Public Works Compliance Checklist for Subcontractors (California)

Winning a public works job is the easy part. Staying compliant for the life of it — wages, apprenticeship, weekly payroll, training contributions, recordkeeping — is where contractors lose money to penalties and withheld payments. This is the master checklist for subcontractors on California public works: every obligation in one place, in the order it usually hits, with links to the detailed guide for each. Use it as your pre-job and during-job reference. Where a step has its own deep dive, follow the link.

The 30-second checklist

If you do nothing else, do these:

• Confirm DIR public works registration is current — yours and the prime's.
• Pull the correct prevailing wage determination for the project and each classification.
• File the DAS-140 within 10 days of award; send DAS-142 dispatch requests 72 hours before you need apprentices.
• Submit certified payroll weekly, with a signed statement of compliance.
• Pay base + fringe every hour, and remit training fund contributions on covered hours.
• Keep everything — proof of mailing, payments, payroll — for the required retention period.

Now the detail, section by section.

1. Prevailing wage rates and the wage determination

Everything downstream depends on getting the wage right. Before you put a worker on the job:

• Identify the applicable determination. California uses DIR prevailing wage determinations by classification and locality. On jobs with both federal and state funding, the higher applicable rate governs.
• Match every worker to a real classification in that determination — "Laborer Group 1," "Operating Engineer," and so on. Misclassification is the root of most wage violations.
• Read both numbers: base rate and fringe. You owe both, on every hour. See how the two combine in our fringe benefit statement guide.
• Watch effective dates. Determinations have predetermined increases — make sure you are paying the rate in effect for the work period.

2. Apprenticeship: DAS-140 and DAS-142

Apprenticeship is two forms doing two different jobs, and confusing them is the classic mistake.

• DAS-140 — Contract Award Notice. Notifies the applicable apprenticeship committee(s) you were awarded the job. File within 10 days of award, to every applicable committee for each apprenticeable craft in your scope. Keep proof of mailing.
• DAS-142 — Request for Dispatch. Asks the committee to send apprentices. Submit at least 72 hours (excluding weekends and holidays) before you need them. Filing the 140 does not get you apprentices — you still need the 142.
• Meet the ratio. Maintain the required ratio of apprentice hours to journeyman hours, using apprentices from DIR-approved programs.

Full breakdown, deadlines, and the mistakes that trigger penalties: DAS-140 vs DAS-142.

3. Certified payroll (WH-347 / DIR A-1-131)

Every week you work, you file certified payroll. No exceptions, and the details are unforgiving.

• Weekly, one report per project, numbered sequentially, last one marked "Final."
• Federal jobs use the WH-347 (or equivalent information). California public works reports to the DIR, mostly through the online eCPR portal (the A-1-131 is the state form), in addition to the awarding body.
• Classifications must match the determination, the math must reconcile (hours → gross → deductions → net), and overtime must follow the right rule — California is daily (over 8/day OT, over 12 double time), federal is weekly (over 40).
• "No work performed" payrolls may be required for weeks you did not work, depending on the awarding body.

Column-by-column walkthrough and the top rejection reasons: Certified Payroll WH-347 guide.

4. Statement of compliance

The certification that makes your payroll legally binding.

• Signed every week by an authorized person with payroll authority — under penalty of perjury.
• Certifies the payroll is correct and complete, everyone got at least base + fringe for their classification, no improper deductions or kickbacks, and apprentices are registered.
• Fringe boxes 4(a)/4(b) must be checked and must match how the rate column was paid.

What it certifies, who can sign, the field-by-field structure, and the rejection traps: Statement of Compliance guide.

5. Fringe benefits and the training fund (CAC)

Two separate money obligations beyond the base wage — and both are common audit findings.

• Fringe benefits. The fringe rate from the determination, owed on every hour, delivered as plan contributions, cash, or a combination. A fringe shortfall is a wage violation even if the base is correct. Details: Fringe Benefit Statements.
• Training fund contributions. A per-hour contribution on apprenticeable-craft hours, owed whether or not you employ apprentices. Either pay into an approved apprenticeship program for the craft, or remit to the California Apprenticeship Council on the CAC-2. Details: CAC-2 and Training Fund.

6. Recordkeeping, audits and penalties

The job is not done when the work is done. The paperwork has to survive an audit that can come later.

• Keep everything, organized by project: the wage determination used, DAS-140/142 with proof of mailing and dispatch responses, all weekly certified payrolls and signed statements of compliance, fringe and training contribution proof (CAC-2s, plan statements, payment confirmations).
• Retain for the required period. Public works records must be kept for the retention period set by law — keep them well past project closeout.
• Reconcile across documents. Hours on certified payroll, the CAC-2, and your apprenticeship records should all agree. Auditors cross-check.
• Respond fast to requests. "We sent it" without a date-stamped record is the same as not sending it. Missing or late records can lead to withheld payments, penalties per worker per day, and debarment from future public work.

Compliance is not one big thing — it is a dozen small habits that have to happen every week. Build the system once and the job runs clean.

The compliance timeline: when each thing happens

Obligations land at different points in the job. Mapping them to the timeline is the easiest way to stop missing deadlines:

• Before you bid / before award: confirm DIR public works registration is current, and price the job using the correct prevailing wage determination including fringe and training contributions.
• Within 10 days of award: file the DAS-140 to every applicable apprenticeship committee, and save the proof.
• Before you need apprentices (72 hours out): send the DAS-142 dispatch requests.
• Every week you work: run payroll at base + fringe, file certified payroll with a signed statement of compliance, and track the apprentice-to-journeyman ratio.
• Periodically (often monthly): remit training fund contributions — to an approved program or the CAC on the CAC-2 — reconciled to your payroll hours.
• At closeout: mark the final certified payroll "Final," settle any outstanding contributions, and file the complete record set.
• After the job — for the full retention period: keep everything retrievable in case of audit.

What gets you caught (and what protects you)

Audits and worker complaints tend to surface the same handful of failures: misclassification, fringe shortfalls, missing or unsigned statements of compliance, skipped apprenticeship requests, and unpaid training contributions. The defense against every one of them is the same — accurate classification up front, paying the full base + fringe on every hour, certifying weekly, and keeping date-stamped proof of everything you filed and paid. Penalties on public works can run per worker per day, payments can be withheld until you cure the violation, and repeated failures can lead to debarment from future public work. None of that happens to a contractor whose paperwork is consistent and on time.

Final pre-submission checklist

Run this before you send each weekly package:

• Every worker matched to a real classification in the current determination.
• Base + fringe met on every hour; overtime on the California daily rule where it applies.
• Payroll math reconciles: hours → gross → deductions → net.
• Statement of compliance signed this week by an authorized person, with 4(a)/4(b) checked to match the rate column.
• Apprentices registered, within ratio, and consistent with your DAS filings.
• Training contributions current and reconciled to payroll hours.
• Proof of every filing and payment saved to the project file.

Run it in TradePRO

TradePRO ties this whole checklist together — wage determinations, DAS-140/142, weekly certified payroll, statements of compliance, fringe and CAC-2 training contributions, and the proof behind all of it — tracked per project so nothing falls through the cracks. Run your next public works job in TradePRO — free →

This article is general information for contractors, not legal advice. Prevailing-wage rules and forms change — confirm current requirements with the U.S. Department of Labor and the California DIR before relying on this.