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⟡ Reference — Certified payroll

Certified payroll electronic filing, state by state.

Federal certified payroll is a weekly form sent to a contracting agency. Several states replaced that with a portal that accepts a defined file format, on its own schedule, with fields the federal form does not carry. A project can be subject to both at once, and the two obligations do not merge.

This page covers California, New York and Washington — three states that publish a machine-readable format and a schema you can build against — plus the federal baseline they sit on top of. Other states with mandatory electronic certified payroll portals include Illinois (IDOL Certified Transcript of Payroll portal, monthly under 820 ILCS 130/5 since 2020) and New Jersey (NJ Wage Hub, mandatory under N.J.S.A. 34:11-56.33 since August 2024). It is not an exhaustive survey of all fifty states, and a city or county program can apply on top of a state one. The linked official sources govern; nothing here is legal advice.

How do the four regimes compare?

Certified payroll filing — federal baseline and three state systems
Jurisdiction Filed how often Accepted formats Filed where Authority
Federal (DBRA) Weekly Form WH-347, or any format carrying an identically worded Statement of Compliance The contracting agency — or the applicant, sponsor or owner that maintains the records 40 U.S.C. § 3145; 29 CFR 5.5(a)(3)(ii)
California At least monthly, or more often if the contract with the awarding body says so Online entry, or XML upload against DIR's published CPR schema DIR Public Works Website Services (eCPR) Labor Code §§ 1771.4, 1776
New York At least once every 30 days, for the length of the project Online entry, or XML bulk upload against NYDOL_CertPayroll.xsd. XML only — no CSV, no spreadsheet, no API NYSDOL Certified Payroll Portal (NYC contracts carved out to NYC OTI eComply) Labor Law Article 8, § 220-j
Washington At least once per month Online entry, or XML upload through the same portal L&I Contractor Portal (PWIA), in My L&I RCW 39.12.120

The payroll itself is always weekly. Only the filing cadence differs. A state that collects monthly is collecting a month of weekly records, not authorising a monthly payroll.

What is the federal baseline?

Under the Copeland Act and 29 CFR 5.5(a)(3)(ii), contractors and subcontractors on federal and federally assisted construction contracts submit a certified payroll every week, each one accompanied by a signed Statement of Compliance. There is no central federal portal — the payroll goes to the contracting agency, or to the entity maintaining records for transmission to it. Form WH-347 is optional; the weekly submission is not.

Field-level detail lives on its own page: WH-347, field by field.

California: what does the eCPR system require?

Contractors and subcontractors on most public works projects submit certified payroll records to the Labor Commissioner through DIR's Public Works Website Services. Labor Code § 1771.4 requires them at least monthly, or more frequently if the contract with the awarding body specifies, in an electronic format prescribed by the Labor Commissioner. Specific projects are exempt from electronic reporting to DIR: projects covered by a qualifying Project Labor Agreement (PLA) under § 1771.4(a)(4), and small public works projects under statutory thresholds ($25,000 or less for construction, alteration, or demolition, or $15,000 or less for maintenance), as set out in DIR's eCPR exemptions list.

Records can be keyed in through the portal or uploaded as XML built against DIR's published CPR schema, which DIR documents with an XML guidelines PDF and a downloadable sample file. The sample's namespace is http://www.dir.ca.gov/dlse/CPR-Prod-Test/CPR.xsd.

Fields worth noting, because the federal form has no equivalent:

  • doubletime is a first-class field — per day, in weekly totals, and as its own hourly rate alongside straight time and overtime. Federal WH-347 records straight time and overtime only.
  • deductionsContribPay is itemised rather than bucketed: separate elements for fedTax, FICA, stateTax, SDI, vacationHoliday, healthWelfare, pension, training, fundAdmin, dues, travelSubs, savings and other, plus a total.
  • contractorPWCR carries the contractor's public works registration, and projectID the DIR project identifier.
  • statementOfNP marks a statement of non-performance — the affirmative "no work this period" filing that keeps a project's record continuous.

Two distinct penalties apply under California law:

  • Electronic filing failure (Labor Code § 1771.4): runs to $100 per day of violation, capped at $5,000 per project, and cannot be imposed until 14 days after the deadline has passed.
  • Failure to produce records on request (Labor Code § 1776(h)): carries a separate penalty of $100 per calendar day per worker if certified payroll records are not produced within 10 days of receiving a written notice from the awarding body or DLSE.

Filed records are searchable by the public through DIR's CPR Public Search with confidential information removed. Labor Code § 1776(e) governs that redaction: copies furnished to the public are marked to prevent disclosure of a worker's name, address and Social Security number, while multiemployer Taft-Hartley trust funds requesting records to allocate contributions receive the last four digits.

New York: what changed on 1 January 2026?

Electronic submission became mandatory. Under Labor Law Article 8 § 220-j, contractors and subcontractors on public work — and on privately owned projects carrying prevailing wage obligations, including certain renewable energy projects — submit certified payroll through the NYSDOL Certified Payroll Portal at least once every 30 days for the length of the project. Article 9 building service work is excluded, and pre-2026 payroll records are not mandated retroactively. Paper filing to the Department is no longer accepted.

The New York City carve-out: Under Labor Law § 220-j(2), public work contracts solicited on or after 31 December 2025 by a city with a population of one million or more (New York City) — as well as roadway excavation work permitted under § 224-f — are submitted directly through the City's portal (NYC OTI eComply / PASSPort) rather than the statewide NYSDOL database.

