PWC-100 explained: what it is and why your project might not be registered

What the PWC-100 is

DIR's own instructions call it Web form PWC 100, PWC-100 for short. It is an electronic form, not a paper filing, and it is how an awarding body, a city, county, school district, water district, state agency, or any other public entity, tells DIR that a public works contract exists. Once DIR has that record, the project gets a DIR Project ID. That ID is what the eCPR system checks for before it will let anyone file a certified payroll record against the job.

Think of it as project registration, separate from your own company's contractor registration. You register your company once a year. The awarding body registers each project, one PWC-100 per contract.

Who files it

The awarding body files the PWC-100. Not the general contractor, not you as a subcontractor. Labor Code section 1773.3(a)(1) puts the duty on the awarding body in plain terms: it "shall provide notice to the Department of Industrial Relations" of the contract. There is no version of this where a sub is supposed to be the one filing it, and DIR's own eCPR guidance confirms it plainly: an awarding body must submit a PWC-100 before you can submit an eCPR at all, according to DIR's eCPR FAQ.

What goes on the form

The PWC-100 asks for the facts that let DIR and the Labor Commissioner track a project from bid to close, per the statute and DIR's field by field instructions:

• Contractor identity. The general contractor's business name, CSLB license number, and the registration number DIR assigned under Labor Code section 1725.5.
• Subcontractor identity. The license number, name, and worker classification for each subcontractor named on the successful bid. Labor Code section 1773.3(a)(3) separately requires the notice to include each such subcontractor's own DIR registration number issued under Section 1725.5.
• Contract facts. Contract and project numbers, the bid advertisement date, the award date, the actual contract amount, and estimated total project cost.
• Jobsite and schedule. The project location, the county, and estimated or actual start and completion dates.
• Funding and labor terms. Any state bond source and amount, whether a DIR-approved labor compliance program covers the job, and whether a project labor agreement applies.

Questions about a specific PWC-100 go to DIR's Compliance Monitoring Unit at cmu@dir.ca.gov, per the instructions. If you are chasing down an audit letter from that same unit, see our guide to the DIR Compliance Monitoring Unit.

The deadline, and which projects it applies to

The awarding body has 30 days from the contract award to file the PWC-100, and no later than the first day a contractor has workers on the job, whichever comes first, under Labor Code section 1773.3(a)(1).

The requirement only reaches contracts above a dollar line. Under section 1773.3(j), it applies to construction, alteration, demolition, installation, or repair contracts over $25,000, and maintenance contracts over $15,000. Below those lines, there is no PWC-100 to chase and, correspondingly, no eCPR duty either.

What happens when it is late or missing

Two different people carry two different consequences here, and they are not each other's problem.

For the awarding body: a civil penalty of $100 per day for each day the PWC-100 is late, capped at $10,000 for the project, under section 1773.3(c)(1). The Labor Commissioner can waive the penalty for a first, unintentional violation that did not get in the way of enforcement, under section 1773.3(c)(2). The statute also requires an awarding body to withhold final payment to the contractor until at least 30 days after it has submitted the full subcontractor list DIR requires, under section 1773.3(d), and adds a separate penalty, up to $100 a day for up to 100 days per unregistered contractor or subcontractor, if the awarding body makes that final payment and an unregistered contractor or subcontractor is later found to have worked on the job.

For you as the contractor or subcontractor: the statute is explicit that you carry none of that liability. Section 1773.3(h) says a contractor or subcontractor is not liable for penalties assessed against an awarding body under this section, and the awarding body cannot make you indemnify it either. Your actual problem is practical, not financial: DIR's eCPR system will not recognize a project that has no PWC-100 on file, so you cannot submit certified payroll at all until it does.

What to do if your eCPR says the project is not registered

1. Look up the DIR Project ID first. Before assuming nothing was filed, use the public works project search inside DIR's Public Works portal. A project can exist under a contract or project number that does not match what you were given.
2. If you were on the bid but are not listed, add yourself. DIR's eCPR FAQ notes that subcontractors often are not listed on the PWC-100 because the awarding body did not yet know every sub when it filed. If the project is registered but you are not on it, the eCPR system lets you add your own information and file from there.
3. If the project genuinely is not registered, put it in writing. Tell the general contractor or the awarding body's contract administrator, in writing, that DIR shows no PWC-100 and that you cannot file until one exists. Reference Labor Code section 1773.3 by name; it gives you something concrete to point to that is not a guess about internal process.
4. Keep your own records moving regardless. The duty to keep certified payroll records under Labor Code section 1776 does not pause because the awarding body is behind on its own paperwork. Prepare your payroll records on your normal schedule so you are ready to file the eCPR the moment the project shows up.
5. Escalate if the delay drags on. DIR's Compliance Monitoring Unit handles PWC-100 questions at cmu@dir.ca.gov. A dated email showing you tried is worth more later than a memory of a phone call.

This is exactly the kind of dead end that swallows an afternoon: you export payroll from QuickBooks, ADP, Paychex, Gusto, or Sage, sit down to file, and the portal tells you the project does not exist. We check project registration status as part of preparing every filing, so a missing PWC-100 gets caught and chased down instead of discovered at the deadline. The first filing is free, and read our full walkthrough of how the DIR eCPR system works for the rest of what can bounce a filing once the project is actually registered.

Questions