Colorado certified payroll: state, CDOT and Denver jobs

What goes wrong first on a Colorado job

A state agency must not approve a payment demand until you show unpaid wages were paid (C.R.S. 24-92-204(1)(d)). Denver's overview says its Auditor's Office withholds payment when certified payrolls are not submitted in LCPtracker.

State agency projects of $500,000 or more

Part 2 reaches state agencies and institutions with construction contracting authority (24-92-201(1)). Part 2 applies to a contract for a public project awarded under part 1 of Article 92 and to an integrated project delivery contract for a public project awarded under Article 93 of Title 24 (24-92-202(1)). A public project includes construction, repair, demolition, improvement, operation and maintenance programs, and private work under a contract for an agency to rent, lease or purchase at least 50 percent of it (24-92-201(5); OSA). INFO #13 calls this broader than federal law.

Part 2 applies to projects bid on or after July 1, 2021, per the Colorado Department of Labor and Employment (CDLE) complaint form (December 2021). The form says "over $500,000"; the statute says "or more", and governs. Contracts must require weekly pay and an on-site daily log (24-92-204(1)).

What OSA asks you to do

1. Set up your account. OSA's Policies and Procedures (2025 edition by file name) have you return the SBP-2.6 setup form for your LCPtracker account.
2. Enter and certify weekly, per OSA's FAQ; the prime approves subcontractor data first.
3. Add the paperwork. In LCPtracker, submit a Contractor Fringe Benefit Statement per project and a deduction consent form per employee (OSA FAQ). Keep the SBP-2.7 daily log on site.

What holds your money

OSA's policies say no payment is made if there are "unpaid Certified Payrolls" for the pay application period, and final payment waits on unresolved restitution. Part 2 names no separate fine for a late payroll report; its fines cover willful violations, missing posters ($100 per calendar day, 24-92-207(2)) and willfully false wage representations ($1,000 to $3,000 each, 24-92-210(7)).

If a violation is alleged

Workers are directed to file first with the contracting agency (complaint form; INFO #13). Yet INFO #13's step table also has CDLE investigate a "complaint directly from employee", a path the form disclaims ("not to CDLE DLSS"). The statute calls for a CDLE complaint process (24-92-209(7)). The steps in 24-92-209 are:

1. Within 48 hours of a worker complaint or its own payroll analysis, the agency reports a perceived violation to you.
2. You have 15 calendar days to cure a legitimate administrative error. If it is uncured or willful, the agency refers it to CDLE.
3. On a willful finding, CDLE requires back pay and fines of $5,000, $10,000, then $25,000 for the third and later. After three willful violations in five years, three-year debarment is discretionary.
4. If the claim is unresolved 120 days after CDLE's initial determination, the worker may sue (24-92-209(6)), within three years of the violation, for unpaid wages, interest and equal liquidated damages (24-92-210(1), (5)).

Separately, 24-92-210(1) says an employee or former employee of a contractor or subcontractor may bring a civil action for a violation of 24-92-204 within three years after the alleged violation, and it states no waiting period.

Weekly or monthly? OSA's own documents use both

None explains how weekly entries become the monthly report. Certify every week, then ask the project manager what monthly submission your contract expects.

CDOT contracts

Part 2 does not apply to CDOT, but 24-92-202(2) requires a contractor on any CDOT public project, whatever the funding, to pay Davis-Bacon and related-act wages. CDOT's payroll page says every contractor enters and certifies payroll weekly in CDOT's LCPtracker, and the prime reviews subcontractor data. A missing classification needs DOL Form 1444 (see our SF-1444 guide). CDOT's FAQ and deductions guidance did not load, so this rests on its payroll page and the statute.

Denver contracts over $2,000

D.R.M.C. 20-76 covers contracts "in excess of" $2,000, change orders included, for drayage, construction, alteration, improvement, repair, maintenance or demolition by or for the city, financed by it, or on city property, and for custodial work (20-76(a), (b)). Denver Labor's page says "$2,000 or more"; the ordinance governs. It excludes dedicated-fund transfers to entities such as metropolitan districts, and downtown development authority projects (20-76(a)(3)).

The ordinance requires certified payroll copies each pay period (20-76(d)(5)); the overview says to submit weekly in LCPtracker. Denver Labor's tutorials send payroll to your assigned prevailing wage analyst for review, and a rejection notice comes from that analyst.

Denver penalties: the ordinance and the overview differ

The ordinance text, whose amendment history ends with Ord. No. 542-26 (May 11, 2026), is newer than the overview, whose footer reads "Updated 01/2025". Its editor's note exempts from 542-26 any project with a Department of Housing Stability Award Letter before June 1, 2026 (ask Denver Labor which text governs). The sources read do not say what 542-26 changed.

The overview lists different fines for unsubmitted payrolls, $10 to $100 per worker per week. Those are not in the ordinance, which is newer and governs. For underpayment, the overview also describes Denver's Civil Wage Theft Ordinance process, separate from 20-76(e) and not in the text read: 14 days to pay restitution, then 12% interest, and after 30 days 300% damages.

To dispute a determination, petition the Auditor for a hearing within 30 days of notice, a prerequisite to any later action (20-76(g)(1)).

Jobs outside the three tracks

School districts and other local governments. Part 2 excludes counties, cities, school districts and other political subdivisions (24-92-201(1)), as INFO #13 says. Check your contract.

Federally funded jobs outside CDOT. Part 2 does not apply (24-92-202(1)); the federal payroll rules apply (29 CFR 5.5(a)(3)(ii)(A)). See our WH-347 guide.

Energy sector projects (Part 3). Part 3 covers a project that generates, transmits or distributes electricity or natural gas for Colorado consumers, is built by or for a public utility, and is funded by the state or by utility customer funding approved in Public Utilities Commission proceedings on an electric resource acquisition or a certificate of convenience and necessity (24-92-303(5)(a)); some cooperative-funded work also counts. INFO #13 applies it to bids invited from January 1, 2024.

INFO #13 reads the size tests in 24-92-304(1)(b) as alternatives: generation of one megawatt or more, or storage of one megawatt of power or four megawatt hours, in a project funded by the state (24-92-303(5)(a)(I)(A)) with $500,000 or more of state assistance; or other listed types, such as electric transmission (24-92-303(5)(b)(II)), costing $1 million or more with $500,000 or more from the state, a utility or a cooperative. For generation, 24-92-304(1)(a) states the one-megawatt test with no dollar amount and (1)(b)(I) sets the $500,000 test for projects funded by the state; INFO #13's list does not mention generation projects funded another way. INFO #13 writes "more than $1,000,000"; the statute says "one million dollars or more". Exemptions include project labor agreements and a utility's own employees (24-92-304(1)(c)).

Where Part 3 applies, the lead contractor submits certified payroll for all contractors to the owner weekly (24-92-305(1)), and each quarter the owner or lead contractor sends craft labor certifications to CDLE (INFO #13).

We prepare certified payroll for public works contractors. Tell us about your project.

Questions