State by State: Understand Certified Payroll Reporting
Prevailing wage and certified payroll reporting requirements look different in every state, and for contractors working across state lines, that complexity adds up fast.
About 30 states plus the District of Columbia have their own "Little Davis-Bacon" laws layered on top of the federal Davis-Bacon Act. Each comes with its own thresholds, forms, filing cadences, and enforcement quirks. States without their own prevailing wage laws still require certified payroll reporting on federally funded projects, and a growing number are introducing additional wage protections, paid leave laws, and labor reporting requirements that affect contractors and payroll teams.
This guide breaks down what you need to know for each of the states we cover: including governing agencies, key forms, thresholds, and recent regulatory updates. Use the navigation below to jump to your state, or read through for a complete picture.
The federal Davis-Bacon Act, established in 1931, sets prevailing wage requirements for contractors and subcontractors working on federally funded or assisted construction contracts in excess of $2,000. Together with nearly 60 Related Acts overseen by the U.S. Department of Labor, it requires that workers on covered public works projects be paid no less than the locally prevailing wages and fringe benefits for similar work in the area.
The regulatory environment around Davis-Bacon continues to evolve, including significant updates from the 2023 final rule, ongoing court challenges, and shifting enforcement priorities under the current administration. For a deeper dive on federal requirements, recent rule changes, and what they mean for contractors, see our complete guide to the Davis-Bacon Act and its Related Acts.
Federal Certified Payroll Reporting
Certified payroll reporting is the weekly documentation contractors and subcontractors submit to verify they're paying the appropriate prevailing wage rates and fringe benefits on federally funded public works projects. Each report tracks worker classifications, hours worked, and deductions, and includes a signed statement of compliance from the contractor or subcontractor.
The federal Form WH-347 is the standard form for Davis-Bacon reporting. However, many states require their own state-specific forms, sometimes in addition to WH-347, sometimes in place of it, for state-funded projects, which is where state-level requirements come into play.
State requirements vary widely, from filing systems and form formats to wage rate updates, apprenticeship rules, and county-level variations. Below, we cover the top-level requirements for contractors and subcontractors working on public projects, with links to in-depth articles for each state. If you don't see your state, federal Davis-Bacon requirements still apply to federally funded projects, and certified payroll reporting may be required regardless of your state's specific law. Need support with certified payroll reporting? Reach out to us.
Master Electronic Filing in California
California has some of the most active prevailing wage enforcement in the country. The California Department of Industrial Relations (DIR) sets and enforces prevailing wage rates for public works projects over $1,000, covering construction, alteration, demolition, installation, repair, and maintenance projects funded by public money. Contractors and subcontractors must pay both the established rate and qualifying fringe benefits, and rates typically reflect local cost of living and union wage standards.
What makes California unique is its fully electronic certified payroll filing process. Every submission flows through DIR's online filing system, which can save time in some respects but creates real compatibility, security, and technical challenges if your payroll systems weren't built for electronic integration. Worker classification accuracy is critical, since misclassification is one of the most common compliance violations on California public works projects.
Apply Federal Davis-Bacon Without a State Law in Florida
Florida is among the states that have not enacted state-level prevailing wage legislation, meaning there is no state agency that sets or enforces prevailing wage rates and no Florida-specific certified payroll forms. As of July 2024, local prevailing wage ordinances that had been active in Orlando, Miami-Dade County, and the City of Miami were preempted by state law (HB 705), eliminating that layer of local coverage. That means federal Davis-Bacon is the only prevailing wage standard that applies to construction in Florida, and it applies often.
Federal funding flows into Florida through NASA Kennedy Space Center, MacDill and Eglin Air Force Bases, port expansions at PortMiami and Port Tampa Bay, FEMA-funded hurricane recovery, and Everglades restoration work. Wage determinations vary significantly across Florida's counties, with Miami-Dade carrying the highest rates in the state. Contractors should pull the applicable wage determination from SAM.gov before bidding, since using the wrong classification is a compliance violation from day one.
Navigate Federal Davis-Bacon Across 159 Counties in Georgia
Georgia does not have a state-level prevailing wage law, meaning state and locally funded construction projects do not trigger wage floor requirements. However, federal Davis-Bacon applies to any project receiving federal funding, and Georgia receives a significant share of federal construction dollars. From Hartsfield-Jackson Atlanta International Airport to Fort Eisenhower (home of U.S. Army Cyber Command), the Savannah Harbor Expansion Project, and CDC campus construction, federal funding reaches nearly every region of the state.
