Federal Payroll Forms Invalid After September 2026 — HVAC Contractors Face Hard Deadline

HVAC contractors working on federal projects exceeding $2,000 have until September 30, 2026 to switch to updated WH-347 certified payroll forms — after that deadline, the old forms will no longer be valid for federal contract compliance.

The Department of Labor's updated WH-347 form, which became available in 2025, introduces new compliance requirements that could trip up contractors still using the previous version. One overlooked form update could cost contractors three years of federal contract eligibility—or worse.

New Form Requirements Hit Payroll Processes

The new form requires more detailed documentation of fringe benefits, including details like specific hourly rates, and payment methods. Apprentices must now be clearly identified as registered apprentices, while Journeyworkers also have to be marked as such.

The updated WH-347 consolidates reporting under a single form name, with Page 1 still covering payroll data, and Page 2 focusing on compliance certification, fringe benefits, and apprenticeship details. Contractors will now see a designated field for the Wage Determination Number on the form, which helps confirm that reported wage rates align with the correct Davis-Bacon wage decision for their project. Each worker must now be assigned a unique Worker Entry Number, starting at "1" and continuing sequentially across rows and pages.

Federal Projects at Risk

The Davis-Bacon Act makes the submission of certified payroll reports mandatory for federal construction contracts valued at $2,000 or more. That includes construction, repairs, or alterations for public buildings and public works. For HVAC contractors, this covers a significant portion of government work, from military base installations to federal building retrofits.

The new WH-347 form addresses gaps in the old system and introduces requirements designed to protect workers and ensure compliance: Expanded Fringe Benefits Reporting You must now specify whether fringe benefits are paid in cash or contributed to approved plans (health insurance, pension, training programs).

Transition Period Creates Confusion

While the previous WH-347 form is valid until 9/30/2026, some project administrators are already requiring the updated version. However, some agencies and awarding bodies may require the updated form immediately. Double-check with your project administrator to avoid any issues. The Department of Labor (DOL) is encouraging contractors and subcontractors to start using the updated 2025 form as soon as possible to stay compliant.

Compliance experts report hearing the same response daily: "We'll switch when we have to." But that time is almost here. The updated WH-347 form isn't a suggestion. It's a federal requirement.

Software Scrambles to Keep Up

Certified payroll software providers are actively updating their systems to accommodate all new requirements. As compliance experts note, these changes have big impacts on clients' compliance requirements and workflows, making it a focus to ensure Certified Payroll Reporting software stays as up-to-date as possible to accommodate these new form requirements.

Updated certified payroll software platforms now automatically generate compliant forms with the new fields, maintain digital records for easy electronic submission, ensure accurate job classifications and fringe benefit reporting, and reduce human error with automated validation checks.

The stakes are particularly high for HVAC contractors who depend on federal work. The contractors who get ahead of this change will avoid the last-minute rush, protect their federal contract eligibility, and ensure their teams are properly trained before the deadline hits.