Certified payroll deductions and net pay

Davis-Bacon workers must be paid "the full amount of basic hourly wages and bona fide fringe benefits," at least weekly, "without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3))" (29 CFR 5.5(a)(1)(i)). Column 8 of the WH-347 is where you show that every deduction you took is one of the permitted ones, and column 9 shows what the worker actually received.

Column 8, deductions for all work

The 2025 form has four deduction columns:

Column	What goes in it
Tax withholdings	Income tax withheld
FICA	Social Security and Medicare withheld
Other (must specify, see instructions)	Any other deduction
Total deductions	Tax withholdings + FICA + Other

Key instructions from DOL:

• All deductions come from the gross for all work (7B). Column 8 is headed "Deductions for all work."
• Do not pro-rate. "If a worker worked on other jobs in addition to this project, do not pro-rate the deductions; instead, show actual deductions from the worker's weekly gross wage for all projects."
• Explain "Other." If "Other" is a single deduction, describe it under Additional Remarks on page 2. If it combines several, submit an addendum itemizing each deduction with a description and amount.
• Total means total. Enter the total of all deductions actually made, including tax withholdings, FICA and Other.
• Stay within part 3. "All deductions must be in accordance with the provisions of the Copeland Act Regulations, 29 CFR part 3." And: "Except for deductions listed in 29 CFR 3.5, all deductions must have prior approval from the Department of Labor."

Deductions you can make without asking DOL (29 CFR 3.5)

29 CFR 3.5 lists the deductions you may make without applying to the Secretary of Labor. In summary:

3.5	Deduction	Main conditions
(a)	Deductions required by federal, state or local law	For example, withholding income taxes and Social Security taxes
(b)	Repayment of a bona fide prepayment of wages	Advanced without discount or interest, with complete freedom of use
(c)	Amounts required by court process (garnishments)	Not in favor of the contractor or an affiliated person, and no collusion
(d)	Contributions to funds for medical care, pensions, death, injury, illness, disability, insurance, unemployment, vacation, savings and similar benefits	Not otherwise illegal; voluntarily consented to in writing in advance (not a condition of employment) or provided in a bona fide collective bargaining agreement; no profit to the contractor; in the worker's convenience and interest
(e)	Credit union loan repayments or share purchases	Requested by the worker
(f)	Contributions to governmental or quasi-governmental agencies, such as the American Red Cross	Voluntarily authorized by the worker
(g)	Contributions to 501(c)(3) charitable organizations	Voluntarily authorized by the worker
(h)	Regular union initiation fees and membership dues	Provided for in a collective bargaining agreement; not fines or special assessments
(i)	Reasonable cost of board, lodging or other facilities	Must meet FLSA section 3(m) and 29 CFR part 531; extra records under 29 CFR 516.25(a)
(j)	Safety equipment of nominal value the worker buys as their own (safety shoes, glasses, gloves, hard hats)	Not required by law to be furnished by the contractor; no more than actual cost; no return to the contractor; written advance consent or a collective bargaining agreement

Deductions that need DOL approval (29 CFR 3.6)

Anything not covered by 3.5 needs permission. Under 29 CFR 3.6, a contractor or subcontractor may apply to the Secretary of Labor, who may grant permission if the contractor and affiliated persons make no profit or benefit from it, it is not otherwise prohibited by law, it is voluntarily consented to in writing in advance (not as a condition of employment) or provided in a bona fide collective bargaining agreement, and it serves the worker's convenience and interest.

Do not take an unapproved deduction "temporarily" and sort it out later. Box 6 of the Statement of Compliance certifies that no deductions were made "other than permissible deductions as defined in 29 CFR part 3."

Column 9, net pay

DOL's instruction: "Enter the actual dollar amount paid to the worker for all hours worked across all projects (including non-DBRA covered projects) during the week."

Net pay is a fact, not a formula: it is what you actually paid. It should reconcile with the other columns. With cash paid in lieu of fringe benefits reported separately in 6C, the check is:

Net pay (9) = gross for all work (7B) + cash in lieu of fringe (6C) − total deductions (8)

That is also how DOL's own online WH-347 form computes net pay.

Worked example

A finisher works 40 hours on this project at $30.00 with $10.00 fringe paid as cash in lieu, and earns $200.00 on a private job the same week.

Column	Calculation	Amount
7A gross, this project	40 × 30.00	1,200.00
7B gross, all work	1,200.00 + 200.00	1,400.00
6C cash in lieu	40 × 10.00	400.00
8 tax withholdings	from payroll	168.00
8 FICA	from payroll	137.70
8 other	union dues per CBA, described in remarks	25.00
8 total	168.00 + 137.70 + 25.00	330.70
9 net pay	1,400.00 + 400.00 − 330.70	1,469.30

The withholding and FICA figures are illustrative; enter the amounts your payroll actually withheld, computed on everything that is taxable for the week (cash in lieu of fringe is paid to the worker in cash). Additional Remarks would read something like "Other: union dues, $25.00, per collective bargaining agreement."

Common mistakes

• Pro-rating taxes to the project instead of showing actual weekly deductions.
• A lump "Other" with no description or addendum.
• Deductions for tools, uniforms, loans from the company or damages that are not covered by 3.5 and have no DOL approval.
• Net pay that does not match the check or direct deposit actually issued.

In WH-347 Kit you enter tax withholdings, FICA, other and its description for each worker. The app totals column 8, computes column 9 as above for you to check against what you paid, and carries the "Other" description into Additional Remarks.