Certified Payroll for a No-Work Week: Do You Still Submit? (Davis-Bacon)

No work this week on a Davis-Bacon job? You still submit certified payroll — a No Work Performed statement for every week between your first and final payroll, so the payroll numbers have no gaps.

Yes. On a Davis-Bacon job with no work this week, you still submit certified payroll. You file a "No Work Performed" statement for every week between your first and last week of work. That way the payroll numbers run 1, 2, 3 with no gaps. A gap looks like a missing report to an auditor. And missing reports hold up the prime's progress payments. The no-work statement goes on the same WH-347 form you file in an active week.

The rule and the prime point the same way. 29 CFR 5.5(a)(3)(ii) requires a certified payroll "for each week in which any contract work is performed." A zero-hour week is not a week work was performed, so the rule itself does not spell out a no-work filing. Agencies and prime contractors fill that gap with a short statement, so the weekly series stays unbroken. One small sub on two federal jobs said it plainly: "The prime wants certified payroll submitted weekly, no exceptions." When the prime says weekly, you file weekly. The pay side of that rhythm is the weekly-pay requirement.

Do you submit certified payroll with no work performed?

Yes. Submit a "No Work Performed" statement for each week between your first and final payroll. It can be a WH-347 marked "No work performed this week," or a short signed statement. This keeps the weekly payroll series unbroken, so no week looks like a missing report.

The weekly cadence is the point. Davis-Bacon covers federal construction contracts over $2,000. Certified payroll on those jobs is a weekly task, tied to the prime's day (usually Friday). Every prime contractor/subcontractor on a covered job files its own weekly report. Once you file Payroll No. 1, the agency expects a numbered report for every week the project is open on your end. That includes the empty ones. You are not certifying that anyone worked. You are certifying that no one did that week. That is still a statement of compliance, and it belongs in the file. The weekly-pay requirement spoke covers the cadence in full.

What a "No Work Performed" statement looks like

Two formats are accepted. Option one: a WH-347 with "No work performed this week" written across the worker rows, and the Statement of Compliance signed. Option two: a short standalone statement. It names the project, contract number, week-ending date, and payroll number, then gets signed. The prime or agency tells you which they want.

A no-work week strips the report down to almost nothing. No hours worked means no work classification, no gross amount earned, no fringe benefits column, no deductions, and no net wages paid. There is no apprentice ratio to report either. What is left is the project/contract number, the week it covers, and your signature. Here is wording that satisfies a standalone statement:

No work was performed on [Project Name], Contract No. [xxxxxxxx], during the payroll period ending [MM/DD/YYYY]. This is Payroll No. [n].
Signed: [Name], [Title] — [date]

If your prime demands the WH-347 layout, type the no-work line into the fillable WH-347 PDF instead of the note. Many primes do, and the format is not optional. The WH-347 line-by-line guide shows the header fields you still complete.

How to number payrolls across a no-work gap

Number payrolls in order from 1. Count the no-work weeks in that sequence. Mark the last payroll of the project "Final." An auditor matches those numbers against the project calendar. No number can go missing.

The payroll number is the thread the auditor pulls. Take a seven-week project. The crew is off site for two weeks in the middle:

Week ending	On site?	Payroll No.	What you submit
07/03	Yes	1	WH-347 with hours
07/10	Yes	2	WH-347 with hours
07/17	No	3	No Work Performed statement
07/24	No	4	No Work Performed statement
07/31	Yes	5	WH-347 with hours
08/07	Yes	6	WH-347 with hours
08/14	Yes	7	WH-347 with hours, marked FINAL

Payrolls 3 and 4 carry no worker data. But they hold their place in the count. The numbers run 1 through 7 with nothing skipped. A reviewer matching the sequence against the open weeks finds a complete file. Keep every submission, no-work statements included, for at least three years after the project ends (29 CFR 5.5(a)(3)(i)).

Payrolls stay numbered 1 through 7 across the two-week no-work gap, with the last marked Final, so no week reads as a missing report

When can you stop submitting no-work statements?

You start with Payroll No. 1 the first week you work. You stop after the payroll you mark "Final." You owe no no-work statements before your crew starts, or after the Final payroll.

Numbering starts the first week you actually work, so you owe nothing before your crew starts. On the other end, the last payroll gets the word "Final" next to the payroll number (WH-347 instructions, OMB 1235-0008). That closes your series, and the no-work statements stop with it. One caution: do not mark Final early. If you leave the site but expect to return for punch-list work, keep filing until the job is truly done. A payroll that lands after a "Final" confuses the agency, so confirm the timing with the prime first.

Skipping a no-work week is the mistake auditors catch

A skipped week leaves a gap in the payroll numbers, say Payroll 5 to Payroll 8. To an auditor that reads as three missing reports, not three idle weeks. The burden is on you to prove the difference.

The reviewer does not see your job calendar. They see your payroll numbers. A jump from Payroll 5 to Payroll 8 says "three reports missing," and the agency has to chase them. The cost is real: withheld progress payments until the file is whole, a compliance flag on the contract, and a closer look at whether records were faked. A missing week can look like a hidden one. A false Statement of Compliance is a federal crime under 18 U.S.C. 1001. That statute is named on the WH-347 itself. A false certification can also draw civil liability under the False Claims Act. A full WH-347 week can run two to three hours; the no-work note takes about two minutes. For the full weekly workflow, the certified payroll pillar walks it start to finish.

Frequently asked questions

Do I submit certified payroll with no work performed?

Yes. On a Davis-Bacon project you submit a No Work Performed statement for each week between your first and final payroll, even weeks your crew logged zero hours. It can be a WH-347 marked "No work performed this week" or a short signed statement. Skipping the week leaves a gap in your payroll numbers that reads as a missing certified payroll report.

Do I need a statement of non-performance on a Davis-Bacon job?

Usually yes. The prime contractor and the contracting agency require one to keep the weekly payroll series continuous. 29 CFR 5.5(a)(3)(ii) requires a certified payroll for each week contract work is performed; agencies extend that to no-work weeks with a non-performance statement so the payroll numbers have no gaps. Confirm your agency's required format.

What do I write for a no-work week on the WH-347?

Write "No work performed this week" across the payroll rows. Fill in the header: contractor, payroll number, week ending, project and contract number. Then sign the Statement of Compliance. A short standalone statement also works. Name the project, contract number, week-ending date, and payroll number, then sign. No hours means no classification, fringe, or deductions to report.

Can I skip weeks when there are no hours?

No. A skipped week leaves a gap in your payroll numbers, and an auditor reads a gap as a missing certified payroll report, not an idle week. Missing reports hold up the prime's progress payments and invite scrutiny. Filing a no-work statement costs one signature and keeps the sequence clean.

When is my last certified payroll?

Your last certified payroll is the week you finish work; mark it "Final" next to the payroll number. After a Final payroll you stop submitting, including no-work statements. Do not mark Final early: if you return for punch-list work, keep filing until the job is truly complete.

Verify the rule before you file

Last reviewed: 14 July 2026. Reviewed by the Davis-Bacon Wage editorial team. Reviewed against primary DOL, 29 CFR and SAM.gov sources per our editorial process. This page explains how no-work weeks are handled on Davis-Bacon certified payroll and is not legal advice. Weekly-submission and retention rules live in 29 CFR 5.5; the no-work-statement, numbering, and Final-marking conventions come from your contracting agency and prime. Confirm your agency's exact format and the current wage determination on SAM.gov and with the Wage and Hour Division before you file.