University of California certified payroll requirements for contractors and subcontractors

On a University of California construction job you can owe two payroll filings, not one. UC's Facilities Manual says contractor and subcontractor payroll records must be certified and submitted electronically to the University, and DIR's exemption list does not include UC. If the project is registered with DIR and is not exempt, your own eCPR also goes to DIR.

Last reviewed against the sources it cites

The short answer

UC requires certified payroll records from the contractor and every subcontractor on its prevailing wage construction jobs, submitted electronically through the software UC designates. When the project is registered with DIR and is not exempt, you also file your own eCPR with DIR. The exemptions include small projects and projects covered by a qualifying project labor agreement, and UC is not on DIR's exemption list.

  • UC's Facilities Manual says contractor and subcontractor payroll records must be certified and submitted electronically to the University using designated software, at the times UC directs, per Volume 5, Chapter 14.
  • UC's Labor Compliance Program manual, dated January 1, 2012, covers UC public works projects awarded on or after that date that use California state bond funds and are not otherwise administered by DIR's Compliance Monitoring Unit, per the manual itself.
  • DIR's eCPR exemptions page names four legacy programs (Caltrans, City of Los Angeles, Los Angeles Unified, County of Sacramento) and qualifying project labor agreements, and does not name the University of California.
  • DIR's certified payroll reporting FAQ says submitting certified payroll to an awarding body or a Labor Compliance Program does not satisfy the requirement to submit it to the Labor Commissioner.
  • The same FAQ says a project must be registered with DIR on a PWC-100 form before contractors and subcontractors can submit certified payroll for it, and UC Procurement's prevailing wage page says the University files the PWC-100 form and puts the DIR Project ID number on the Purchase Order.
  • DIR's FAQ also exempts projects covered by a qualifying project labor agreement and projects under the small project exemption, which is $25,000 for new construction, alteration, installation, demolition or repair and $15,000 for maintenance.
  • Labor Code section 1771.4(a)(3) requires eCPR to DIR at least once every 30 days while work is performed, with a penalty of $100 per day capped at $5,000 per project that does not start until 14 days after the filing was due.

What UC requires

UC sets its own payroll rules for its construction and maintenance contracts. Volume 5, Chapter 14 of its Facilities Manual (updated March 16, 2026) says the contractor and all subcontractors must keep accurate payroll records, and that those records must be certified and submitted electronically to the University using designated software, at the times the University directs. The manual says "designated software" and, outside the one case covered below, does not name it. Ask UC which system it designated.

When UC requires prevailing wage

The manual says its guidelines cover construction and maintenance contracts over $1,000. UC requires prevailing wage when any state money is in the contract, when the contract uses UC contract documents, when UC owns the land and manages the project, or when UC will lease more than 50 percent of the assignable square feet. It can decline on some developer projects on UC land when no state money is involved and the project could not be built economically with prevailing wage. The contract decides.

UC's Labor Compliance Program and its 2012 manual

For projects funded in whole or in part by California state bonds and awarded after January 1, 2012, the Facilities Manual says UC runs a systemwide Labor Compliance Program, with monthly payroll review. The program document is UC's Labor Compliance Program manual, dated January 1, 2012. It covers projects not otherwise administered by DIR's Compliance Monitoring Unit (see our guide to that unit) and says:

  • The contractor and each subcontractor keep weekly certified payroll records for submittal to the UC Labor Compliance Office as required, but not less than monthly, with a statement of compliance signed by the contractor.
  • Weeks with no work need a Statement of Non-Performance, the last payroll is marked Final, and a copy of each DAS 140 goes in with your first payroll.
  • The contractor submits its subcontractors' payrolls, and UC may withhold any part of a payment until certified payrolls are properly submitted.

