Reporting apprentices on WH-347

Apprentices are the one group of workers who may legally be paid less than the wage determination rate on a Davis-Bacon job. Because of that, the rules for who counts as an apprentice are strict, and the 2025 WH-347 asks you to show apprentice status on every row and certify the program on page 2.

Who counts as an apprentice

Under 29 CFR 5.5(a)(4)(i)(A), apprentices may work at less than the predetermined rate when they are "employed pursuant to and individually registered in a bona fide apprenticeship program registered with" DOL's Office of Apprenticeship (OA), or with a State Apprenticeship Agency (SAA) recognized by the OA.

There is one narrow extension: a person not yet individually registered, but certified by the OA or an SAA as eligible for probationary employment as an apprentice, may be paid less than the predetermined rate during the first 90 days of probationary employment in that program.

If the OA or SAA withdraws approval of the program, you may no longer pay apprentice rates until an acceptable program is approved.

What happens if the worker does not qualify

The rule is blunt: "Any worker listed on a payroll at an apprentice wage rate, who is not registered or otherwise employed as stated in paragraph (a)(4)(i)(A) of this section, must be paid not less than the applicable wage rate on the wage determination for the classification of work actually performed."

The same applies to apprentices working beyond the allowed ratio (below): anyone over the ratio must be paid the full rate for the work performed.

Pay rates and fringe

• Wage rate: set by the registered program, typically as a percentage of the journeyworker's hourly rate that rises with each level.
• Fringe benefits: "in accordance with the provisions of the apprenticeship program." If the program does not specify fringe benefits, apprentices must be paid the full amount of fringe benefits listed on the wage determination for the classification. If the WHD Administrator determines that a different practice prevails for that apprentice classification, follow that determination.
• Different locality: if you work in a locality other than where your program is registered, the ratios and wage rates (expressed as percentages of the journeyworker's rate) that apply in the project's locality must be observed. If the project's locality has none, use your program's.

Ratios

The ratio of apprentices to journeyworkers on the job site in any craft classification may not exceed the ratio permitted to you for your entire work force under the registered program, or the ratio for the project's locality where the reciprocity rule applies. Apprentices beyond the ratio must be paid the full wage determination rate for the work performed.

Showing apprentices on page 1

Column 2, Journeyworker / Registered apprentice. Enter "J" for a journeyworker or "RA" for a registered apprentice. DOL's instructions add: "For registered apprentices, also list their level of progression within the approved program." For example: "RA 2" or "RA (2nd yr)", following however your program names its levels.

Column 3, Labor classification. The classification of the work the apprentice performs, as in the wage determination (for example, "Electrician"), not just "apprentice."

Column 6A. The apprentice's actual hourly rate. The overtime rate on the bottom line is 1.5 times that basic rate where overtime applies.

Example

Wage determination: Electrician $40.00 + $16.00. The contractor's registered program sets a 2nd-year apprentice at 60% of the journeyworker rate, and its standards say fringe benefits are paid in full. The apprentice works 40 hours, and fringe is paid to plans.

Column	Entry
2	RA, level 2
3	Electrician
6A	24.00 (60% of 40.00) / 36.00 OT
7A	40 × 24.00 = 960.00
6B	40 × 16.00 = 640.00

The percentages and fringe treatment here are illustrative; use what your program's standards actually say.

Page 2: box 4 and the apprenticeship program table

Box 4 of the Statement of Compliance certifies that any workers paid as apprentices during the period are duly registered in a bona fide program registered with the OA or a recognized SAA, and that you verified the program information listed.

DOL's instructions:

• If any worker is paid as an apprentice during the period, box 4 must be checked.
• List each program name in which you have registered apprentices working on the project during this payroll period.
• Mark whether the program is registered with the OA or an SAA.
• Enter the name of the labor classification.
• More than three entries: submit an addendum with the same information.
• If box 4 is not applicable: do not check it, and enter "Not Applicable" or "N/A" under Apprenticeship Program Name.

Records to keep

The contract clause in 29 CFR 5.5(a)(3)(i)(D) requires contractors with apprentices to keep written evidence of:

• the registration of the apprenticeship program,
• the registration of each apprentice, and
• the ratios and wage rates prescribed in the program.

Get the registration paperwork before an apprentice starts on the job, and keep it with the project's payroll records for the same 3-year period.

Common mistakes

• Paying a "helper" or "trainee" an apprentice rate without individual registration.
• Using the program's rate in a different locality without checking local ratios and rates.
• Forgetting fringe for apprentices when the program is silent (then the full determination fringe applies).
• Checking box 4 but leaving the program table blank, or leaving box 4 unchecked without writing N/A.

In WH-347 Kit you mark each worker as J or RA with their level, and you can enter an apprentice's own rate instead of the classification's journeyworker rate. On the Crew tab you also set the apprentice's fringe as the program provides it — the full wage-determination fringe when the program is silent, a different hourly rate with its plan credits, or no fringe — and columns 6B, 6C and the page 2 credit table use it. You still confirm the program details and box 4 each week before you sign.