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.
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 funding or assistance in the project | Registered California public works subject to prevailing wage |
| Cadence | Weekly | 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 form (or equivalent) with a signed Statement of Compliance; get it 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 | Last four digits only | Full nine digits, inside DIR's system |
| Who enforces | U.S. DOL Wage and Hour Division and the contracting agency | California Labor Commissioner, plus awarding bodies via withheld payments |
The traps in the overlap
- The SSN contradiction. The federal form wants the last four digits; 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 the worker is owed the HIGHER applicable package where both determinations reach the same hours. 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, one obligation. California's electronic record is sometimes called by its old paper form number, A-1-131. If a contract references A-1-131, it means the eCPR duty, not an extra form.
- 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.
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 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 weekly filing free, flat published pricing on the home page.