Illinois certified payroll: how to file with IDOL and what a missed month costs
This page reads section 5 of the Prevailing Wage Act (820 ILCS 130/5, as amended by Public Act 104-23, June 30, 2025) with the Illinois Department of Labor's Certified Transcript of Payroll (CTP) page and FAQ, all read on November 4, 2026.
Last reviewed against the sources it cites
The short answer
Under the Prevailing Wage Act, contractors file with the Illinois Department of Labor by the 15th for the month before. IDOT contracts with BDE 109.13 or the Illinois-rate branch of BDE 109.15 also require weekly payrolls to IDOT; under the Davis-Bacon branch of 109.15 they replace the IDOL filing. Each missed month is a separate offense with a civil penalty up to $1,000 ($2,000 for a repeat within five years); willfully failing to file is a Class A misdemeanor.
- IDOL's Certified Transcript of Payroll FAQ (item 8) answers "No" when asked whether you must submit certified payroll to IDOL for a week with no work to report on a project.
- Section 5(d) sets a civil penalty of up to $1,000 for a first offense and up to $2,000 for a second or later offense within five years, and makes each month a separate offense.
- IDOL's Certified Transcript of Payroll FAQ says prior-month payrolls cannot be withdrawn from the portal after the 15th.
- Section 11a makes a contractor convicted or found guilty under section 5 or 6 subject to automatic four-year debarment with no right to a hearing.
- Section 5(a)(2) of the Prevailing Wage Act requires any contractor and each subcontractor who participates in public works to file a certified payroll by the 15th for the month before.
- IDOT's special provision BDE 109.13, revised April 2026 for state-only contracts on the state letting, requires weekly LCPtracker Pro payrolls to IDOT in addition to the monthly IDOL filing.
If you missed the 15th
The Prevailing Wage Act requires any contractor and each subcontractor who participates in public works to file by the 15th for the month before. The deadline is monthly, but the portal works by pay period: IDOL's training slides show it asking for a pay period's start and end dates, and the FAQ (items 13 and 14) covers pay periods that run a week or two weeks.
| Consequence | What the sources say |
|---|---|
| Civil penalty | Section 5(d): up to $1,000 for a first offense and up to $2,000 for a second or later offense within five years. Each month is a separate offense, and the officer, employee or agent whose duty is to file can be penalized too. IDOL's Prevailing Wage Act FAQ (item 12) says a failure to submit draws a Notice of Violation. |
| Misdemeanor | Section 5(a)(2): willfully failing to file by the due date, or willfully filing a payroll false as to a material fact, is a Class A misdemeanor. |
| Debarment | Section 11a: a contractor convicted or found guilty under section 5 or 6 is automatically debarred from public works for four years, with no right to a hearing. A second route: two violations within five years bring notice and 10 working days to ask for a hearing; silence means automatic placement on the published debarment list, and no public works contract for four years from publication. |
If you receive a notice
You can challenge a finding that you failed to file if IDOL receives a hearing request within 10 business days after you receive the notice. IDOL must show good cause: that you worked on a public works project and had not submitted by the 15th. Technical problems that stopped an on-time attempt are considered; not knowing the rule is not.
