Do subcontractors have to submit certified payroll?

Yes. On Davis-Bacon covered work, every contractor and subcontractor with laborers or mechanics on the project submits weekly certified payrolls for its own workers, and lower-tier subcontractors do too.

Is the prime contractor responsible for subcontractor payrolls?

Yes. Under 29 CFR 5.5 the prime contractor is responsible for the submission of all certified payrolls by all subcontractors, and for subcontractors' compliance with the labor clauses. The prime can be liable for unpaid wages owed to workers of lower-tier subcontractors.

In California, do subcontractors submit through the prime?

No. DIR says each contractor and subcontractor must submit certified payroll records directly to the Labor Commissioner; submitting to the prime does not satisfy the requirement. Primes and awarding bodies may still ask for copies.

Certified Payroll for Subcontractors: Rules and Prime Checklist

Who does what

Item	Federal Davis-Bacon	California public works
Who prepares payrolls	Each contractor and subcontractor, for its own laborers and mechanics	Each contractor and subcontractor
Where they go	To the contracting agency, or the applicant, sponsor or owner on federally assisted work	Directly to the Labor Commissioner (DIR eCPR)
Route	Usually through the prime; the prime "is responsible for the submission of all certified payrolls by all subcontractors"	Not through the prime; sending to the prime "does not satisfy" the duty
How often	Weekly, for each week with covered work	At least monthly; weekly recommended; your contract may require more
Prime's liability	Responsible for subs' compliance; liable for unpaid wages to lower-tier workers	Joint liability for subs' wage violations under California law (Labor Code 1743)
Records kept	3 years after all work on the prime contract is completed	Per Labor Code 1776 and the contract

Flow-down: the clauses go to every tier

Under 29 CFR 5.5(a)(6), the prime must put the Davis-Bacon labor clauses and the wage determination into every subcontract, with a clause requiring each sub to pass them down to its own subcontractors. The regulation then makes the prime "responsible for the compliance by any subcontractor or lower tier subcontractor". If a third-tier sub underpays its crew, the prime and the responsible subs are liable for the back wages and interest, and can face debarment.

Since DOL's 2023 rule update (29 CFR 5.6(e)), the clauses and the right wage determination apply by operation of law even if they were wrongly left out of a contract, so a missing clause doesn't excuse anyone.

How a subcontractor fills the WH-347

Prime or subcontractor: the 2025 form has a checkbox in the header. Subs tick Subcontractor.
Business name and address: the subcontractor's own, not the prime's.
Project and contract number: the prime contract's project details, so the agency can match payrolls to the job.
Payroll number: each sub keeps its own sequence, starting at 1 for its first week on the project.
Final: tick "Submission of final DBRA certified payroll form" on the sub's last week, even if the prime keeps working.
Signature: an officer or authorised employee of the sub signs page 2. The prime doesn't sign the sub's payroll.

The free generator has a Prime/Subcontractor choice and remembers each project's details, so a sub can produce the week's form from its payroll export in minutes. California subs can download the DIR eCPR XML for their own submission.

What primes check each week

Primes carry the risk, so most review every sub payroll before forwarding it. A practical weekly checklist:

Received on time for every sub that was on site, including no-work weeks if the agency wants them. Compare against the daily logs or sign-in sheets.
Headcount matches the site. Workers seen on site are on the payroll; nobody is missing.
Classifications are real ones from the wage determination, and match the work done (a "laborer" running a backhoe is a red flag).
Rates meet the wage determination: basic rate plus fringe per hour, for each classification.
Overtime paid at time and a half of the basic rate for hours over 40 in the week.
Apprentices are registered, paid the program's rate for their level, and within the ratio (see apprentices).
Fringe credits are listed on page 2 for plan contributions in column 6B (see fringe benefits).
Arithmetic adds up: hours × rate, gross, deductions, net.
Signed page 2 with the right boxes checked; no full SSNs on the form.
Payroll numbers in sequence, and a final payroll at the end.

When something's wrong, return the payroll with a written note and keep a copy. Underpayments are cheapest to fix in the next payroll, with restitution shown.

Withholding when subs fall short

The contract clauses let the agency withhold enough from the prime's payments to cover back wages owed to any worker on the project, including a sub's. To protect themselves, primes often write payroll submission into the subcontract as a condition of payment: no compliant payrolls, no progress payment. That's a contract choice, not a federal rule, so it belongs in the subcontract.

Sources

General information as of November 2026, not legal advice. Your contract, the wage determination and the agency's instructions govern.

Questions

Do lower-tier subcontractors file certified payroll?

Yes, every tier with laborers or mechanics on the project.

Can the prime submit payrolls for the sub?

On federal work the prime collects and forwards them, but each sub prepares and signs its own. In California each sub submits its own records to DIR.

Who keeps the records?

Each employer keeps its own payrolls and basic records for at least 3 years after the prime contract's work is complete.

Certified payroll for subcontractors