California certified payroll (DIR eCPR)

Who has to submit certified payroll to DIR?

Every contractor and subcontractor on a covered California public works project submits its own electronic certified payroll records (eCPRs) directly to the Labor Commissioner. That's Labor Code 1771.4(a)(3), and DIR's FAQ adds that each company files separately for each project. Prevailing wage applies to public works over $1,000, according to DIR's FAQ.

DIR's FAQ also says filing with someone else doesn't count. Certified payroll sent to the prime, a union, the awarding body or a labor compliance program is a separate requirement, and the DIR filing is still due.

Federal funding doesn't take a job out of the state system. DIR's FAQ says federally funded or assisted projects run by a California awarding body follow state law, including contractor and project registration, eCPRs, and California prevailing wage rates where they're higher than the Davis-Bacon rates. Projects awarded by and under the complete control of a federal agency are the exception.

Which projects are exempt from eCPR?

DIR lists three groups:

The small project amount is the whole contract between the awarding body and the prime, not your subcontract. DIR's FAQ says a subcontract under the threshold on a prime contract over it does not fall under the exemption. The same FAQ says contractors on small projects still keep certified payroll records and provide them to the Labor Commissioner's Office on request, and Labor Code 1771.4(a)(4) says unregistered contractors on those jobs keep the records at least three years after the work is done.

How often are eCPRs due?

At least monthly. Labor Code 1771.4(a)(3)(A)(i) defines monthly as at least once every 30 days while work is being performed on the project, and within 30 days after the final day of work. The contract with the awarding body can require more frequent filing. DIR's FAQ calls weekly filing, or filing at the end of each payroll period, the best practice.

A late filing can draw a penalty of $100 for each day in violation, up to $5,000 per project. Under 1771.4(a)(3)(C), the Labor Commissioner can't levy it until the records are 14 days past the deadline, and it only applies to the contractor or subcontractor that didn't file.

What does the awarding body register before you can file?

The project. Labor Code 1773.3 says the awarding body gives DIR notice of the contract within 30 days of the award, and no later than the first day a contractor has workers on the job. DIR calls this Project Registration; it was formerly known as the PWC-100. The notice includes the prime's and each listed subcontractor's name and DIR registration number, the bid and award dates, the contract amount, the expected start and finish dates and the jobsite location.

Registration creates the DIR project ID that every eCPR is filed under. DIR's FAQ says contractors can't submit eCPRs until the project is registered, and to ask the awarding body, then DIR, if it isn't. Penalties for a missing notice fall on the awarding body, up to $10,000 per project, and 1773.3(h) says a contractor can't be made liable for them.

How does public works contractor registration work?

Labor Code 1725.5 says a contractor, including a subcontractor, has to be registered with DIR to bid on, be listed in a bid for, or work on a public works contract. DIR lists these qualifications:

• Workers' compensation coverage for any employees.
• Only registered subcontractors on its public works jobs.
• A Contractors State License Board license if the trade needs one.
• No delinquent unpaid wage or penalty assessments.
• Not debarred under federal or state law.

Registration runs by fiscal year, July 1 to June 30. DIR's fee is $400 for one year, $800 for two or $1,200 for three. DIR's contractor registration page lists these penalties:

DIR's contractor registration page says contractors that haven't created a new account since May 24, 2024 need one on Public Works Website Services. Registration isn't required on projects under the small project thresholds (1725.5(f)).

What does Labor Code 1776 require in the payroll records?

Labor Code 1776(a) says each contractor and subcontractor keeps payroll records showing, for each worker on the public work:

• Name, address and Social Security number
• Work classification
• Straight time and overtime hours worked each day and week
• The actual per diem wages paid

As amended by AB 538 (effective January 1, 2026), 1776(a) says each payroll record contains or is verified by a written declaration under penalty of perjury that the information is true and correct and that the employer has complied with Labor Code sections 1771, 1811 and 1815 for its employees' work on the project.

Section 1776(c) says records not furnished directly to the Labor Commissioner under 1771.4 go on forms provided by the Division of Labor Standards Enforcement, or contain the same information. DIR's suggested form is the Public Works Payroll Reporting Form, Form A-1-131. The copy on DIR's site is marked "New 2-80" and has columns for name, address and SSN, withholding exemptions, work classification, hours each day (straight time and overtime), total hours, hourly rate, gross earned on this project and all projects, deductions and contributions (federal tax, FICA, state tax, SDI, vacation and holiday, health and welfare, pension, training, fund administration, dues, travel and subsistence, savings, other), net wages and check number. The certification is on the back. Title 8, section 16401 says the Labor Commissioner may require Form A-1-131 when a contractor doesn't meet 1776.

DIR's forms page says Form A-1-131, or the information on it, is required if the Labor Commissioner investigates, and it doesn't satisfy the eCPR filing.

What happens when someone asks for your payroll records?

Labor Code 1776(d) says the contractor files a certified copy of the records with the entity that asked within 10 days after receiving a written request. If the records aren't provided within the 10 days, 1776(h) sets a penalty of $100 for each calendar day, or part of a day, for each worker until the contractor complies, and the Division of Labor Standards Enforcement can have it withheld from progress payments. A prime isn't penalized under 1776 for a subcontractor's failure to provide records.

The Labor Commissioner's Public Works Manual (October 2023) says the eCPR filing and a written records request are separate duties: filing eCPRs doesn't excuse a response to a request, and answering a request doesn't stop the eCPR filing. Copies released to the public are redacted to remove workers' names, addresses and Social Security numbers (1776(e)).

What are the apprenticeship forms on California public works?

DIR says public works contracts of $30,000 or more carry apprenticeship duties for every contractor and subcontractor on the project, unless the craft doesn't use apprentices according to the prevailing wage determination. Two Division of Apprenticeship Standards forms come up:

• DAS 140 (Rev. 1/04), Public Works Contract Award Information, sent to the apprenticeship committees for the craft in the project's area, not to DAS.
• DAS 142 (6/24), Request for Dispatch of an Apprentice, sent to the apprenticeship committee at least three business days before apprentices are needed, according to DIR's apprenticeship page.

DIR's apprenticeship page also lists training fund contributions in the amount set in the prevailing wage rate, and states a ratio of one hour of apprentice work for every five hours of journeyman work. For the rules on your craft, DIR points contractors to the DAS public works page.