When certified payroll is due, and who gets it

Your first week on a Davis-Bacon job is done and the prime's project manager is asking for your payroll. Here is what the federal rules require, and where the prime's own schedule fits.

How often is certified payroll submitted?

Weekly. The contract clause at 29 CFR 5.5(a)(3)(ii)(A) says the contractor or subcontractor "must submit weekly, for each week in which any DBA- or Related Acts-covered work is performed, certified payrolls." The Copeland Act regulation at 29 CFR 3.3 says the same thing from the other side: each week you provide a copy of your payroll for the "preceding weekly payroll period," with a signed statement of compliance.

The pay cycle has to keep up. Section 5.5(a)(1)(i) requires covered workers to be paid "not less often than once a week." A company that pays every 2 weeks off the job still has to pay its Davis-Bacon crew weekly, and each of those weeks gets its own payroll.

Weeks with no covered work are a separate question. No-work weeks.

When is it due?

Within 7 days after the regular pay date for the payroll period. This comes from 29 CFR 3.4(a), which says each certified payroll "must be delivered by the contractor or subcontractor, within 7 days after the regular payment date of the payroll period," to the agency's representative at the site, or, if there is none, by mail or any other means that normally assures delivery to the agency within the same 7 days.

The clock starts on the pay date. The week-ending date on the form is the last day of the workweek. The pay date is the day the crew is paid for that week, which is often a few days later. The 7 days run from the second date.

Who do I send it to?

The regulation names 2 possible recipients:

• The federal agency, when the agency is a party to the contract (a direct federal contract).
• The applicant, sponsor, owner, or other entity that keeps the payrolls and transmits them to the agency, when the agency is not a party. This is the usual case on federally assisted work, such as a city building a project with federal grant money.

A subcontractor sends its payroll to the prime. The same paragraph says "the prime contractor is responsible for the submission of all certified payrolls by all subcontractors," so subs deliver to the prime and the prime transmits the package. What the prime is responsible for.

The agency or the prime may require submission through an electronic system, as long as the system takes a legally valid electronic signature and the agency or prime allows another method for a contractor that can't use it.

The prime's cutoff comes first

The prime has to collect payrolls from every sub, check them, and get the full set to the agency on time. So subcontracts commonly set an earlier deadline for subs. That deadline is a contract term, and it's the one you work to.

Read the payroll section of your subcontract before the first week ends, and ask the prime 3 things: the day and time payrolls are due, how to deliver them (portal, email, or paper with an ink signature), and who to call when one will be late.

A worked example

Your crew's workweek runs Sunday to Saturday, and you pay on Friday for the week before.

• Workweek: Sunday, October 4, 2026 through Saturday, October 10, 2026.
• Week ending date on the WH-347: October 10, 2026.
• Regular pay date: Friday, October 16, 2026.
• Federal deadline under 29 CFR 3.4(a): 7 days after October 16, so by Friday, October 23, 2026.

If your subcontract says payrolls are due to the prime by the Tuesday after pay day, your real deadline is Tuesday, October 20. Missing the prime's date while making the federal one still puts you in breach of the subcontract.

What if a week's pay date moves?

The regulation counts from the "regular payment date." It does not say what happens when a holiday moves pay day for 1 week, so take the earlier date and tell the prime.

Example: Christmas, Friday, December 25, 2026, falls on your regular pay day for the week ending Saturday, December 19. You pay on Thursday, December 24 instead. Counting 7 days from the regular Friday gives January 1, 2027, itself a holiday. Counting from the day you actually paid gives Thursday, December 31. File by December 31 and nobody can argue the payroll was late.

If you change pay days permanently, tell the prime in writing before the change, so the new day becomes your regular payment date on the record.

When is the first payroll due?

Payroll number 1 covers the first workweek in which your crew does covered work on the project. The WH-347 instructions say to number payrolls starting with "1" for each project, and you keep counting from there to the final payroll, where you check the "Submission of final DBRA certified payroll form" box.

The first payroll is due on the same schedule as every other one: 7 days after the regular pay date for that first week, or earlier if the prime says so. It is also the first time the prime sees your classifications, rates and fringe, so any setup mistake shows up here. Get the wage determination from the prime before the crew starts, and send the first payroll a day early if you can, so there's time to fix it before the deadline. How to fill out the WH-347.

What makes payrolls late

Timecards that arrive after pay day, a signer working on another site, or a prime that wants the ink-signed original by mail can each cost a day. Set a weekly routine around your pay date. Close timecards, run payroll, fill the WH-347, sign page 2, and send it the same day you pay. The free fillable WH-347 works for a small crew; CertifiedHours sends a reminder 2 days after a week ends without a filed payroll.

A payroll that is late or missing has consequences for the prime's payments and eventually yours. Penalties and withholding.