Where your payroll goes depends on who owns the job
| Job | Where the payroll goes | How often |
|---|---|---|
| Public works of any public body, or paid in part with public funds (section 2) | IDOL's portal. Section 5(a)(2) says payroll goes only there once the database is active. | Monthly |
| A state agency contract (the FAQ names IDOT, CDB and DNR) | IDOL's FAQ (item 5) tells contractors to assume a state agency contract is a state capital project and mark the box in the portal. Section 5(a)(2) lets an agency opt to take payrolls itself; no source read names one that has. | Monthly |
| Federal construction run by a public body, Illinois rate at least the federal rate (section 2); IDOL expects contracts bid after August 14, 2025 to conform | IDOL's HB 1189 FAQ (item 4) says a contractor whose project carries Illinois rates should upload certified payrolls to the portal. Where there is no corresponding Illinois determination or trade classification, the Davis-Bacon rate applies (items 5 and 6). In this initial implementation phase, IDOL says it will not focus enforcement resources on federally funded projects where the bid was previously formulated and selected based on Davis-Bacon rates (item 2). | Monthly under section 5 once section 2 makes the job public works; IDOL says more reporting detail is forthcoming |
| IDOT state-only contract (BDE 109.13), or federal-aid contract where the IDOL rate is equal or higher (BDE 109.15) | IDOL's portal by the 15th, and "in addition" a weekly payroll to IDOT through LCPtracker Pro. | Monthly to IDOL, weekly to IDOT |
| IDOT federal-aid contract, Davis-Bacon rate higher | Under BDE 109.15, only the Davis-Bacon Act applies, so the weekly payroll to IDOT through LCPtracker Pro replaces the IDOL filing. | Weekly |
BDE 109.15 took effect April 1, 2026, and BDE 109.13 was revised that day. Their designer notes put 109.13 in state-only funded contracts and 109.15 in federal aid contracts, both on the state letting. The designer notes do not say whether they reach a local-agency letting; see the last item under "Where the sources disagree" below, and read your contract.
The last two rows split federal-aid contracts by comparing rates "for the same type of construction," as BDE 109.15 puts it. IDOL's HB 1189 FAQ (item 6) tests each trade classification instead. If some trades on a federal-aid job fall on each side, check the contract's special provision and ask IDOT which filing applies.
IDOT's Construction Memorandum 14 (effective August 23, 2019, expiry "Indefinite") covers federal-aid contracts with US Department of Labor wage decisions. It has weekly payrolls go on form SBE 48 or an approved facsimile, with a signed SBE 348 statement, to the Resident or District Labor Compliance Representative. It makes the prime contractor responsible for submitting copies of every subcontractor's payrolls, says they should be received within 7 days of the payment date, and says that after 4 consecutive missed payroll periods the contractor has 7 days to submit before contract payments are withheld. The Davis-Bacon branch of BDE 109.15 instead has the contractor and each subcontractor submit weekly through LCPtracker Pro, and the BDE text read states no receipt deadline and no withholding step. So the two differ on who transmits (the prime for its subcontractors under the memo, each firm under the BDE), on the 7-day receipt expectation and on the payment-withholding remedy. Nothing read reconciles them or says the memo was withdrawn, and the memo does not reach BDE 109.13 or the Illinois branch of 109.15. Follow your contract's special provision, and ask IDOT in writing which rule it applies. For the federal side, see our WH-347 guide and FHWA-1273 changes.
Where the sources disagree
- Public body or IDOL? IDOL's Contractor FAQ (question 3) still says payroll goes to the public body; IDOL's January 2025 press release says IDOL has taken payrolls since 2020. Section 5(a)(2) sends payroll only to IDOL's database once it is active, and the portal is live, so the filing goes to IDOL unless a state agency has opted to take payroll itself or your contract says otherwise.
- Subcontractor through the general contractor? The CTP FAQ (item 10, undated) says a subcontractor may keep giving payroll to the general contractor, though IDOL recommends its own filing because liability falls on the individual contractor. Section 5(a)(2) puts the filing duty on any contractor and each subcontractor who participates in public works, so make your own filing. The same paragraph says a general contractor is not prohibited from relying on a lower-tier subcontractor's certification unless it knowingly relies on a false one; that is about the general contractor's reliance, not a substitute for the subcontractor's filing. A footnote on the fringe-benefit step of IDOL's training slides (file name 2026, no date in the text) reads "Subcontractors must file their own CTP, this form needs to be updated." A general contractor can request the emailed PDF copy or search the database (FAQ item 11).
- Davis-Bacon? The CTP FAQ (item 1) says a contract that mentions Davis-Bacon need not go to IDOL. But since HB 1189 (effective August 14, 2025), a federal job run by a public body can carry Illinois rates, and IDOL's HB 1189 FAQ (item 2) says projects bid after that date should conform (third row above). Where there is no corresponding Illinois determination, the Davis-Bacon rate applies (item 5), and IDOL says more reporting detail is forthcoming (item 4). Ask the public body which rate sheet applies.