With 159 counties (the most of any state east of the Mississippi), federal wage determinations can vary dramatically across Georgia. Metro counties including Fulton, DeKalb, Cobb, and Gwinnett carry the state's highest rates, while rural South Georgia and Appalachian North Georgia counties generally carry significantly lower rates. The metro-to-rural wage gap is among the steepest in the Southeast, making project-specific rate verification on SAM.gov essential before bidding.
Basics and Violations of Prevailing Wage in Illinois
Illinois has two separate laws governing prevailing wage compliance: the Prevailing Wage Act, which covers construction, and the Illinois Procurement Code, which governs other public-funded labor such as janitorial services, food services, window cleaning, security services, and printing. Public works projects subject to these laws are those funded in whole or in part with bonds, grants, loans, or other funds made available by the state or its political subdivisions. Rates are determined by county or locality and by trade, so a carpenter and a painter on the same project may have different prevailing wage rates.
Public bodies in each county or locality are responsible for notifying contractors and subcontractors of changes to prevailing wage rates, which makes tracking somewhat easier than in states with fully decentralized systems. The primary form to know is the Illinois Department of Labor Certified Transcript of Payroll, which captures project information, contractor and subcontractor details, and worker-level data including hours worked and hourly wage rates. Worker misclassification and incomplete or inaccurate certified payroll reports are among the most common violations and the most frequent triggers for investigations.
Navigate the Reinstated Law and New Registration Requirements in Michigan
Michigan is one of the few states to repeal and then reinstate its prevailing wage law. After a six-year gap (2018 to 2024), Act 10 of 2023 restored requirements effective February 13, 2024, with administration falling to the Michigan Department of Labor and Economic Opportunity (LEO). The reinstated law applies to state-funded construction projects involving public buildings, schools, roads, bridges, and highways, with a $28,000 contract threshold. A 2024 amendment further expanded coverage to qualifying energy facility projects (solar, wind, and energy storage) with a nameplate capacity of 2 megawatts or more.
The reinstated law brought new compliance obligations beyond the wage rate itself. All contractors and subcontractors employing construction mechanics must register with LEO's Wage and Hour Division, with a $500 annual fee. Certified payroll submission has phased to online filing through LEO's system, with full online submission required as of April 2026, and current rate schedules are published by county on the LEO's prevailing wage page at michigan.gov. Michigan also includes joint and several liability provisions, meaning general contractors and subcontractors share responsibility for wage violations. If a project is subject to federal Davis-Bacon requirements, Act 10 may not apply to the same work, so contractors should confirm their specific obligations with the contracting agent for any mixed-funding project.
Master Regional Wage Zones in Nevada
Nevada divides the state into four prevailing wage regions for the purpose of wage determinations: Washoe Region (Washoe County), Northern Rural Region (Carson City and surrounding counties), Clark Region (Clark County), and Southern Rural Region (Esmeralda, Lincoln, and Nye counties). Prevailing wage law in Nevada is governed by Nevada Revised Statutes (NRS) Chapter 338 and enforced by the Nevada Office of the Labor Commissioner, which operates within the Department of Business and Industry. Prevailing wage applies to public works contracts over $100,000, a threshold lowered from $250,000 in 2019 under Assembly Bill 136.
A significant 2026 development reshaped Nevada's compliance landscape: the U.S. Department of Labor formally adopted Nevada's prevailing wage rates for federal Davis-Bacon projects, meaning contractors now follow a single unified set of rates across both state-funded and federally funded public works in the state. The Labor Commissioner conducts contractor surveys in odd-numbered years, with new wage rates effective for a two-year cycle (the current cycle covers October 1, 2025 through September 30, 2027), available on the Nevada Labor Commissioner's website at labor.nv.gov. Certified payroll reports are submitted monthly within 15 days of month-end. Nevada also has a 3% apprentice utilization requirement on horizontal construction projects where more than three workers are employed in a covered craft.
Manage County Variations and the NJ Wage Hub in New Jersey
New Jersey's prevailing wage requirements are established by the New Jersey Prevailing Wage Act and overseen by the New Jersey Department of Labor and the Commissioner of Labor and Workforce Development. Rates are determined by factors including cost of living, collective bargaining agreements, and local labor market conditions, and they vary by county. The law covers contractors and subcontractors performing work on publicly funded public works projects, with certified payroll reporting required to verify compliance with the established rates and fringe benefits.