Read it as a floor, not a current rulebook

The manual is more than ten years old and some of its numbers have moved. It lists $25 per day per worker for payrolls not produced within 10 days of a request. Labor Code section 1776(h) now reads $100 for each calendar day per worker. From January 1, 2027, SB 909 raises this to $140 (see what SB 909 changes). DIR's Labor Compliance Program FAQ says the only statute that currently requires an approved program is Public Resources Code section 75075, for Proposition 84 projects, plus two covering certain projects awarded before January 1, 2012. One of them, Labor Code section 1771.7, names the University of California for contracts awarded before then that used the 2002 or 2004 Kindergarten to University bond acts.

DIR's approved program list (data as of October 15, 2026) has an entry for the University of California, approved August 11, 2003. Its note refers to use on "own CMU projects" from January 2012 to June 2014. Ask UC which system it designated and when it wants payroll.

Does UC's system replace your DIR eCPR filing?

No, not on a project that is registered with DIR and is not exempt. The link from a UC job to DIR runs through project registration. DIR's certified payroll reporting FAQ says a project must be registered with DIR on a PWC-100 before contractors and subcontractors can submit certified payroll for it. UC Procurement's prevailing wage page says that when a project requires prevailing wage compliance, the University files the PWC-100 form and puts the DIR Project ID number on the Purchase Order. The Facilities Manual also says the University applies provisions of the California Labor Code to certain University construction and maintenance contracts.

Then the exemptions decide it. DIR's exemptions page says only projects monitored and enforced by an approved labor compliance program, or covered by a qualifying project labor agreement, may be exempted from submitting certified payroll records to DIR. It names four programs: Caltrans, the City of Los Angeles, Los Angeles Unified School District, and the County of Sacramento. The University of California is not on it. DIR's FAQ also lists a small project exemption, covered below.

The same FAQ says that if you submit payroll to a union, the prime contractor, the awarding body, or a Labor Compliance Program, you still submit to DIR, because those submissions do not satisfy the requirement to file with the Labor Commissioner. That holds on a project that is not exempt.

Labor Code section 1771.4(a)(3) sets the clock. Each contractor and subcontractor furnishes payroll records directly to the Labor Commissioner, electronically on DIR's website, at least once every 30 days while work is performed and within 30 days after the last day of work, or more often if the contract says so. The penalty is $100 per day, capped at $5,000 per project, and it does not start until 14 days after the filing was due. See how often certified payroll is due.

UC copyDIR eCPR
Where it goesUC's designated softwareDIR's online certified payroll system
How oftenAs UC directs. The 2012 manual says not less than monthly.At least every 30 days while working, or as the contract says
Who filesContractor and each sub, or the contractor for its subs under the 2012 manualEach contractor and sub files its own

Small jobs use two different lines

The DIR FAQ's small project exemption covers public works projects that do not exceed $25,000 for new construction, alteration, installation, demolition or repair, or $15,000 for maintenance. UC's manual applies to contracts above $1,000. A small UC job can therefore carry a payroll duty to UC with no direct DIR filing. Check the contract amount against both lines, and see our thresholds guide.

Which system UC wants

The Facilities Manual names LCP Tracker for one case, projects pursuing Inflation Reduction Act funding. Otherwise it says "designated software". One campus, UCLA Capital Programs, lists LCP Tracker on its contractor links page under electronic certified payroll record systems. We found no list of which campus uses which system, so ask UC which system it designated. See LCPtracker vs DIR.

UC campus requirements pages

DIR's public project search lists UC projects under many awarding body names, so we keep pages for the ones we track. They are listed on the university requirements page and the public agency requirements page:

What to do before your first UC payroll

  1. Get the DIR Project ID. Use our Project ID guide. DIR's FAQ says a project must be registered on a PWC-100 before you can file. If UC has not registered it, ask UC to complete the registration. If it is still not registered, email publicworks@dir.ca.gov, as DIR's FAQ directs.
  2. Ask who uploads what. Ask UC or your general contractor which system UC designated, whether you upload yourself, and what schedule UC directs.
  3. File the eCPR on its own clock. At least every 30 days, or more often if the contract says. DIR's FAQ calls weekly the best practice.
  4. Cover idle weeks. UC's 2012 Labor Compliance Program manual requires a Statement of Non-Performance for idle weeks on projects it covers. DIR's eCPR XML Guidelines show how its system records one: you enter true for the statementOfNP element and include no employee elements. See no work performed.

