the new WH-347 requirements. This begins with accurate data collection at the source—ensuring that time and attendance systems capture all necessary information for certified payroll reporting.

Regular training for project managers, superintendents, and payroll staff is crucial. Everyone involved in workforce management should understand the new requirements and their role in maintaining compliance. This includes understanding the distinction between journeyworkers and apprentices, proper fringe benefit documentation, and accurate wage reporting.

Documentation procedures should be standardized across all projects and locations. Consistent processes reduce the risk of errors and make it easier to identify and correct problems before they impact compliance. This includes maintaining backup documentation for all reported wages, benefits, and worker classifications.

The Role of Technology in Compliance Management

Modern workforce management technology offers significant advantages for WH-347 compliance. Automated systems can ensure that all required data fields are completed, flag potential errors before submission, and maintain comprehensive audit trails for government inspections.

Integration between time and attendance systems, payroll platforms, and certified payroll reporting tools eliminates manual data entry and reduces the risk of transcription errors. This integration becomes increasingly important as reporting requirements become more complex and detailed.

Cloud-based solutions offer additional benefits, including real-time access to compliance data, automatic form updates, and centralized management across multiple projects and locations. These capabilities are particularly valuable for larger contractors managing numerous federal projects simultaneously.

Preparing for the Future

The 2025 WH-347 update represents part of a broader trend toward enhanced transparency and accountability in federal contracting. Construction companies should view this update as an opportunity to enhance their overall compliance infrastructure rather than merely meeting minimum requirements.

Investing in robust workforce management systems and processes positions companies for future regulatory changes while providing operational benefits beyond compliance. Better data collection and reporting capabilities support improved project management, cost control, and strategic decision-making.

The updated WH-347 form represents a significant evolution in certified payroll reporting requirements. While the enhanced documentation and reporting requirements present implementation challenges, they also offer opportunities for construction companies to strengthen their compliance programs and improve their competitive position in the federal marketplace.

Success with the new requirements depends on early preparation, systematic implementation, and ongoing attention to compliance procedures. Companies that proactively address these changes will be better positioned to capitalize on federal construction opportunities while avoiding the risks associated with non-compliance.

The construction industry's ability to adapt to evolving regulatory requirements remains a key differentiator in the federal marketplace. By embracing the new WH-347 requirements and implementing robust compliance systems, construction companies can ensure their continued success in this critical market segment while supporting the broader goals of transparency and worker protection that drive these regulatory changes.