Since August 2024, certified payroll reporting in New Jersey has been centralized through the NJ Wage Hub, replacing the previous patchwork of submission methods and streamlining filings for contracting agencies and employers alike. Contractors must be familiar with several state-specific forms, including the New Jersey Department of Labor Certification for Public Works Projects form, the New Jersey Contractor Certified Payroll form, and the New Jersey Economic Development Authority form, as well as the federal WH-347 for any federally connected work. With multiple required form formats in play, accurate certified payroll reporting is essential for compliance.
Manage Municipal-Level Requirements in New York
Prevailing wage in New York is codified in Articles 8 and 9 of New York State Labor Law and overseen jointly by the New York State Department of Labor and the Office of the New York State Comptroller. Together, these agencies monitor and enforce prevailing wage and certified payroll reporting requirements to ensure that workers and skilled laborers on public work contracts are paid fairly. Rates typically mirror union contract hourly wages, often making them notably higher than market rates for the same work.
What makes New York's framework uniquely complex is its granularity. Prevailing wage rates vary by county, and different counties or municipalities can layer their own certified payroll reporting requirements on top of the state framework. That means a contractor working on projects in multiple New York counties needs working knowledge of both the statewide requirements and the local-level variations that apply to each job site. Detailed record-keeping, project-specific wage determination verification, and a strong handle on geographical disparities across counties are essential.
Apply Federal Davis-Bacon Across a Right-to-Work State in North Carolina
North Carolina does not have a state prevailing wage law, and the state's Department of Labor does not set or enforce prevailing wage rates. Instead, North Carolina defers entirely to federal Davis-Bacon, directing contractors to the U.S. Department of Labor's Wage and Hour Division offices in Charlotte and Raleigh for wage determination information. With $12.3 billion in federal infrastructure funding allocated to projects across the state (per ASCE's 2026 Report Card for North Carolina's Infrastructure), federal prevailing wage is playing a larger role in North Carolina's construction landscape than ever before.
As a right-to-work state with a predominantly non-union workforce, North Carolina presents a particular compliance wrinkle: Davis-Bacon rates are often calculated from union wage survey data, which can create confusion for non-union contractors unfamiliar with the rate-setting methodology. Regardless of how rates are derived, compliance is based on the published wage determination and not whether a contractor's workforce is unionized. Wage determinations also vary widely across the state's 100 counties, with Charlotte rates looking very different from those in rural western North Carolina, so contractors should always pull the correct wage determination from SAM.gov before bidding.
Navigate Dual Thresholds and County Coordinators in Ohio
Ohio has one of the longest-standing prevailing wage programs in the country, dating back to 1931 and governed today by Ohio Revised Code Chapter 4115. Administration falls to the Ohio Department of Commerce, Division of Industrial Compliance, Bureau of Wage & Hour Administration. The state uses a dual threshold system: building construction triggers prevailing wage requirements at $250,000 for new construction or $75,000 for renovation and repair, while horizontal and road construction follows separate thresholds adjusted biennially. Annual threshold changes are capped at 3%.
Rates are determined county-by-county based on local union collective bargaining agreements, meaning rates can vary significantly across Ohio's 88 counties for the same trade. A distinctive feature of Ohio's system is the local Prevailing Wage Coordinator, a government employee appointed for each prevailing wage project who handles compliance oversight, audits certified payroll reports, and serves as the liaison between contractors and the Ohio Department of Commerce. Reports flow weekly for short projects (four months or less) or monthly for longer ones, and before final payment, contractors must submit a notarized Affidavit of Compliance. Penalties include 100% of underpaid wages and potential debarment for intentional violations.
Manage BOLI Compliance and Semi-Annual Rate Updates in Oregon
Oregon's Prevailing Wage Rate (PWR) Law is governed by Oregon Revised Statutes Chapter 279C.800-279C.870 and administered by the Oregon Bureau of Labor and Industries (BOLI). Prevailing wage applies to public works projects exceeding $50,000, ensuring fair compensation for workers through established base hourly wages and fringe benefits on construction, reconstruction, major renovation, painting, demolition, and hazardous waste removal projects. Before starting work on any prevailing wage project, contractors and subcontractors must file a $30,000 public works bond with the Construction Contractors Board (CCB), which serves as a continuous financial guarantee that workers will receive proper wages.
