WH-347 vs eCPR: two governments, two filings
Contractors who work both federal and California public jobs meet two different certified payroll regimes wearing the same name. Here is which is which, which projects need both, and the places where the two flatly contradict each other.
The one-paragraph version
The WH-347 is the federal certified payroll form under the Davis-Bacon Act, due weekly on federally funded or assisted construction, submitted up your contracting chain. The eCPR is California's electronic certified payroll record under its own prevailing wage law, due directly to DIR at least monthly on registered public works, filed under your own contractor registration. They are enforced by different agencies, keyed to different wage determinations, and neither satisfies the other. A California project with federal money in it requires both, on their own schedules, in their own formats.
Which law applies: Davis-Bacon or California prevailing wage
Two separate laws decide whether you owe a filing at all, and they trigger on different facts, not just different money. The federal Davis-Bacon and Related Acts reach contractors and subcontractors on federal or federally assisted construction, alteration, or repair contracts over $2,000, where "federally assisted" means a federal agency put money in through grants, loans, loan guarantees, or insurance, not necessarily a direct federal contract. California's own prevailing wage law reaches further and does not care where the money came from: under Labor Code section 1720, "public works" is construction work done under contract and paid for in whole or in part out of public funds, state or local, with no federal dollar required.
Run both tests on your own project, because they are independent. A city street resurfacing paid entirely from local funds meets California's public works definition on its own and owes the eCPR, but if no federal grant or loan touches it, the $2,000 Davis-Bacon threshold never applies, so there is no WH-347. A transit platform built partly with a federal grant crosses both tests at once: the federal assistance pulls in the WH-347, and public funding of any kind pulls in the eCPR. That double covered case, not the single covered one, is where most subs asking this question actually live.
Side by side
| Form WH-347 | DIR eCPR | |
|---|---|---|
| Law behind it | Davis-Bacon Act and related federal acts | California Labor Code, including section 1771.4 |
| Trigger | Federal or federally assisted construction contracts over $2,000 | Registered California public works subject to prevailing wage |
| Cadence | Weekly, under the Copeland Act | At least monthly, or more often when the contract says so (DIR FAQ) |
| Where it goes | The contracting agency, through your prime | Directly to DIR at services.dir.ca.gov/pw, under your own PWCR registration |
| Format | A two-page form, or an equivalent document with identical certification wording: worker columns 1A through 9 on page one and a six-point Statement of Compliance on page two. Current version revised January 2025, OMB 1235-0008, from the U.S. DOL | Electronic: hand-typed iForm or XML upload in DIR's published format, then reviewed and signed in the portal |
| Wage determinations | Federal determinations (SAM.gov) | California determinations by craft and county (DIR lookup) |
| Social Security numbers | Never the full number. Column 1E takes the last four digits or another worker-specific number, per the WH-347 instructions | Full nine digits, entered directly into DIR's current Public Works Portal, as shown on the employee registration and payroll screens in DIR's Upload eCPR guide |
| Fringe benefits | Three columns: 6A hourly wage rate, 6B total fringe benefit credit taken against bona fide plans, 6C cash paid in lieu. Any 6B amount is backed by a per-worker hourly credit table on page two (WH-347 instructions) | Reported in DIR's electronic format, iForm or XML |
| Signature | Certifying official signs page two with date, phone, and email; a legally valid electronic signature is accepted, a scanned or photocopied one is not (WH-347 instructions) | Reviewed and signed in the DIR portal under your own registration |
| Who enforces | U.S. DOL Wage and Hour Division and the contracting agency (DOL) | California Labor Commissioner, plus awarding bodies via withheld payments |
The traps in the overlap
- The SSN contradiction. The federal form bars the full number; column 1E takes the last four digits or another worker-specific number. The state record wants all nine. Feed one filing's format to the other and you have either a privacy violation on a federal form or a rejected state record. This single row in the table above causes more cross-contamination errors than everything else combined.
- Two determinations, one worker. On a dual-covered project, pay whichever wage package for that classification is higher, federal or state, where both determinations reach the same hours, an approach California's own Caltrans labor compliance manual confirms. Certifying against the lower one is a wage violation with a signed confession attached.
- Different weeks, same data. The WH-347 is weekly and the eCPR at least monthly, but the underlying payroll facts must match. An auditor who pulls both filings and finds different hours for the same worker in the same week has found something much worse than a late filing.
- Two names, two obligations. DIR's own Public Works page names Form A-1-131 as the suggested paper format the Labor Commissioner may require when a contractor does not comply with Labor Code section 1776, the separate duty to keep payroll records and furnish them to the awarding body or the Labor Commissioner on request. That is not the same duty as the direct electronic filing to DIR under Labor Code section 1771.4, the eCPR. Where a contract calls for A-1-131, treat it as the section 1776 paper duty to the awarding body, owed in addition to the eCPR to DIR, not in place of it.
- Neither covers the other, and portals cover neither, with one narrow exception. Filing the WH-347 does not touch the DIR duty, the eCPR does not touch the federal duty, and the GC's portal satisfies neither. The exception: projects run by the four legacy Labor Compliance Programs (Caltrans, the City of Los Angeles, LAUSD, and the County of Sacramento) are exempt from the direct DIR filing per DIR's exemptions page; there the awarding body's own monitoring stands in for it.
Which projects need what
- California public works, no federal money: eCPR to DIR, plus whatever the awarding body's portal demands. Many awarding bodies also expect WH-347-format weekly reports contractually even without federal funds, so read the labor compliance exhibit.
- Federal project outside California's system (rare in-state; e.g., certain purely federal facilities): WH-347 weekly.
- Federally assisted California public works, the common case for transit, ports, water, and housing: both. Weekly WH-347, eCPR to DIR on its cadence, portal uploads on top, every filing consistent with every other.
Questions
What is a WH-347 form?
Does ADP do certified payroll?
Is Form WH-347 required on California public works projects?
Which law applies to my project, Davis-Bacon or California's prevailing wage law?
Is the WH-347 due weekly or monthly, like the eCPR?
If I already upload to LCPtracker or another GC portal, do I still owe the eCPR?
What does A-1-131 mean on my contract?
One export, both regimes
Every fact both governments want lives in the payroll export you already run. We turn that one export into the weekly WH-347 on the current January 2025 form with its Statement of Compliance and the validated DIR eCPR file, consistent with each other by construction, checked by software and verified by a person, with rates sanity checked against the applicable published determination. First filing free, flat published pricing on the home page.