Caltrans CEM-2503 Statement of Compliance: what it says and who signs it

What the CEM-2503 is

The form is titled Statement of Compliance, and its header prints "DOT CEM-2503 (REV 12/2025)". Caltrans's form database lists the same revision as 12-01-2025 and shows "PDF Format: Not Offered." It offers the form only as a "LiveCycle Format" link, and the file at that link says it needs Adobe Reader 8 or higher. The database also lists "Instructions: Not Offered"; the instructions this page cites are printed on the form itself.

Manual chapter 13-3 says: "A payroll is not considered to be certified unless accompanied by the statement of compliance." Labor Code 1771.5(b)(3) lists "a certified copy of each weekly payroll containing a statement of compliance signed under penalty of perjury" among the requirements of a labor compliance program. The Caltrans checklists cite Labor Code 1776 for the CEM-2503 line, and the State Contract and Federal-Aid Contract versions add the Standard Specifications.

Who signs the CEM-2503

Item 1 of the form answers this. The signer swears "That I pay or supervise payment to employees of the contractor referenced on this form on the contract referenced on this form." The form lists no required title.

The manual says signing "declares under penalty of perjury that the information submitted in the payroll reports is true and correct to the best of their knowledge." That qualifier is in the manual, not in the form text you sign, which says employees "have been paid their full weekly wages earned" and payrolls are "correct and complete."

Labor Code 1776(a) and 2025 Standard Specifications 7-1.02K(3) both describe the sworn declaration as stating that the payroll information is true and correct (the specifications add "complete") and that the employer complied with Labor Code 1771, 1811 and 1815. The specifications also list a third item, that wage rates paid are at least those the Contract requires. The four sworn items on the CEM-2503 cite no Labor Code sections and are worded differently. This page read the 2025 Edition of the Standard Specifications only, so check which edition your contract names. If Caltrans asks for other wording, ask your Labor Compliance contact.

Where a contract carries the Davis-Bacon clauses, 29 CFR 5.5(a)(3)(ii)(C) has the statement signed by the contractor or subcontractor, or an agent "who pays or supervises the payment of the persons working on the contract." The 2025 Standard Specifications (3-1.13) say a federal-aid contract includes form FHWA-1273, and section III of that form repeats the clause at paragraph 3.b.(3). See who signs certified payroll in California.

The CEM-2503, field by field

The four sworn items

All four sit under "I do hereby certify under penalty of perjury:".

Item 1: wages, rebates and deductions

(1) That I pay or supervise payment to employees of the contractor referenced on this form on the contract referenced on this form. All persons employed on said project for the time period referenced on this form have been paid their full weekly wages earned, that no rebates have been or will be made either directly or indirectly to or on behalf of said contractor from the full weekly wages earned by any person and that no deductions have been made either directly or indirectly from the full wages earned by any person other than permissible deductions.

Item 2: payrolls and wage rates

(2) That any payrolls otherwise under this control required to be submitted for the period referenced on this form are correct and complete; that the wage rates for laborers or mechanics contained therein are not less that [sic] the applicable wages rates: (a) Specified in the applicable wage determination incorporated into the contract; (b) Determined by the Director of Industrial Relations for the county or counties in which the work is performed; that the classification set forth therein for each laborer or mechanic conform with the work he or she performed.

The instructions printed on the form say to check 2(a) for federal wage rates and 2(b) for State prevailing wage rates. The manual says contractors "may check both boxes if they are using both determinations." See Davis-Bacon plus California prevailing wage.

Item 3: apprentices

(3) That any apprentices employed in the period referenced on this form are duly registered in a bona fide apprenticeship program registered with a State apprenticeship agency.

Apprentice paperwork: DAS 140 and 142 on Caltrans jobs.

Item 4: fringe benefits

(4) That fringe benefits as listed in the contract: (a) Have been or will be paid to the approved plan(s), fund(s), or program(s) for the benefit of listed employee(s), except as noted in the following table. (b) Have been paid directly to the listed employee(s), except as noted in the following table. (c) See exceptions noted in the following table.

The printed instructions say to check 4(a) if you pay plans at least the determined amounts and 4(b) if you pay no fringes to a plan and pay the employee a like amount. Exceptions go in the table with the craft and hourly amounts.

The sources differ on mixing boxes. The manual says benefits "may also be paid as a combination of both or with noted exceptions," and the checklists say "Boxes must be marked indicating if benefits are paid to a fund and/or to the employee/employees." The LiveCycle form, though, clears the other two item 4 boxes when you tick one. LCPtracker's help says in its statement "some may have both already checked." If you mix, ask your Labor Compliance contact how to show it. Amounts come from your CEM-2501.

The electronic signature line

Above the signature boxes, the form prints:

I agree that by providing my electronic signature for this form, I agree to conduct business transactions by electronic means and that my electronic signature is the legal binding equivalent to my handwritten signature. I hereby agree that my electronic signature represents my execution or authentication of this form, and my intent to be bound by it.

On a contract that carries the Davis-Bacon clauses, 29 CFR 5.5(a)(3)(ii)(E) says the signature "must be an original handwritten signature or a legally valid electronic signature," as does FHWA-1273 at paragraph 3.b.(5).

The LCPtracker checklists (state, Revised 1/2026, and federal-aid, Revised 1/2026) refer to "the electronic Statement of Compliance." Neither LCPtracker checklist names the CEM-2503, and LCPtracker's help says the administrator's settings decide how its statement looks, so confirm which statement your project uses. See File Transfer or LCPtracker and LCPtracker eSignature problems.

When it is due

The State Contract and Federal-Aid Contract checklists without the LCPtracker Project heading (State, Revised 07/2025, Federal-Aid, Revised 1/2026) say the CEM-2503 "is due with each weekly payroll." The LCPtracker versions of those two checklists do not name the CEM-2503; see File Transfer or LCPtracker to tell which checklist your contract uses. The Maintenance, Services and Architectural and Engineering checklists (State, Revised 1/2026) carry it too.

On construction capital projects, chapter 8 lists payroll documents as due by the 15th for the previous month's work, says the payrolls become delinquent on the 15th, and advises weekly submission "to discover payroll discrepancies early." The same two checklists say documents not previously submitted are due by that 15th. Where your checklist names the CEM-2503, send it with each weekly payroll (the CEM-2502); on an LCPtracker contract, follow the electronic Statement of Compliance your checklist refers to. 2025 Standard Specifications 7-1.02K(3) also say to submit certified payroll records electronically through LCPtracker Pro, and File Transfer or LCPtracker sets out how Caltrans's documents differ on that. Chapter 16-3-2 lists "Signatures" among the missing required elements that make documents inadequate, without saying which document's signature; see the delinquent payroll notice.

On contracts invoiced in arrears, including service, A&E, Minor B and emergency, chapter 8 says payrolls are due with the invoice submission instead of by the 15th, and the Maintenance and Services checklists say documents "are due with invoice." Chapter 13-1 agrees for service contracts and leaves emergency and Minor B submittals to the contract provisions. Confirm yours with your Labor Compliance contact.

What WellStanding does

WellStanding prepares your Caltrans payroll documents from the payroll export you already run, and a person reviews them. You review and sign; the certification is always yours and we never sign for you.

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