What Happens If You Submit the Old WH-347 After September 30?
— WH347.io Team
Five weeks until the deadline. After September 30, contracting agencies must reject any WH-347 submitted on the old form. Here's exactly what rejection means for your project — delayed payments, compliance flags, and how to recover if it happens to you.
Five weeks from today is September 30, 2026 — the last day the old WH-347 form is accepted. Understanding exactly what happens if you miss the deadline isn't pessimism; it's motivation. The consequences are real and predictable, and the scenario is entirely avoidable.
For the full background on what's changing, see: New WH-347 Form: September 30, 2026 Deadline.
Consequence 1: Rejection by the Contracting Agency
After September 30, contracting agencies are required by the Department of Labor to reject any certified payroll submission made on the old form. This is not discretionary — agencies that accept submissions on an expired form are themselves out of compliance with the DOL's procurement requirements. The rejection is automatic and immediate upon review.
Rejection means the certified payroll for that work week is not accepted into the project record. In the agency's system, that week appears as a missing or non-compliant payroll — even though you did file, just on the wrong form.
Consequence 2: Withheld Progress Payments
Federal construction contracts give contracting agencies the authority to withhold progress payments when certified payroll submissions are missing or non-compliant. A rejected old-form submission creates exactly that situation — a week where no compliant certified payroll is on file.
Payment withholding can happen quickly. Some agency contracting officers review payroll submissions in real time with each pay application. If a rejection triggers a hold, your pay application for that period may be partially or fully withheld until the compliant resubmission is received and processed. For a contractor financing a project on cash flow, a withheld payment is a serious operational problem.
Consequence 3: Compliance Flags on Your Contractor Record
Using a form with an expired OMB approval number is a compliance deficiency in the DOL's records. A single rejected submission caught and corrected promptly will likely be treated as an administrative error. Multiple rejected submissions, or a pattern of non-compliance, can escalate to a formal finding in the project's compliance review.
Frequently Asked Questions
What happens if a contracting agency receives a WH-347 on the old form after September 30?
The agency is required to reject it. After September 30, agencies cannot accept submissions made on the old form. Rejection means the payroll for that week is not recorded as compliant, which can trigger payment holds and create a gap in your project's certified payroll record.
Can an agency withhold payment because of an old-form submission?
Yes. Federal construction contracts give agencies the authority to withhold progress payments when certified payroll submissions are missing or non-compliant. A rejected old-form submission creates a week with no compliant payroll on file, which can result in partial or full payment withholding until a compliant resubmission is received.
Is using the old WH-347 form after September 30 a compliance violation?
Yes. Submitting on a form with an expired OMB approval number is a compliance deficiency. A single incident corrected promptly is typically treated as an administrative error. Repeated incidents or an unresponsive contractor can escalate to formal compliance findings.
How quickly can I recover if a submission is rejected for using the old form?
Recovery is straightforward: generate the same payroll data on the new form and resubmit as quickly as possible with a brief cover note explaining the correction. Most agencies process compliant resubmissions within their normal review cycle. Payment holds are typically released once the corrected submission is accepted.
If my subcontractor submits on the old form after October 1, does that affect me as the prime?
Yes. As prime contractor, you bear compliance responsibility for the entire project. A rejected sub payroll creates a gap in the project record that can affect progress payments across the project. Notify all subs in writing now — five weeks is sufficient time for them to update their process.
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