Where we fit

A UC job means one payroll and two destinations. We take the half DIR requires. From your payroll export we prepare the federal WH-347 and file the DIR eCPR, plus the DAS 140 and DAS 142. A person reviews every filing, and you sign the certification. We never sign for you. Tell us which system UC designated and we will say plainly what we do and do not handle for it. Setup is $995 one time, first filing free, then $249 per month for crews up to 25 workers or $449 for 26 to 50 workers.

Questions

Does the University of California require certified payroll?
Yes, on the construction and maintenance contracts where it requires prevailing wage. UC's Facilities Manual says contractor and subcontractor payroll records must be certified and submitted electronically to the University using designated software.
Do I file with UC or with DIR?
Both, on a project that is registered with DIR and is not exempt. UC's copy goes into the software UC designates. The eCPR goes to DIR, which says submitting to an awarding body does not satisfy the requirement. UC is not among the four legacy programs on DIR's exemption page, but a small project or a qualifying project labor agreement can be exempt.
Is the UC Labor Compliance Program manual current?
It is the document UC's Facilities Manual still points to, and it is dated January 1, 2012. DIR says only the Proposition 84 statute now requires an approved program for new projects. Read your contract before relying on the manual's details.
What system does UC use for certified payroll?
UC's manual says designated software and names LCP Tracker for Inflation Reduction Act projects. UCLA Capital Programs also lists LCP Tracker. We found no system wide answer, so ask UC which system it designated.
Does a small UC job need a DIR eCPR?
Not under DIR's small project exemption: no more than $25,000 for new construction, alteration, installation, demolition or repair, or $15,000 for maintenance. UC's manual still applies its prevailing wage guidelines above $1,000, so a payroll duty to UC can remain.
Who signs the payroll on a UC job?
The contractor. UC's 2012 manual says each submittal comes with a statement of compliance signed by the contractor. We prepare and file, and we never sign for you. See who signs certified payroll.

Sources

Every figure on this page links to its source where it first appears. The full list, in order:

  1. Facilities Manual facilitiesmanual.ucop.edu
  2. exemption list dir.ca.gov
  3. registered with DIR dir.ca.gov
  4. the manual itself ucop.edu
  5. UC Procurement's prevailing wage page procurement.ucop.edu
  6. Labor Code section 1771.4(a)(3) leginfo.legislature.ca.gov
  7. manual says facilitiesmanual.ucop.edu
  8. DAS 140 dir.ca.gov
  9. Labor Code section 1776(h) leginfo.legislature.ca.gov
  10. SB 909 leginfo.legislature.ca.gov
  11. Labor Compliance Program FAQ dir.ca.gov
  12. Public Resources Code section 75075 leginfo.legislature.ca.gov
  13. Labor Code section 1771.7 leginfo.legislature.ca.gov
  14. approved program list dir.ca.gov
  15. applies provisions of the California Labor Code facilitiesmanual.ucop.edu
  16. UCLA Capital Programs capitalprograms.ucla.edu
  17. DIR's public project search services.dir.ca.gov
  18. eCPR XML Guidelines dir.ca.gov
  19. WH-347 dol.gov

Filing on a UC project? First filing free

Send the payroll export you already run. We turn it into the WH-347 and the DIR eCPR filing, checked by software and verified by a person. Your first weekly filing is free, before you pay us anything. $995 one time setup, then $249 per month flat.

Got it. We reply the same business day. Next: we confirm your payroll system and the project, you send one export, and your first filing comes back for your review before anything is submitted.

First filing free