WH-347 Statement of Compliance: Who Can Sign

April 30, 2026 — WH347.io Team

The Statement of Compliance on page 2 of the WH-347 is a legal document — not a formality. Here's who is authorized to sign it, what each checkbox actually means, and what happens if you sign something that turns out to be inaccurate.

Page 2 of the WH-347 is called the Statement of Compliance. It's what transforms a payroll summary into a certified payroll report — and it's the reason the Davis-Bacon submission carries legal weight. When you sign it, you are not acknowledging receipt of a form. You are making a federal legal certification under penalty of law.

Most contractors sign it every week without thinking much about it. That's fine when your payroll is correct. It becomes a serious problem when it isn't.

What the Statement of Compliance Certifies

By signing the Statement of Compliance, you are certifying three things: (1) the payroll information on page 1 is correct and complete; (2) each worker listed was paid wages no less than the applicable prevailing wage rate for their classification; and (3) fringe benefits were paid as described — either into an approved plan or as additional cash wages.

The certification is made under the Copeland Anti-Kickback Act and the Contract Work Hours and Safety Standards Act. Knowingly making a false statement on the form is a federal crime, and civil liability under the False Claims Act may also apply when federal funds are involved.

Who Is Authorized to Sign

The Statement of Compliance must be signed by an officer or individual who is legally authorized to make the certification on behalf of the company. In practice, that typically means:

• The company owner or sole proprietor.
• A corporate officer — president, VP, treasurer, secretary, or other officer named in the company's organizational documents.
• A payroll administrator or other employee who has been given written authorization by an officer to sign on the company's behalf.

The key requirement is that the person signing has actual authority — either by position or by written delegation — and has reviewed the payroll data being certified. A bookkeeper who prepared the report but was never given signing authority is not a valid signatory. If you delegate signing authority, keep a written record of that delegation in your files.

What the Two Checkboxes Mean

The Statement of Compliance has two checkboxes that govern how you're representing your fringe benefit payments. You must check one or both — leaving both blank is a form error.

• Checkbox (a): Fringe benefits equal to at least the prevailing fringe rate were paid to approved plans, funds, or programs for the benefit of workers. This is the correct box if you provide health insurance, pension contributions, or other bona fide benefits that meet or exceed the required fringe rate.
• Checkbox (b): Fringe benefits equal to at least the prevailing fringe rate were paid in cash directly to each worker in addition to their base wages. This is the correct box if you pay cash-in-lieu of benefits, or if your benefit plan doesn't fully cover the required fringe rate and you top it up in cash.
• Both checkboxes: Check both if some workers receive benefits through a plan and others receive cash-in-lieu, or if benefits partially satisfy the fringe rate and cash makes up the remainder.

What Changed in the 2025 Updated Form

The 2025 revised WH-347 updated the language in the Statement of Compliance section. The legal obligations did not change, but the specific wording on page 2 is different from the prior version. If you are signing a Statement of Compliance that was printed from an old PDF or filled in from a template created before 2025, you may be signing a form with superseded language. The contracting agency may flag this, and after October 1, 2026, submissions on the old form will be rejected.

What to Do If You Find an Error After Signing

Discovering an error after you've submitted a certified payroll report does not automatically mean you're in legal trouble — it means you need to act quickly. File a corrected WH-347 as soon as possible. Label it as a correction referencing the original payroll number and week-ending date, include a brief written explanation of what changed and why, and submit it to the contracting agency promptly.

The DOL distinguishes between honest mistakes that are promptly corrected and patterns of inaccuracy or deliberate falsification. A single corrected submission, handled quickly and transparently, rarely escalates beyond an administrative note. Repeated errors, late corrections, or inconsistencies across multiple weeks are a different matter.

Managing the Statement of Compliance at Scale

If you are running multiple projects with dozens of workers, the practical challenge isn't knowing who can sign — it's making sure the person signing has actually reviewed the data. WH347.io builds a review step into the submission workflow: before the Statement of Compliance can be finalized, the preparer must confirm the payroll data. The signature is yours; the verification that the numbers are right is built into the process.

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