The New WH-347 Requires More Than a New Form

What changed – and how to be ready by October 1, 2026.

The U.S. Department of Labor revised Form WH-347 – the federal certified payroll form for Davis-Bacon and Related Acts projects – effective January 15, 2025. The form is valid through January 31, 2028. But the practical transition matters sooner than that: starting October 1, 2026, the new WH-347 becomes the only valid form for federal certified payroll reporting.

That’s roughly 10 weeks away. And most compliance setups are still configured for the old form.

Here’s what actually changed, what it means for your compliance program, and what we’d recommend doing in the next 30 days to be ready.

What Actually Changed

The new WH-347 isn’t a cosmetic refresh. The DOL used the revision to bring certified payroll reporting in line with how prevailing-wage compliance has actually been enforced – and to capture more granular data on the elements where contractors most often get audited.

Five changes are worth understanding in detail.

1. Fringe benefits, now on the main form.

The detailed fringe data isn’t strictly new – the old WH-348 supplemental page required similar information. But on the old form it lived on a supplemental page that was easy to skip, and in practice most subs did. The new WH-347 brings the full fringe breakdown onto the main form itself: benefit name, type, plan name, plan number, hourly credit value, distinction between funded and unfunded, plus a separate field for payments made in lieu of fringes. The data isn’t new. The visibility – and the difficulty of leaving fields blank – is the change.

2. Journeyworker vs. registered apprentice, explicit.

The old form left worker classification implicit in the wage rate. The new form requires explicit identification – Journeyworker (J), Registered Apprentice (RA), and a Worker Entry Number tying each labor hour back to the specific worker on the job. This change reflects the apprenticeship-ratio requirements introduced under the Inflation Reduction Act and tightens the audit trail for those ratios.

3. Wage Determination Number, now explicit on the payroll.

The old form left this connection implicit – the wage determination was the basis for the rates, but it wasn’t recorded on the payroll record itself. The new form has an explicit Wage Determination Number field tied to each weekly payroll. For audit defense, this makes the tie between the payroll record and the underlying determination unambiguous.

4. Withholding exemptions removed.

The old “No. of Withholding Exemptions” column is gone. One of the few simplifications.

5. Apprenticeship documentation on the WH-348 supplemental page.

The supplemental WH-348 page requires Registered Apprenticeship Program records, apprentice agreements, and supporting documents for each apprentice on the project. This requirement isn’t strictly new – but the new form’s tighter integration of apprentice classification on the main WH-347 means the supplemental documentation is much harder to ignore. Producing a complete WH-348 requires both the payroll data and the underlying apprentice records, every week.

What This Means for Compliance Teams

It’s tempting to think of this as “the form update.” At the operational level, it’s a data update. The form is a symptom; the substance is what your compliance system has to capture every week to produce the form correctly.

Two questions every compliance lead should be asking right now.

Are we capturing all the new fields at source?

Supporting “WH-347 2025” is one thing. Collecting the detailed fringe breakdown at the moment payroll is processed is another. If your system requires manual entry of fringe plan numbers, credit values, and funded/unfunded classifications each week, you’ll get the form out – but the data capture is fragile, error-prone, and slow. Across the projects we work on, the enhanced fringe reporting is where we’ve seen the most teams quietly behind.

Are we populating the new form directly from that data?

Most compliance systems can produce a WH-347. Far fewer populate it directly from the underlying payroll data without manual transcription. Manual transcription is where errors live – and where audit risk quietly accumulates. Every step between source data and the certified payroll form is a step where reconciliation can break and an auditor can find a discrepancy.

Direct population means your audit trail starts where your data does, not in a spreadsheet. It also means corrections flow through automatically – when a wage rate or apprenticeship ratio updates, the next week’s form reflects it without a separate fix-up workflow.

What to Do in the Next 30 Days

A practical pre-deadline checklist:

• Audit your current data capture against the new fields. Walk through a recent payroll and confirm you can produce the new fringe benefit detail, journeyworker/apprentice classifications, wage determination numbers, and apprenticeship documentation without manual addition.
• Test your form generation. Produce a full WH-347 from real project data and compare it against the official January 2025 form. Note any field that requires manual addition or transcription.
• Map your manual transcription points. Anywhere your team is moving data from one system into the form by hand is a future audit-defense weak spot. The fewer such points, the cleaner the audit posture.
• Brief your contractors and subs. Trade partners need to know what additional data they have to report. Most field failures will come from second-tier subs who haven’t updated their own processes.
• Plan your transition timeline. Even though the DOL’s mandatory deadline isn’t until October 1, 2026, project administrators on individual jobs may require the new form earlier. Don’t wait for the deadline to start running parallel reporting.

Where SkillSmart Fits

We built SkillSmart InSight IQ around the principle that compliance evidence should live where it’s created. Detailed fringe benefit data, journeyworker and apprentice classifications, and wage determination linkages are captured at source – at the time payroll is processed – and the WH-347 is populated directly from that data.

The supplemental WH-348 page, including the apprenticeship documentation section, is also automated when subs enter their apprentice data and upload supporting employee documents through the platform – which doubles as document control for those records. No manual transcription. No reconciliation gap between what’s in the payroll system and what’s on the form. No scramble at audit to track down apprentice agreements scattered across contractor file systems.

For teams running prevailing-wage compliance across federal contracts, IRA-funded clean energy projects, or state programs like CEJA, CLCPA, and the California DIR framework, the operational shift to the new WH-347 is a chance to tighten the audit trail, not just check a box.

AboutSkillSmart

SkillSmart provides construction technology to transform the way project data is tracked and reported. Our team supports some of the largest economic development and construction projects in the U.S. SkillSmart Insight helps organizations address diversity, prevailing wage, and regional workforce compliance, moving to quantify the economic impact of every project in the communities where you are building. We provide a secure solution for tracking and reporting all of the data that you need to run your project and your business. Our team works collaboratively with yours to streamline the way data is collected and stored so that when it comes time to report, analyze, quantify, and deliver the results there’s no second guessing.