- Local-agency lettings? IDOT's Local Roads and Streets manual, chapter 12, section 12-2.01(e) (dated November 2018, for MFT and state-funds lettings), says the contractor and each subcontractor submit a certified payroll monthly to the local public agency, and calls a known-false payroll a Class B misdemeanor. That predates IDOL's portal, which began taking payrolls in 2020, and section 5 now says Class A and sends payrolls to IDOL's database, so section 5 controls. If your job is a local-agency letting, ask the local agency or IDOT which track your contract uses.
If you have no work to report
IDOL's FAQ (item 8) asks whether you must submit certified payroll if you have no work to report on a project for a week. The answer is "No." IDOL's training slides agree: "A No Work Report is not required by the Act." Section 5(a)(2) fits that: a payroll "must be filed for only those calendar months during which construction on a public works project has occurred." Section 5(d) measures a missed filing the same way, by the "immediately preceding month in which the public works were performed by the contractor or subcontractor."
So the FAQ, the slides and the statute all point one way: no work to report, no IDOL filing for that period. One gap is left. If other trades worked on the project in a month when your own crew did none, section 5(a)(2) speaks of months in which construction on the project occurred, section 5(d) counts months in which you performed the work, and the FAQ answers for a week, not a month. If that is your situation, ask the IDOL contact below before you skip the month. A contract that carries BDE 109.13 or 109.15 is different: for an inactive week it requires a "No Work," "Suspended" or "Complete" payroll to IDOT.
Filing in the IDOL portal
- Make an account. Create an Illinois Public ID account and choose "Public Account," as IDOL's Certified Transcript of Payroll page directs.
- Start one payroll per project and pay period. The FAQ (items 16 and 17) says each project is submitted separately and two companies need two logins. Enter a worker once per classification (item 7), report hours worked outside the project (item 3), and on a two-week period report net pay on the second week (item 14).
- Enter or upload. IDOL's page links an Excel template for use from July 1, 2025; the training slides describe a CSV. For pay periods that do not run Monday through Sunday, FAQ item 13 says "The excel template order cannot be changed."
- Add the fringe document. The slides require a document here, and do not name it, unless the payroll is a No Work Report. The No Work Report box is optional: the slides say the Act does not require one. IDOL's page lists a Fringe Benefit Affidavit asking for each fund's name, address, sponsor and administrator.
- Certify and save. The signer agrees to the certification and types a first and last name. The portal emails a PDF and a CTP number to the contractor.
Section 5(a)(2) requires a signed statement that the records are true, no rate is below prevailing, and a knowingly false filing is a Class A misdemeanor. Read the payroll before whoever certifies signs.
Corrections and who to contact
You can withdraw a payroll for the current month due and wait for IDOL's review. The FAQ (item 4) says prior-month payrolls cannot be withdrawn after the 15th and gives no other correction path. IDOL's CTP page lists dol.certifiedpayroll@illinois.gov as the contact, and the slides add 217-725-5455.
Other states
To compare Illinois with other states, use our state-by-state table. We prepare certified payroll for public works contractors. Tell us about your project.
Questions
Do I file certified payroll every week in Illinois?
Do I file when I have no work to report?
Can I fix a payroll after the 15th?
Can my subcontractor give its payroll to me instead?
Sources
Every figure on this page links to its source where it first appears. The full list, in order:
- section 5 of the Prevailing Wage Act ilga.gov
- Certified Transcript of Payroll (CTP) page labor.illinois.gov
- FAQ labor.illinois.gov
- BDE 109.13 apps1.dot.illinois.gov
- BDE 109.15 apps1.dot.illinois.gov
- Section 11a ilga.gov
- training slides labor.illinois.gov
- Prevailing Wage Act FAQ labor.illinois.gov
- section 2 ilga.gov
- HB 1189 FAQ labor.illinois.gov
- Construction Memorandum 14 idot.illinois.gov
- Contractor FAQ labor.illinois.gov
- January 2025 press release labor.illinois.gov
- Local Roads and Streets manual idot.illinois.gov
- Fringe Benefit Affidavit labor.illinois.gov