State certified payroll requirements: how 10 state systems differ from the WH-347

The federal WH-347 covers work funded with federal money. Roughly half the states have prevailing wage laws of their own for state and local public works, and each has its own certified payroll form, portal, and data rules. A contractor on a state-funded school in Ohio files nothing federal; a contractor on a federally assisted highway job in California files both.

The 4 states below are the largest and the most different from the federal form. The common thread: each asks for worker data the federal form prohibits.

California

Law. California Labor Code sections 1720 through 1861. Applies to public works over $1,000, including maintenance. Projects up to $25,000 for construction or $15,000 for maintenance are exempt from DIR contractor registration and eCPR filing, not from paying prevailing wage.

System. Certified payroll records go to the Department of Industrial Relations (DIR) through its eCPR system, either typed into the portal or uploaded as XML that follows DIR's published schema (version 2.0 as of March 2026). The state form is A-1-131.

Frequency. The Labor Code requires submission to DIR at least monthly. Most contracts and labor compliance programs require weekly. For weeks with no work, eCPR has a statement of non-performance.

Data. This is where California departs furthest from the federal rule. Every eCPR submission requires each worker's full Social Security number and home address. DIR redacts them before making records public. The federal WH-347 for the same worker, if the job also has federal money, carries only the last 4 or an employee ID.

Other differences. California public works pay overtime after 8 hours in a day as well as after 40 in a week, and many crafts have weekend and holiday rates. Contractors must be registered with DIR to bid or work on public works, and awarding bodies register each project with DIR before work starts. Apprentices must be requested from the local apprenticeship committee and employed at a ratio of at least 1 apprentice hour for every 5 journeyworker hours. California in detail.

New York

Law. Labor Law Article 8 for public work, and Article 9 for building service contracts.

System. Beginning January 1, 2026, contractors and subcontractors on Article 8 projects must submit certified payrolls electronically through the New York State Department of Labor's Certified Payroll portal; paper is no longer accepted. The portal accepts manual entry or a bulk XML upload in the format described in the Department's bulk upload formatting guide.

Frequency. The Department requires reporting at least every 30 days throughout the life of a covered project, including weeks with no work. Most contracts call for weekly.

Data. The portal asks for each worker's name, home address, and the last 4 digits of the Social Security number. A worker with no SSN, or who does not know it, can be entered with a date of birth instead. Full SSNs are not collected.

Other differences. New York's prevailing wage schedules include supplemental benefit rates that function like fringe, and many crafts have their own overtime and holiday provisions. Employers on public work must post the schedule, and since December 30, 2024 every contractor and subcontractor on Article 8 work must register with the Department of Labor before starting work. Public work by or for New York City goes through the City's own certified payroll system, not the state portal. New York in detail.

Washington

Law. Chapter 39.12 RCW.

System. Washington's Department of Labor & Industries runs the Prevailing Wage Intent and Affidavit system. Contractors file a Statement of Intent to Pay Prevailing Wages before work starts and an Affidavit of Wages Paid at the end. For public works, certified payroll reports are submitted through L&I's online system, at least monthly for all prevailing wage jobs and weekly where the contract requires it.

Data. L&I's required payroll records include each worker's name and home address, trade and occupation including journey level or apprentice status, straight time rate, hourly rate of usual benefits, and hours worked including overtime by day and week. L&I's filing instructions and its XML upload guide also require each worker's full Social Security number. Washington in detail.

Other differences. Washington uses "usual benefits" as its fringe concept and publishes rates by county and trade twice a year. Apprentice utilization requirements apply to state projects over certain thresholds.

Illinois

Law. The Prevailing Wage Act, 820 ILCS 130. Since August 14, 2025 (Public Act 104-0160), it includes federal construction projects administered or controlled by a public body when the Illinois rate is equal to or greater than the Davis-Bacon rate for the same locality and type of construction.

System. Certified payroll is filed monthly with the Illinois Department of Labor through its Certified Transcript of Payroll portal, no later than the 15th of the month following the work. IDOL provides an import template.

Data. The transcript requires each worker's name, address, and telephone number, the last 4 digits of the Social Security number, classification, hours worked each day, hourly rate, gross, and fringe contributions, plus a signed statement of compliance. IDOL also collects each worker's race, ethnicity, veteran status, and gender for reporting.

Other differences. Illinois publishes rates by county and requires the contractor's payroll to identify the specific public body and project. Illinois in detail.

The rest

Six more states have their own forms and rules, each with a page of its own:

• New Jersey: form MW-562, filed through the NJ Wage Hub and with the public body within 10 days of payday.
• Pennsylvania: form LLC-25, weekly to the awarding body; the state Act does not apply to work covered by Davis-Bacon.
• Massachusetts: weekly to the awarding authority with worker addresses and the state's statement of compliance.
• Connecticut: form WWS-CP1, weekly sheets submitted monthly to the contracting agency.
• Minnesota: every 2 weeks to the contracting agency, with daily overtime after 8 hours.
• Oregon: BOLI form WH-38, weekly payrolls filed monthly with the public agency.

Ohio (state-funded work only), Nevada, Maryland, Hawaii and others have prevailing wage laws as well. Check the awarding body's bid documents, which say which law applies and how payrolls are submitted.

Jobs covered by both

Federal money in a state or local project usually brings the Davis-Bacon requirement alongside the state one. Where both apply, the project pays the higher of the 2 rates for each classification, and the certified payrolls are separate filings to separate recipients: the WH-347 without SSNs and addresses up the federal chain, and the state report with whatever the state requires through the state system. The same hours and pay appear on both.

The states do not all handle it the same way:

• Pennsylvania excludes work covered by Davis-Bacon from its own Act, so a federally funded job there files the WH-347 only.
• Illinois went the other way on August 14, 2025: Public Act 104-0160 put federal construction projects administered or controlled by an Illinois public body under the Illinois Act when the Illinois rate is equal to or greater than the Davis-Bacon rate for the classification. IDOL says contractors on those jobs upload certified transcripts of payroll to its portal (monthly) and that it will not focus enforcement on projects bid on Davis-Bacon rates before that date; more reporting guidance is promised. The weekly WH-347 still goes up the federal chain.
• Oregon accepts the federal WH-347 with its own supplement, form WH-38F, on jobs covered by both laws.

What this means for a small sub

If your public work is federally funded, one report format, the WH-347, covers you in every state, and it never carries SSNs or addresses. If you take state-funded work in California, New York, Washington, or Illinois, you will be entering worker data into that state's portal that the federal form forbids, and your recordkeeping has to hold it. Keep the two obligations distinct in your files and in your mind, and never put the state data on the federal form to save time.