Davis-Bacon Compliance 101: What Contracting Agencies Need to Know
- pbarcelona8
- Jul 9
- 2 min read
Updated: Jul 30
🏛️ Davis-Bacon Compliance 101: What Contracting Agencies Need to Know
When federal funds support construction, Davis-Bacon requirements may apply. It’s your agency’s responsibility to determine when they do—and to follow through with full, documented compliance.
At ARTOVIA, we help agencies stay compliant, avoid findings, and deliver federally funded projects with confidence.
📚 What Laws Apply
When Davis-Bacon is triggered, these labor standards come with it:
Law/Regulation | Covers |
Davis-Bacon Act | Sets prevailing wages and benefits for construction workers on covered federal contracts over $2,000 |
DBRA | Applies those standards to federally assisted projects like HUD- or EPA-funded construction |
Copeland “Anti-Kickback” Act | Prohibits unlawful deductions and requires weekly certified payrolls |
CWHSSA | Requires time-and-a-half overtime pay on contracts over $100,000 |
29 CFR Parts 1, 3, 5 | Provide procedural guidance on wage determinations, payroll reporting, and enforcement |
2023 Final Rule | Expands coverage and strengthens enforcement |
🧭 Build Compliance from the Start
If Davis-Bacon applies, your bid/contract package must include:
📄 The full wage determination
📘 All required clauses from 29 CFR § 5.5
📎 Related rules from Copeland, CWHSSA
🔗 Flow-down language for all subcontractor tiers
🔄 Updates from the 2023 Final Rule
🧾 Other required provisions based on your federal funding source
📌 Missing or vague provisions weaken your ability to enforce the law later.
Contracting agencies must also verify that prime contractors and subcontractors are not debarred from participating in federally funded projects before awards or made.
🏗️ Enforcing Requirements During Construction
Compliance becomes critical once work starts. Your agency must:
✅ Review weekly certified payrolls
🏷️ Confirm jobsite wage postings
👷 Conduct worker interviews
📁 Collect supporting documentation, including:
Apprentice/trainee registrations
SF-1444 forms proposing additional job classifications
Fringe benefit calculations
Confirmation that subcontracts include required provisions
ARTOVIA helps monitor compliance at every contractor tier and keeps your project audit- and monitoring-ready.
📝 Reporting & Enforcement
Agencies must be prepared to complete semi-annual and other enforcement reports as needed, based on their funding source and regulatory obligations. ARTOVIA helps you track activity and stay ahead of reporting deadlines—so documentation is timely, accurate, and complete.
📁 Close Out With Confidence
Before wrapping up, make sure you:
🗃️ Retain records for at least 3 years—or longer if required by your funding source—including payrolls, interviews, and monitoring logs
🧾 Document any wage corrections, conformance approvals, or enforcement actions
📑 Be prepared for audits or compliance reviews
ARTOVIA helps you keep everything organized and compliant.
🔗 Why It Matters
If Davis-Bacon applies and you don’t manage it well:
Workers may be underpaid or misclassified
Contractors may fail to comply if labor requirements aren’t clearly included in the contract language
Subcontractors may overlook key provisions
Agencies may face findings
ARTOVIA is your partner in getting it right—start to finish.
Jeanne Burke