What sets Oregon apart is its semi-annual rate update cycle. BOLI publishes new prevailing wage rate books on January 1 and July 1 each year, with additional amendments on April 1 and October 1, keeping Oregon rates more current than most states. Certified payroll reports must be submitted using Oregon-specific Form WH-38 (Payroll and Certified Statement) or Form WH-141 to the public agency by the fifth business day of each month following work. Importantly, the federal Form WH-347 used for Davis-Bacon reporting is not sufficient for meeting Oregon's state-funded project requirements, and late submissions trigger mandatory 25% retainage on earned payments.
Track County Determinations and Form LLC-25 in Pennsylvania
The Pennsylvania Prevailing Wage Act (43 P.S. §§ 165-1 through 165-17) became law in 1961 and is administered by the Department of Labor & Industry (DLI) through its Bureau of Labor Law Compliance. The state uses a dual threshold system: $25,000 for most public works construction projects (a threshold unchanged since 1963, making it one of the oldest unmodified thresholds in the country) and $100,000 for locally funded highway and bridge projects under Act 89 of 2013. Wage determinations are issued on a project-by-project basis at the county level, so contractors must obtain new determinations directly from DLI for every project rather than relying on annual rate books.
Pennsylvania's required weekly certified payroll report is Form LLC-25, which captures worker classifications, hours worked, wages paid, and fringe benefits, plus a signed certification of accuracy. Records must be retained for a minimum of three years and made available for DLI inspection. Notably, Pennsylvania does not require overtime premiums under state prevailing wage law, though federal projects or collective bargaining agreements may still apply them. Enforcement is serious: in one notable case, a Pennsylvania contractor was ordered to pay over $20 million for prevailing wage violations on public works projects.
Navigate a No-Threshold, Decentralized System in Texas
Texas prevailing wage law is governed by Texas Government Code Chapter 2258 and has been on the books since 1933. The statute applies to all public works construction funded wholly or partially by state or local public funds, with two characteristics that make Texas unusual. First, there is no minimum dollar threshold: every public works project is subject to prevailing wage requirements regardless of size. Second, rate-setting is fully decentralized, with each political subdivision (county, city, school district, or other public body) responsible for determining its own rates.
The 2007 HB 2625 amendment allowed political subdivisions to adopt federal Davis-Bacon wage determinations rather than conducting their own local surveys, which significantly simplified compliance in adopting jurisdictions. Major jurisdictions that have done so include Austin, Houston (including Houston Airports), Harris County, Lubbock, Baytown, Pasadena, and the Texas Facilities Commission. Other jurisdictions continue to conduct their own local wage surveys, meaning contractors working across multiple Texas jurisdictions cannot rely on a single statewide schedule and must verify rates with each public body. Underpayment carries a $60-per-worker-per-day civil penalty.
Track Statewide and Growing Local Ordinances in Virginia
Virginia's prevailing wage law (Va. Code § 2.2-4321.3), often called the "Little Davis-Bacon Act," became effective May 1, 2021 and is administered by the Virginia Department of Labor and Industry (DOLI). The law applies to public works contracts over $250,000 paid for in whole or in part by state funds, and contractors must engage with DOLI within a specific 10 to 20 day pre-bid window for project-specific wage determinations. Virginia also has a 6-year record retention requirement, notably longer than the federal Davis-Bacon three-year requirement.
Virginia's compliance landscape is uniquely active. Under § 2.2-4321.3(C), localities can adopt their own ordinances extending prevailing wage to locally funded public works: Portsmouth, Fairfax County, and (effective July 2025) the City of Richmond have all done so at the $250,000 threshold. In April 2026, Governor Spanberger signed legislation further strengthening the state's prevailing wage program, including a shift toward Virginia-specific rate-setting (replacing the current reliance on federal Davis-Bacon benchmarks) and consolidated wage theft enforcement under HB 238. Contractors must verify both locality ordinance status and current state requirements before bidding. Willful violations are a Class 1 misdemeanor carrying up to 12 months in jail, a fine of up to $2,500, or both.
Track Craft Codes and Apprenticeship Requirements in Washington
Washington State's Prevailing Wages on Public Works Act protects workers from substandard earnings and preserves local wage standards on publicly funded projects. Administration falls to the Washington State Department of Labor and Industries (L&I), which sets rates based on surveys of contractors and labor unions. Public works projects in Washington include any project funded by public dollars, plus certain private construction projects resulting from government agency rental, lease, or purchase agreements, broadening coverage beyond what most states define as public work.
