Apprentices and Trainees on Form WH-347

David Gul · Last updated September 18, 2026

A worker may be paid less than the journeyworker prevailing wage on Davis-Bacon work only if they are individually registered in a bona fide apprenticeship program registered with the Department of Labor’s Office of Apprenticeship or a recognized state apprenticeship agency, or are in the first 90 days of a probationary period certified as eligible by one of those. The apprentice is paid the program’s percentage for their level, applied to the journeyworker’s basic rate in the wage determination, and the number of apprentices on the site may not exceed the ratio allowed. Anyone else at an apprentice rate is a journeyworker paid short, and the difference is owed.

Registration comes first

29 CFR 5.5(a)(4) is the clause. An apprentice is a person employed pursuant to and individually registered in a program registered with the Office of Apprenticeship or a state agency recognized by it, or a person in the first 90 days of probationary employment as an apprentice who has been certified as eligible for probationary employment by the office or agency. A trainee is a person in the first 90 days or otherwise in a training program certified in advance by the Office of Apprenticeship. Pre-apprentices and helpers are neither, and are paid the full rate for the work they do.

Registration is individual. A company’s program being registered is not enough; the worker’s own registration is what the certification on page 2 asserts.

The ratio

The allowable ratio of apprentices to journeyworkers on the job site in any craft may not be greater than the ratio permitted to the contractor for its entire workforce under the registered program, and since the 2023 rule the ratio and the wage rates that apply are those of the locality where the construction is performed, where the two differ. When the ratio is exceeded, the apprentices over the ratio must be paid the full journeyworker rate for that day. Ratio compliance is checked day by day, not on the week’s totals.

The percentage, and which rate it applies to

The program states a percentage of the journeyworker rate for each level of progress. That percentage is applied to the journeyworker’s basic hourly rate in the wage determination for the classification, not to the rate in the program’s own schedule. Where a program states dollar amounts instead of percentages, the Department of Labor’s approach is to convert them to a percentage of the program’s own journeyworker rate, then apply that percentage to the determination. A program journeyworker rate of 16.00 with a first-year step of 8.00 is a 50 percent apprentice; on a determination whose journeyworker basic rate is 22.50, that apprentice is paid at least 11.25 an hour.

Fringe for apprentices

Fringe follows the program. If the registered program specifies the fringe benefits apprentices receive, the contractor pays those. If the program is silent on fringe, the apprentice is owed the full fringe amount listed in the determination for the classification. Paying a percentage of the fringe because the wage is a percentage is a finding.

On the form

• Column 2 shows RA for a registered apprentice or an approved trainee, J for everyone else. The 2025 revision has no separate column for the level or the percentage.
• Column 3 carries the classification being learned, the same wording as the journeyworker line.
• Column 6A shows the apprentice rate actually paid, which will be below the determination’s basic rate; the reviewer will look for the RA in column 2 and for the registration on file to explain it.
• Page 2, paragraph 3 is the certification that every apprentice on the payroll is registered. Many agencies ask for a copy of each apprentice’s registration with the first payroll they appear on.

More in this series: Prevailing Wage and Fringe Benefits on Certified Payroll · How to Fill Out Form WH-347, Column by Column · All certified payroll guides