The Statement of Compliance on Form WH-347: What Signing It Asserts

David Gul · Last updated September 18, 2026

Page 2 of Form WH-347 is the Statement of Compliance: a signed certification that the payroll on page 1 is correct and complete, that every worker was paid the full wages earned with no rebate and no deductions beyond those the Copeland Act regulations permit, that the rates paid are not less than the wage determination for the work performed, that any apprentices are registered, and that fringe benefits were paid either into bona fide plans or in cash, as the ticked box says. The contract clause requires it with every weekly payroll, and a properly completed page 2 satisfies that requirement. Signing it is what turns a spreadsheet into a certified payroll.

What the clause requires

29 CFR 5.5(a)(3)(ii) requires each payroll to be accompanied by a Statement of Compliance signed by the contractor or subcontractor, or by the person who supervises the payment of the persons employed under the contract. The regulation lists what the statement must certify, and page 2 of the form carries exactly those certifications, numbered.

The four paragraphs

1. Payment in full, and the deductions. That during the payroll period the workers were paid the full weekly wages earned, that no rebates were taken or will be taken, and that no deductions were made other than those permitted under the Copeland Act regulations in 29 CFR part 3. The signer lists any other deductions in the space provided, which is why the deductions guide matters here.
2. The payroll is complete and the rates are right. That the records submitted are correct and complete, that the wage rates paid to each worker are not less than the applicable rates in the wage determination incorporated into the contract, and that the classifications shown match the work performed.
3. Apprentices. That any apprentices on the payroll are registered in a bona fide apprenticeship program registered with a recognized state agency or the Department of Labor’s Office of Apprenticeship, and that any trainees are in a program approved by that office.
4. Fringe benefits. With three ways to answer it, below.

The fringe benefit boxes

Paragraph 4 has boxes for how fringe was met, and the box ticked has to agree with columns 6B and 6C on page 1.

Box	Tick it when	Page 1 shows
(a) Paid to approved plans, funds or programs	The fringe in the determination was paid into bona fide plans for the workers’ benefit	A figure in 6B for each worker
(b) Paid in cash	The fringe was paid to the workers as cash, on top of the basic rate	A figure in 6C, and the cash is part of the gross
(c) Exceptions	Some workers or classifications were handled differently: part in a plan, part in cash, or a plan for some crafts only	The exceptions table on page 2 names the craft and explains

A contractor with a health plan that covers part of the fringe and cash for the rest ticks (a) and (b) and explains in (c). Leaving the exceptions blank while 6B and 6C both carry figures is a mismatch reviewers notice.

Who signs

The form asks for the name and title of the signer. It may be the owner or an officer of the contractor, or the employee who actually supervises the payment of wages, such as a payroll manager. The signer is certifying from personal knowledge or from records they supervise, which is why an outside bookkeeper who never sees the timecards is a poor choice.

What a false statement risks

The statement on page 2 says it plainly: the willful falsification of any of the above statements may subject the contractor or subcontractor to civil or criminal prosecution under Title 18 (false statements to a federal agency, 18 U.S.C. 1001) and Title 31 (the False Claims Act) of the United States Code. Beyond that, a payroll that turns out to be wrong exposes the contractor to back wages with interest, and in serious cases to debarment from federal contracting. None of that needs the signer to have intended harm; a carried-over rate that was never checked is the usual road there.

More in this series: What Form WH-347 Is, Who Files It, and How Often · Deductions on Certified Payroll: What the Copeland Act Allows · All certified payroll guides