Washington has a robust set of state-specific certified payroll forms, including the L&I XML File, the Washington Department of Labor Certified Payroll Report (F700-065-000), the Washington Department of Transportation Monthly Employment Utilization Report, and the Washington Statement of Apprentice/Journeyman Participation (EAS 010103). Apprentice utilization tracking is a significant compliance focus in Washington, with utilization standards built into prevailing wage requirements and enforced through dedicated reporting forms.
Frequently Asked Questions About State Prevailing Wage Laws
The funding source determines your requirements. Federal funding triggers Davis-Bacon Act compliance, while state or local public funding triggers state prevailing wage laws where they exist. Mixed-funding projects can trigger both, and in those cases contractors typically must pay the higher of the two applicable rates. Always verify funding sources with your contracting agency before bidding, since federally assisted funding (federal grants, loans, or insurance flowing to a state or local agency) can be easy to miss but still trigger Davis-Bacon requirements.
When both federal Davis-Bacon and state prevailing wage rates apply to the same project, contractors generally must pay the higher of the two applicable rates. The specific requirements can vary by state and project type. California, New York, Illinois, and other states with strong union presence often have rates that exceed federal minimums for many classifications. Virginia's law explicitly requires the higher of state or federal rates when both apply. A thorough rate comparison before beginning work is essential for both proper budgeting and full compliance, particularly on projects where funding sources may be added or modified mid-project.
Rate update frequency varies significantly by state. Oregon publishes new rate books on January 1 and July 1 each year (with additional amendments April 1 and October 1), making it one of the most current cycles in the country. Nevada conducts contractor surveys in odd-numbered years, with rates effective for a two-year cycle starting October 1. Pennsylvania issues wage determinations on a project-by-project basis rather than publishing annual rate books, so contractors must obtain new determinations directly from DLI for every project. New York updates rates on a rolling basis as new collective bargaining agreements are established. Always check the most current determinations before starting any project and establish a system for monitoring rate changes throughout your project duration.
While some information overlaps between federal and state certified payroll reports, most states require their own specific forms and submission processes. California requires electronic filing through DIR's online system with specific formatting. New Jersey routes all certified payroll through the NJ Wage Hub. Pennsylvania uses Form LLC-25 weekly. Oregon-specific Form WH-38 or WH-141 is required for state-funded projects (the federal WH-347 alone is not sufficient). Michigan has transitioned to mandatory online submission through LEO's system. Many contractors find it easier to use specialized software like Certified Payroll Reporting to manage multiple reporting requirements simultaneously and ensure all necessary forms are completed accurately.
Even in states with their own prevailing wage law, individual localities can adopt additional ordinances extending coverage to locally funded projects. Virginia is one of the most active examples: Portsmouth, Fairfax County, and (effective July 2025) the City of Richmond have all adopted ordinances under § 2.2-4321.3(C) extending prevailing wage to locally funded contracts at the $250,000 threshold. The reverse can also happen: in 2024, Florida's HB 705 preempted local prevailing wage ordinances that had previously been active in Orlando, Miami-Dade County, and the City of Miami. The only reliable way to know is to contact the contracting public body or awarding agency before bidding. Don't assume a locality follows the same rules as the state at large or as neighboring jurisdictions.
Apprenticeship programs play a significant role in prevailing wage compliance across many states. Apprentices working on covered projects must be registered with an approved apprenticeship program (the U.S. Department of Labor's Office of Apprenticeship or a recognized State Apprenticeship Agency for federal projects) and paid a percentage of the journeyworker prevailing wage rate based on their program level. Some states have specific utilization requirements: Nevada requires that apprentices represent at least 3% of total labor hours on horizontal construction projects where more than three workers are employed in a covered craft, and Washington requires dedicated apprentice and journeyworker participation reporting. Misclassifying workers as apprentices to reduce labor costs is a serious violation carrying the same penalties as prevailing wage underpayment.
Failing to understand local variations within states is the most common and costly mistake. Texas has no statewide rate schedule at all, since each political subdivision sets its own rates. New York prevailing wage rates vary by county with different reporting requirements for NYC versus upstate projects. Virginia's law allows individual localities to adopt their own ordinances extending prevailing wage to locally funded projects. Ohio's 88 counties can each have different rates for the same trade. These local nuances often catch contractors off-guard, resulting in violations and penalties. Working with experienced compliance professionals or using specialized software can help navigate these complexities successfully.
Streamline Certified Payroll Reporting in Any State
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