Prevailing wage recordkeeping: the audit ready checklist
An audit ready file comes down to five things: a certified payroll record for every week worked, the time records behind it, a Statement of Compliance signed under penalty of perjury, your apprenticeship and fringe benefit backup, and all of it kept at least three years and available at your principal office. Below is the full checklist, with the rule behind each line, starting with Labor Code section 1776.
What "audit ready" actually means
Audit ready means the file is already in this shape before anyone asks. On a California public works job, four parties can ask to see it: the awarding body's own staff, the Division of Labor Standards Enforcement through a written request under Labor Code 1776, the general contractor's compliance monitor or portal, and, on federally funded work, the U.S. Department of Labor. Each is checking the same underlying record, so building it once, correctly, covers all four.
The checklist
| Record | What it has to show | Source |
|---|---|---|
| Certified payroll record | Name, address, Social Security number, classification, straight time and overtime hours each day and week, and actual wages paid, filed as the federal WH-347 or the state eCPR | Labor Code 1776(a); the same fields plus rates and fringe contributions under 29 CFR 5.5(a)(3)(i)(B) |
| Statement of Compliance | A declaration, signed under penalty of perjury, that the record is accurate and that the wage laws for the work performed were followed. In practice, this should be someone authorized to bind the company. On the WH-347 it is page two, and it carries its own federal exposure for a false statement | Labor Code 1776(a); on the federal WH-347, dol.gov notes the same certification is made subject to 18 U.S.C. 1001, a fine, imprisonment of not more than five years, or both |
| Underlying time records | The daily time cards or schedules the certified hours were built from. Comparing the two is usually the first thing a reviewer does | Good practice, not a single statute. This is the record that makes every other one defensible. |
| Deduction records | Every deduction taken from a paid wage | Listed as a required field, alongside actual wages paid, under 29 CFR 5.5(a)(3)(i)(B) on federally funded work; the eCPR form captures the same field on state jobs |
| Apprenticeship paperwork | The DAS 140 contract award notice, any DAS 142 dispatch requests, and the apprenticeship program's response to each request | The forms themselves are at DIR, Public Works Apprentices; see DAS 140 and DAS 142, explained for the deadlines and the penalty that attaches to each |
| Fringe benefit statements | Proof of any fringe benefit paid through a plan or program rather than cash, matching the rate claimed on the certified payroll | Labor Code 1773.1(b) credits a fringe payment three ways: an irrevocable contribution to a trustee or third person under a plan, fund, or program; the reasonably anticipated actual cost of a self-funded benefit under a written, enforceable commitment; or a payment to the California Apprenticeship Council under Labor Code 1777.5; see the fringe benefit statement guide |
| Wage determination | The prevailing wage determination for the trade, area, and period, matching every classification used | Set under Labor Code 1773, which requires the awarding body to obtain the prevailing rate for each craft, classification, or type of worker in the locality where the work is performed |
| Contractor registration | Proof of current DIR public works contractor registration for the fiscal year worked | Labor Code 1725.5 sets the initial application fee and the annual renewal fee due on or before July 1; see DIR contractor registration, fees and renewal |
| Records location notice | Written notice to the awarding body of where the records are kept, and of any change of location | Labor Code 1776(g), within five working days |
How long to keep everything
Two clocks run at once, and you keep to whichever one is longer. California's general wage record statute sets the floor: payroll records must be kept on file for not less than three years, under Labor Code section 1174(d). Section 1776 does not set its own retention period, so this floor governs a state-only job, run from the week worked.
Federal money changes the clock. Under 29 CFR 5.5(a)(3)(i)(A), records on a Davis-Bacon job must be preserved for at least three years after all the work on the prime contract is completed, not three years from each week worked, and that clock does not start until the whole contract is done, including other subs' work. If you work both kinds of jobs, treat three years from the week worked as your minimum and let the federal clock run longer wherever it applies. See the retention guide for edge cases.
Where the records have to live
The records must be available for inspection at all reasonable hours at your principal office (Labor Code 1776(b)). Tell the awarding body that address, and if it changes you have five working days to send notice (Labor Code 1776(g)). A request that goes to a stale address is still a request, and it still starts the 10 day clock under Labor Code 1776(h).
The self-audit: nine questions before anyone else asks them
- Does every week worked on this project have a filed certified payroll record, including no-work weeks? See certified payroll deadlines and how to catch up if not.
- Do the hours on the certified payroll match your time cards, for every worker, every day? A mismatch is the most common finding, because it is the easiest comparison to run.
- Is the Statement of Compliance signed, for every week filed, by someone with documented authority? An unsigned certification is not a certified record.
- If you paid fringe benefits through a plan, do you have the plan documents or trust statements behind the rate? See the fringe benefit statement guide.
- If the trade is apprenticeable, do you have a DAS 140 and a DAS 142 for every dispatch relied on? See DAS 140 and DAS 142, explained.
- Are training fund contributions paid and documented against the same hours reported?
- Does the awarding body have your current records address on file, matching what you actually sent?
- Is your DIR contractor registration current for the fiscal year worked? See registration fees and renewal.
- Could you produce every record above within 10 days of a request, starting today? See the 10 day records request guide if not.
Where files actually fail
The same handful of gaps show up again and again once a file is reviewed.
- Time cards and certified payroll that do not reconcile, from rounding, an uncorrected hour, or a mismatched classification.
- No record for a no-work week. A gap in the sequence reads the same as a missing filing.
- A fringe rate claimed with no statement behind it. The number on the payroll is only half the record.
- Apprentice hours below the ratio with no DAS 142 or program response on file.
- An address on file with the awarding body that is not where the records actually sit, costing days off the 10 day clock when a request is redirected.
What each of these can cost once it turns into a finding is laid out on certified payroll penalties in California.
Keeping the file current instead of reconstructing it later
The checklist above describes a state, not a project. Stay in that state by building the record once a week from the payroll export you already run, rather than reconstructing it from memory when a request lands. We take your export from QuickBooks, ADP, Paychex, Gusto, or Sage and produce the WH-347 and the DIR eCPR filing every week, with the DAS 140 and DAS 142 alongside them, and a person reviews every filing before it goes out. You still sign the Statement of Compliance yourself, since that certification is yours to make. Setup is $995 one time, then $249 a month for crews up to 25 workers or $449 for 26 to 50, and your first filing is free.