How to Report Apprentices on the WH-347 Form
— WH347.io Team
Apprentices are covered under Davis-Bacon but reported differently than journey-level workers. Here's who qualifies, what documentation is required, how to fill in each column, and what the 2025 form changes added to the apprentice section.
Apprentices on federal construction projects are covered by the Davis-Bacon Act — but they're reported differently than journeymen, and the rules for what qualifies as an apprentice are specific. Getting this wrong doesn't just create a form error; it can mean you've been paying a worker less than the prevailing wage without a valid legal basis for doing so.
Who Qualifies as an Apprentice Under Davis-Bacon
Under Davis-Bacon regulations, an apprentice is a person employed in a skilled trade who is individually registered in a bona fide apprenticeship program registered with the DOL's Office of Apprenticeship or a state apprenticeship agency recognized by the DOL. Informal on-the-job trainees, helpers, or workers you describe as 'apprentices' internally do not qualify unless they meet this registration requirement.
This distinction matters because the only legal basis for paying less than the full journeyman prevailing wage rate is holding valid apprentice status under a registered program. Without it, the worker must be paid at the full journey-level rate for their classification.
Required Documentation Before You List an Apprentice
Before listing a worker as an apprentice on the WH-347, you need to have on file:
- The name of the DOL-registered or state-recognized apprenticeship program the worker is enrolled in.
- The worker's individual registration number in that program.
- The approved wage schedule for the program, showing what percentage of the journeyman rate applies at each apprenticeship level.
- Evidence that the apprentice is currently registered — not just that they were registered at some past point.
The 2025 updated WH-347 strengthened these documentation requirements. The form now expects the program name and registration number to be available for audit — not just the worker's name and a reduced wage rate.
Apprentice Wage Rates: How They Work
Apprentice wages are expressed as a percentage of the journeyman prevailing wage rate for the applicable classification. The percentage is set by the registered apprenticeship program's approved wage schedule and typically increases as the apprentice progresses through the program. For example, a first-year apprentice electrician might be entitled to 60% of the journeyman Electrician prevailing wage rate, rising to 80% in year two and 90% in year three.
Frequently Asked Questions
Who counts as an apprentice on a Davis-Bacon project?
Under Davis-Bacon regulations, an apprentice must be individually registered in a bona fide apprenticeship program registered with the DOL's Office of Apprenticeship or a recognized state apprenticeship agency. Workers who are informally trained on the job, or who are called apprentices internally without registration, do not qualify and must be paid at the full journeyman prevailing wage rate.
What wage rate do I use for apprentices on the WH-347?
Apprentice wages are calculated as a percentage of the journeyman prevailing wage rate, as specified in the registered apprenticeship program's approved wage schedule. The percentage varies by program and increases as the apprentice progresses. Apply the percentage that corresponds to the worker's current level — verify this against the approved schedule before setting any rates.
How do I classify an apprentice in Column 3 of the WH-347?
List the trade classification followed by 'Apprentice' — for example, 'Carpenter Apprentice' or 'Electrician Apprentice.' Do not use 'Helper' or 'Trainee' unless those are explicitly listed as separate classifications in the applicable wage determination for the project.
What is the apprentice-to-journeyman ratio on federal projects?
The ratio is set by the individual registered apprenticeship program — a common ratio is one apprentice per three or four journeymen in the same trade on the same project. If you employ more apprentices than the ratio allows, the excess must be paid at the full journeyman prevailing wage rate. The ratio is calculated at the project level, not company-wide.