WH-347 Statement of Compliance: Who Can Sign
— 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
Frequently Asked Questions
Who can sign the WH-347 Statement of Compliance?
The Statement of Compliance must be signed by an officer of the company or an individual with written authorization from an officer. This includes the owner, corporate officers (president, VP, treasurer), and designated payroll administrators who have been given written signing authority. The signatory must have actually reviewed the payroll data being certified.
What does the Statement of Compliance certify?
It certifies three things: that the payroll information is correct and complete, that each worker was paid at least the applicable prevailing wage rate for their classification, and that fringe benefits were paid as described — either into an approved plan or as additional cash wages. The certification is made under federal law and knowingly false statements carry criminal penalties.
Which checkbox do I check on the Statement of Compliance?
Check box (a) if fringe benefits were paid into approved benefit plans (health insurance, pension, etc.). Check box (b) if fringe benefits were paid as additional cash wages directly to workers. Check both if some workers receive benefits through a plan while others receive cash-in-lieu, or if your plan partially covers the fringe rate and cash makes up the difference.
What happens if I sign the Statement of Compliance and there's an error?
File a corrected WH-347 as soon as you discover the error. Label it as a correction, reference the original payroll number and week ending date, and include a brief explanation of what changed. The DOL distinguishes between honest mistakes that are promptly corrected and intentional falsification. Quick, transparent corrections rarely escalate beyond an administrative note.