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The Statement of Compliance: What You Are Actually Signing
What is a Statement of Compliance in certified payroll?
The Statement of Compliance is the signed certification that must accompany every weekly certified payroll on a Davis-Bacon project. The signer certifies the payroll is correct and complete and that every worker was paid at least the required prevailing wage and fringe benefits for the work performed.
Page 1 of the WH-347 is arithmetic. Page 2 is the law. The Statement of Compliance is why the filing is called certified payroll: a person with knowledge of the payroll signs a federal certification that it is true.
The certifications on the current form
The January 2025 revision presents the statement as a set of explicit certifications. Check a box only if the statement is true for this payroll week:
- The payroll is correct and complete, and every worker was paid not less than the applicable wage and fringe rates for the classification of work actually performed, as specified in the wage determination incorporated into the contract. Credit taken for fringe plans is included in this one.
- All required basic records are complete and accurate and will be made available on request from the agency or the Department of Labor.
- The classifications reported match the work each worker actually performed. Not their job title, not their usual trade: what they did this week.
- Any apprentices are duly registered in a bona fide program with the Office of Apprenticeship or a recognized State Apprenticeship Agency. The form asks you to list each program, whether it is OA or SAA registered, and the classification.
- Fringe benefits were paid as reported, in cash and/or to bona fide plans. If you claimed an hourly credit in column 6B, the form's fringe table asks for each plan's name, type, number, funded status, and the hourly credit per worker.
- Workers received their full weekly wages, with no rebates and no deductions beyond those permitted by 29 CFR part 3.
Below the certifications sit the apprenticeship table, the hourly-credit-for-fringe-benefits grid, additional remarks, and the signature block: signature, date, telephone, and email.
The weight of the signature
Directly under the signature block, the form states that willful falsification may subject the contractor or subcontractor to civil or criminal prosecution under 18 U.S.C. 1001 and 31 U.S.C. 3729, and to debarment. That is not boilerplate; it is the enforcement backbone of the whole system. Two practical rules follow:
- Sign only what you know. The signer should be the person who paid or supervised payment, with access to the time and pay records behind every number.
- Never pre-sign or auto-sign. Software (ours included) can prepare every figure, but the certification is a human act. A tool that "certifies for you" is a tool putting your name on a federal statement you have not read.
Remarks: small box, real value
The Additional Remarks field is the right place to explain anything an auditor would otherwise have to guess: an apprentice's rate step, a corrected figure from a prior week, a worker who appears under two classifications. One plain sentence in remarks prevents most follow-up letters.
The free generator fills the entire page 2, checkboxes, fringe grid, and contact block from what you enter, and leaves the signature line empty on purpose. That line is yours.
Questions
Who should sign the Statement of Compliance?
Someone who pays or supervises payment of the workers and actually knows the payroll is accurate: typically the owner, an officer, or the payroll administrator. The signature carries personal legal responsibility, so it should never be delegated to someone without knowledge of the facts.
Does the statement have to be on the WH-347 itself?
No. Page 2 of the WH-347 or any document with identical wording works. What matters is that the certified payroll is accompanied by the signed statement every week.
What if something on a filed payroll turns out to be wrong?
File a corrected payroll promptly and pay any wages owed. Honest corrections are routine; letting a known error stand under a signed certification is what creates real exposure.