Is DIR registration required for federal only projects?
No, if the federal government awarded and fully controls the project. Yes, if a California state or local agency runs the project, even when the money behind it is federal. DIR states this directly in its public works FAQ: "Registration is not required for projects that are awarded by and under the complete control of the federal government."
The test is control, not the source of the money
DIR's FAQ answers the narrow "Davis-Bacon only" question directly, under "Is a contractor who only does Davis-Bacon work under federal contracts required to register?": "Registration is not required for projects that are awarded by and under the complete control of the federal government. However, federally funded or assisted projects that are controlled or carried out by awarding bodies in California are subject to the state's prevailing wage laws and therefore require registration." A separate entry on the same DIR FAQ, under "If an awarding body is awarded a contract directly by a federal agency, must it comply with California public works law?", adds the detail subs usually miss: those same federally funded or assisted projects, "including most highway construction projects, are subject to the state's prevailing wage laws."
That lines up with how California defines a public work in the first place. Labor Code section 1720(a)(1) defines public works as "construction, alteration, demolition, installation, or repair work done under contract and paid for in whole or in part out of public funds." The statute never asks whose stamp is on the money, only whether public funds paid for the work and who is running the contract. A federal grant or federal loan that flows through a state agency, a city, a county, a school district, or a water district still counts as public funds once it lands in that agency's contract. Our federal vs state certified payroll guide walks through this side by side with Davis-Bacon.
Three scenarios, and which one you are on
| Who awards and runs the job | DIR registration | What you file instead or in addition |
|---|---|---|
| A federal agency itself: GSA, the VA, the Army Corps of Engineers, the Postal Service, a national park, a federal courthouse | Not required | WH-347 to the contracting federal agency, under Davis-Bacon |
| A California state or local awarding body running a project funded in part by a federal grant, loan, or insurance program, for example a city street project or a school modernization with federal dollars in the funding stack | Required | eCPR to DIR, plus WH-347 if Davis-Bacon is also triggered on the federal side |
| A California awarding body running a project with mixed state, local, and federal funding and no single source paying for all of it | Required | eCPR to DIR. California's prevailing wage rate applies when it exceeds the corresponding Davis-Bacon rate |
Notice what does not appear anywhere in that table: the size of the federal check. A project can be almost entirely federally funded and still owe full California registration and eCPR filing, because the question DIR asks is who signed the contract and who administers it, not who wrote the biggest check.
What "Davis-Bacon only" actually describes
The phrase in DIR's own FAQ, "a contractor who only does Davis-Bacon work under federal contracts," describes a narrow group: contractors whose contracts are awarded directly by a federal agency and administered by that agency start to finish. It does not describe every contractor who happens to be paid prevailing wage on a job with federal money in it. If your contract lists a city department, a county, a school district, or a state agency as the awarding body, and the wage rates on the job are prevailing wage, you are very likely in the second row of the table above regardless of where the funding originated.
The fastest way to check is to look at the contract itself, not the funding source line in a budget document. Find the entity that signed as the awarding body and issued the notice to proceed. If that entity is a federal agency, you are in the federal-only lane. If it is any California public entity, DIR's registration and eCPR requirements apply the same way they would on a project with no federal money at all.
The small project exemption applies regardless of funding
Size, not funding source, is the other thing that changes the answer. Under the same DIR FAQ, the certified payroll reporting requirement carries "a small project exemption" for "all public works projects that do not exceed: $25,000 for new construction, alteration, installation, demolition or repair" or "$15,000 for maintenance." A California-controlled project under those thresholds does not require eCPR submission, federal money or not. DIR is explicit that this cannot be gamed: "the law does not permit jobs to be parceled in order to avoid the applicable thresholds," so splitting one job into several small purchase orders does not move you into the exemption. See our project thresholds guide for how this interacts with the separate $1,000 threshold for prevailing wage coverage itself under Labor Code 1771.
Legacy Labor Compliance Programs are a separate exception
Federally assisted highway and transit work in California is often routed through Caltrans, which is one of four agencies DIR still lets run its own approved Labor Compliance Program instead of eCPR submission to DIR directly. DIR's certified payroll reporting exemptions page lists the four: Caltrans, the City of Los Angeles, the Los Angeles Unified School District, and the County of Sacramento. Projects those agencies monitor are exempt from submitting certified payroll to DIR because the agency's own program does the monitoring instead. This exemption is about where the payroll record goes, not about registration, so do not read it as a reason to skip DIR contractor registration. See the Caltrans requirements page for how that legacy program actually works, and WH-347 vs eCPR for how the two filings relate when a project is federally assisted and state controlled.
A four step check for your own project
- Find the awarding body. Read your contract or purchase order for the entity that awarded it, not the entity that funded it.
- Ask if that entity is a federal agency. If yes, and the federal agency administers the job start to finish, DIR registration is not required for that project.
- If it is a California entity, check for a legacy LCP. Caltrans, the City of Los Angeles, LAUSD, and the County of Sacramento file certified payroll through their own programs instead of eCPR.
- Otherwise, assume both apply. DIR contractor registration and eCPR filing to DIR, on top of any WH-347 the federal funding side also requires. Our contractor registration guide covers the fees and renewal cycle, and the DIR eCPR system guide covers how the filing itself works.