Bulk upload is XML only. NYSDOL publishes NYDOL_CertPayroll.xsd and a sample file; there is no CSV or spreadsheet path, and no API for the portal. New York alone publishes explicit partitioning limits constraining every file:

  • One project per file, keyed by prcNumber — the Prevailing Rate Case number, which must match the project.
  • One week per file, with weekEndingDate in ISO format.
  • No more than 500 employee work weeks per file.

The worker identifier is unusual and worth building for deliberately: the schema carries both ssnLast4 and dateOfBirth, and an employee must supply exactly one of them — a value in both is rejected. Other New York-specific elements include nysRegisteredApprentice, workCategory, which is validated against the system's approved classification list, and supplementalPayments.

Continuous reporting: Submissions must be sequential without gaps across the contract. For weeks where no work occurs on site, contractors submit a "No Work" payroll record to keep the weekly numbering unbroken.

Late submissions carry a statutory 14-day grace period, after which penalties of up to $100 a day may apply. Willful failure to provide accurate records is a Class E felony with civil penalties up to $1,000.

As of August 2026, NYSDOL states it is exercising discretion not to issue fines for late payrolls while contractors and agencies acclimate to the system, and that official notice will precede enforcement. That is a discretionary posture, not a change in the statute — check the Department's electronic payroll FAQ before relying on it.

Washington: what does L&I require?

Under RCW 39.12.120 (as amended by ESSB 5035 in 2019 and SHB 1821, 2025 c 99 § 3, effective July 27, 2025), a contractor, subcontractor or employer must file a copy of its certified payroll records using L&I's online system at least once per month for public works. Records are kept for three years from the awarding agency's acceptance of the project, and noncompliance is a violation of RCW 39.12.050. Filing runs through the Contractor Portal in My L&I; L&I publishes an XML payroll upload guide for contractors submitting files rather than keying records in.

The statute sets out what each record must show: full name, address, Social Security number, trade or occupation, classification, straight-time and overtime rates, hourly rate of usual benefits, hours worked each day and week, actual gross wages, itemised deductions, withholdings and net wages — plus any employee authorisations executed under RCW 49.28.065, the four-ten workweek agreements. Those agreements have no analogue on the federal form.

Interested-party disclosure (2025 amendment): Under SHB 1821, L&I must provide certified payroll records upon request to interested parties — explicitly including joint labor-management cooperation committees — with records restricted solely to investigating or filing prevailing wage complaints under RCW 39.12.065.

Like California and New York, Washington requires continuous reporting for the duration of the project: for weeks without active labor, contractors file a "No Work Performed" report in the portal.

Certified payroll is only one of three filings. A Statement of Intent to Pay Prevailing Wages is filed after award and before work begins — and posted on site for contracts over $10,000 — and an Affidavit of Wages Paid is filed at completion. Both go through the same portal, and a project is not closed out on certified payroll alone.

Why can't one file serve every jurisdiction?

Because the systems disagree about what a worker is, what an hour is, and what a payment is. The clearest case is the worker identifier, where the four regimes take four different positions on the same field:

How each regime identifies a worker
Jurisdiction Worker identifier
Federal WH-347 Last four digits of the Social Security number, or any number specific to the worker. Full Social Security numbers must not be included.
California The published sample carries a full nine-digit ssn element. DIR redacts it from the public search under Labor Code § 1776(e).
New York Either ssnLast4 or dateOfBirth — exactly one, never both.
Washington RCW 39.12.120 requires the Social Security number in the payroll record itself.

The same divergence runs through the rest of the record. Hours split into straight time and overtime federally, but into straight time, overtime and double time in California. Fringe obligations are a credit-versus-cash pair on the January 2025 revision of Form WH-347 (columns 6B "Total Fringe Benefit Credit" and 6C "Payment in Lieu of Fringe Benefits", which replaced the older single-column fringe format), itemised by fund type in California, and supplementalPayments in New York. Project keys are a contracting agency's contract number federally, a projectID and registration number in California, and a Prevailing Rate Case number in New York. New York alone publishes explicit file partitioning limits.

Continuous reporting mechanics differ too: California's XML carries an explicit statementOfNP flag, New York requires sequentially numbered "No Work" payrolls, Washington requires an online "No Work Performed" filing, and federal practice relies on numbered non-performance WH-347 forms or statements.

The practical consequence: a single canonical weekly payroll record can be derived into each format, but no format is a superset of the others, and the mapping is per-jurisdiction. The checks differ too — a classification that is valid federally may not exist in New York's approved list, and a rate that clears one wage determination may not clear another applying to the same week.

Official sources

Every claim above traces to one of these. They are the versions to check against, because they change and this page does not change with them.

⟡ Revision history
  • 31 Aug 2026 — Updated Washington RCW 39.12.120 for 2025 SHB 1821 interested-party disclosure rules; detailed NYC § 220-j(2) carve-out and Article 9 exclusion; added CA § 1776(h) penalty distinction and PLA/small-project exemptions; referenced IL (IDOL) and NJ (Wage Hub) portals; dated WH-347 to January 2025 revision.
  • 30 Aug 2026 — Initial publication; verified NYSDOL temporary enforcement discretion posture.

Reviewed against the sources listed above. Filing rules change; verify against the official source before relying on this page.

Maintained by Osketh. We build quiet software for regulated back offices — systems that read a document, check every value against the rules that govern it, and file the result. This page is reference material, not a product. These portals and schemas change without much notice. If you want to be notified when filing rules or schemas change, or have a correction, write to us at [email protected].