- What: Certified payroll for NY prevailing-wage work must now be filed electronically through the state's Certified Payroll Portal.
- When it started: January 1, 2026 — for both new and existing covered projects.
- How often: At least every 30 days from the project start date (not weekly).
- Penalty: More than 14 days late = $100/day. Willfully false records = up to $1,000 and a Class E felony.
- Catch: You must be registered in the Public Work Contractor Registry and have a PRC number first.
What actually changed
New York didn't create a new obligation to keep certified payroll — that already existed under Article 8 of the Labor Law. What changed is how you submit it. Paper and emailed PDFs to the awarding agency are out. Starting January 1, 2026, certified payroll for covered work goes directly to the New York State Department of Labor through an online portal.
The rule applies to both brand-new projects and jobs that were already running into 2026. You don't have to re-file anything from before January 1, 2026 — but every payroll for work performed on or after that date has to go through the system.
Does this apply to you?
It applies if you perform work covered by Article 8 of the NYS Labor Law — that's public work projects, privately owned projects that carry prevailing-wage requirements under Section 224-a, and certain renewable energy projects under Section 224-d. If a letting agency or developer told you the job is prevailing wage, you're almost certainly covered. When in doubt, the agency or general contractor is supposed to tell you; if they can't, the DOL's Bureau of Public Work will.
Two important exceptions for small subs:
- New York City work is separate. Public work performed by or for NYC, and roadway excavation under NYC-issued permits, is filed through NYC's own certified payroll database — not the state portal.
- Federal-only Davis-Bacon jobs are out. If a project is purely federal and state prevailing wage doesn't apply, you don't submit it to the NY system (you still file your federal WH-347).
One thing that trips people up: even if your general contractor doesn't ask for certified payroll, the law still requires you to submit it. The obligation is yours, not theirs.
What you need before you can file
You can't just log in and start typing. Get these lined up first:
- Contractor registration. Every contractor and subcontractor doing Article 8 work must be in the Public Work Contractor and Subcontractor Registry, including out-of-state firms.
- A PRC number for the project. This is required — a project can't be entered without one. The letting agency issues it; if you don't have it, you have to chase it down before you can file.
- Your wage schedule. Generated with the PRC number. Your classifications and rates have to match what's in the system.
- Worker details. Names, addresses, work classifications, hours, and Social Security numbers.
- Supplemental benefit documentation — unless every benefit is paid as cash wages, in which case the cash is simply added to the reported wage rate.
How often you file (and the "no work" trap)
This is the biggest mental shift from federal WH-347. Federal certified payroll is weekly. New York's electronic system is every 30 days, counted from the project start date. The portal dashboard shows your due dates so you're not guessing.
But you still have to account for weeks with no work. If your crew didn't touch the job during a reporting period, you report that — there's a "no work" entry, and a pause feature for longer gaps so you don't have to enter empty weeks one at a time. Skipping these is a common way to fall out of compliance without realizing it.
How you submit
Two ways into the state portal: manual entry, where you type each worker and their hours, or XML bulk upload, where you submit a formatted file. The DOL publishes an XML template, a sample file, and the validation rules. If you go the XML route, your classifications have to match the system's classification list exactly, or the upload fails.
For a sub with a handful of workers on one or two jobs, manual entry is usually fine. The pain shows up when you're running several PRC numbers at once, juggling union and non-union crews (which have to be filed separately, by FEIN), and matching classifications by hand every cycle. That's the part software exists to remove.
What it costs to get it wrong
$100/day
If you're more than 14 days late, that's the fine for every additional day until you file.
Willfully filing inaccurate payroll records is worse: a civil penalty of up to $1,000 and potential Class E felony exposure under the Labor Law.
One bit of breathing room: the DOL has said it's using discretion and not issuing late fines right now while contractors get used to the system. That grace won't last — they've promised to announce and email registered contractors before they start fining. The smart move is to file correctly now and not be the one scrambling when enforcement turns on.
Don't hand-file every 30 days
PrevailComply maps classifications, handles fringe calculations, and prepares New York and federal certified payroll, helping reduce late-filing and underpayment risk. Tell us you're in NY and we'll prioritize it.
The bottom line
If you do prevailing-wage work in New York, electronic certified payroll isn't optional anymore. Get registered, get your PRC number, file every 30 days, and don't skip the no-work periods. Do that and the $100-a-day clock never starts. While you're at it, the free WH-347 generator handles your federal report, the WH-347 step-by-step guide walks the federal form in detail, the fine calculator shows what penalties add up to, and the California and Illinois guides cover those states' rules.
This guide is general information for small subcontractors, not legal advice, and reflects NYS Department of Labor guidance as of June 2026. Rules and dates can change — always confirm against the current DOL guidance and your project's wage schedule, or contact the Bureau of Public Work directly.