The Statement of Compliance, explained
Updated 2026-10-24 · Not affiliated with the U.S. Department of Labor
Every certified payroll must be accompanied by a signed Statement of Compliance. On the current WH-347 (Rev. January 2025), it is page 2. If you submit page 1 information from your own payroll software, you still need the statement: 29 CFR 3.3(b) says it must be on the back of Form WH-347 "or on any form with identical wording," and DOL's instructions say a submission of the WH-347's page 2 (or another document with identical wording) satisfies the regulation.
What the regulation requires the statement to certify
Under 29 CFR 5.5(a)(3)(ii)(C), the signer certifies three things:
- The certified payroll contains the required information, the required records are being kept, and they are correct and complete.
- Each laborer or mechanic (including helpers and apprentices) was paid the full weekly wages earned, without rebate, and with no deductions other than those permitted under 29 CFR part 3.
- Each laborer or mechanic was paid at least the applicable wage rates and fringe benefits, or cash equivalents, for the classification(s) of work actually performed, as specified in the wage determination in the contract.
The six boxes on page 2 break those promises into separate check marks.
The six boxes
Above the boxes, the signer states: "I paid or supervised the payment of the laborers or mechanics working on the above project during the stated time period."
| Box | In plain words | When to check |
|---|---|---|
| 1 | The payroll is correct and complete, and wage and fringe rates paid (including plan credit) are not less than the wage determination rates for the work actually performed. | Always |
| 2 | All regular payrolls and basic records for this period are complete and accurate and will be made available on request. | Always |
| 3 | The classifications reported are the ones each worker actually performed. | Always |
| 4 | Workers paid as apprentices are registered in a bona fide program registered with DOL's Office of Apprenticeship (OA) or a recognized State Apprenticeship Agency (SAA), and the program information listed is accurate. | Only if anyone was paid as an apprentice |
| 5 | Fringe benefits were paid in cash and/or to bona fide plans; plan information and hourly credits are listed for each worker. | When fringe benefits are owed and paid (cash, plans or both) |
| 6 | All workers were paid the full weekly wages earned, with no rebates or deductions other than those permitted under 29 CFR part 3. | Always |
DOL's instructions: "Boxes 1, 2, 3 and 6 (i.e., the first three boxes and the last box) always must be checked."
Box 4 and the apprenticeship table
If any worker was paid as an apprentice during the period, check box 4 and list each apprenticeship program in which you have registered apprentices working on the project that week: the program name, OA or SAA, and the labor classification. More than three entries need an addendum. If box 4 does not apply, leave it unchecked and write "Not Applicable" or "N/A" under Apprenticeship Program Name. See apprentices on WH-347.
Box 5 and the fringe benefit table
If you claim hourly credit for contributions to bona fide fringe benefit plans, check box 5 and complete the Hourly Credit for Fringe Benefits table: each worker in page 1 order, plan name, type, number, funded or unfunded, and hourly credit per plan. If you meet fringe obligations entirely in cash, check box 5 but leave the table empty, since the cash is reported in column 6C. See WH-347 fringe benefits explained.
The page 2 header
Page 2 repeats the project name, project or contract number, payroll number, business name, project location and week ending date. It adds the certifying official's name and title: the contractor or subcontractor, or the agent who paid or supervised the payment of the workers during the week the form covers.
Additional remarks
Optional space for information on deductions, fringe benefit costs, or explanations. This is where you describe a single "Other" deduction from column 8. If you need more room, continue on a separate page and include the contractor and project information on it.
Who signs, and how
- Who: the contractor or subcontractor, or their agent who pays or supervises the payment of the workers.
- Signature type: an original handwritten signature or a legally valid electronic signature (29 CFR 5.5(a)(3)(ii)(E) and 29 CFR 3.3(b)). DOL describes a legally valid electronic signature as one made through an electronic process that indicates acceptance of the certified payroll record and includes an electronic method of verifying the signer's identity.
- Not acceptable: per the DOL instructions, "Photocopies or scanned copies of signatures do not satisfy this requirement."
- Also required: the date signed, and the signer's telephone number and email address.
No notary, but real penalties
The statement does not need to be notarized. But DOL's instructions point out that it is subject to 18 U.S.C. 1001: a fine, possible imprisonment of not more than 5 years, or both. The regulation adds that falsifying the certifications may lead to civil or criminal prosecution under 18 U.S.C. 1001 and 31 U.S.C. 3729, and the form warns of debarment from future federal and federally assisted contracts. Certified payrolls may also be disclosed in response to a Freedom of Information Act request.
The practical takeaway: whoever signs should actually review the payroll each week, or rely on someone who did, not sign a stack of blank page 2s in advance.
How it changed from the old form
On the old WH-347 (Revised December 2008), the statement on the back was a fill-in-the-blanks paragraph: "I, (name), (title), do hereby state: (1) That I pay or supervise the payment of the persons employed by..." followed by numbered statements and a section (4) with sub-parts for fringe benefits paid to approved plans, fringe benefits paid in cash, and exceptions by craft. The 2025 version replaced that with six check boxes, an apprenticeship program table, a per-worker fringe credit table, and phone and email fields. See old vs new WH-347.
Checklist before you sign
- Boxes 1, 2, 3 and 6 checked.
- Box 4 checked with programs listed, or unchecked with "N/A".
- Box 5 checked if fringe is owed; table filled if you claim plan credit.
- Every "Other" deduction explained in remarks or an addendum.
- Name, title, date, phone and email filled in.
- Signed by hand or with a legally valid e-signature, not a pasted image.
Common questions
Does the Statement of Compliance need to be notarized?
No. DOL's instructions say it need not be notarized, but it is subject to the penalties of 18 U.S.C. 1001, so the signer should know the facts.
Can I sign once and reuse a scanned signature every week?
No. The signature must be an original handwritten signature or a legally valid electronic signature. DOL's instructions say photocopies or scanned copies of signatures do not satisfy the requirement.
Can I use my payroll company's report instead of page 1?
Yes, if it contains the required information. The Statement of Compliance still has to accompany it, on page 2 of the WH-347 or on a document with identical wording.
Sources
- DOL WHD — Form WH-347 instructions (page 2, Statement of Compliance) — retrieved 2026-10-24
- eCFR — 29 CFR 5.5(a)(3)(ii)(C)-(G), Statement of Compliance, signature, falsification — retrieved 2026-10-24
- eCFR — 29 CFR 3.3, certified payrolls — retrieved 2026-10-24