What does construction compliance require after award?
After award, compliance becomes a recurring paper trail: weekly certified payrolls on Davis-Bacon work, OSHA injury logs and severe-injury reports, permits and inspections before work is covered, Buy America documentation with product submittals, and current insurance certificates and endorsements from every sub. This guide lists what each requires, who owns it and the rule behind it.
What changes once the contract is signed?
At bid time, compliance is about reading the solicitation: wage determinations, DBE goals, bonds and FAR clauses. That is covered in prevailing wage, DBE goals and FAR clauses in bid packages. After award, the same requirements turn into deadlines, forms and records that someone on the project team has to produce every week.
What is due, how often, and under which rule?
| Obligation | Applies when | What is due | Rule | Usually owned by |
|---|---|---|---|---|
| Certified payroll | Federal or federally assisted construction over $2,000 (Davis-Bacon and Related Acts) | Weekly certified payroll for every week covered work is performed | 29 CFR 5.5(a)(3) | Each employer; the prime collects and submits subs' payrolls |
| Injury and illness records | Employers with more than 10 employees, unless partially exempt | OSHA 300 log and 301 report within 7 calendar days; 300A posted 1 February to 30 April | 29 CFR 1904.29, 1904.32 | Each employer, per establishment |
| Severe injury reports | All employers covered by the OSH Act | Fatality within 8 hours; in-patient hospitalization, amputation or eye loss within 24 hours | 29 CFR 1904.39 | Each employer |
| Permits and inspections | Work that requires a building permit | Inspections at each stage before work is covered; certificate of occupancy before use | Locally adopted code, e.g. IBC 110 and 111 | Permit holder, usually the GC |
| Buy America (BABA) | Infrastructure projects funded by federal financial assistance | Domestic iron, steel, manufactured products and construction materials; certifications with submittals | 2 CFR part 184 | GC and suppliers, through submittals |
| Buy American (federal direct) | Federal construction contracts with FAR 52.225-9 | Domestic construction material; 65 percent domestic component cost for items delivered 2024 to 2028 | FAR 52.225-9 | GC and suppliers |
| Insurance | Every subcontract | Certificates plus the additional insured endorsements the subcontract requires, kept current | Subcontract insurance exhibit | GC project administration |
Federal rules checked on ecfr.gov and acquisition.gov on 21 October 2026. Your contract and state law can add to these.
Certified payroll (WH-347): what is due each week?
- Weekly, for every week covered work is performed. The prime contractor is responsible for submitting all subcontractors' certified payrolls (29 CFR 5.5(a)(3)(ii)(A)).
- WH-347 is optional. Any format that carries the required information and the signed statement of compliance is acceptable. Weekly transmittals use an identifying number such as the last four digits of the SSN, not the full number.
- Keep records for 3 years after all work on the prime contract is completed. False certification can lead to civil or criminal prosecution.
- State and local public work can carry its own wage rule. In Texas, Government Code chapter 2258 requires the prevailing wage on public works for the state and political subdivisions (Gov't Code 2258).
OSHA recordkeeping: what must a contractor keep and report?
| Record | Deadline or period | Rule |
|---|---|---|
| OSHA 300 log and 301 incident report | Within 7 calendar days of learning of a recordable case | 1904.29 |
| 300A annual summary | Posted from 1 February to 30 April of the following year | 1904.32 |
| Retention | 5 years after the end of the calendar year covered | 1904.33 |
| Electronic submission | By 2 March: 300A for construction establishments with 20 to 249 employees and all with 250 or more; 300 and 301 data too for 100 or more in listed industries, including NAICS 2381 | 1904.41 |
| Fatality report | Within 8 hours | 1904.39 |
| Hospitalization, amputation, loss of an eye | Within 24 hours | 1904.39 |
Employers with 10 or fewer employees all year are partially exempt from keeping the logs, but must still report severe injuries (1904.1). On a multi-employer site, each sub keeps its own records; the GC usually requires copies by subcontract.
Permits and inspections: what has to happen before work is covered?
- Call inspections in sequence. Under IBC Section 110.3, required inspections start with footings and foundations and run through slab, framing and final. The permit holder notifies the building official when work is ready.
- Do not cover uninspected work. A missed inspection means opening finished work later.
- No occupancy without a certificate. IBC Section 111.1 bars use or occupancy until the building official issues a certificate of occupancy.
- Check the local code. Cities and counties, including those around Travis County, TX, adopt the IBC with their own amendments. The permit card and the authority having jurisdiction set the actual list.
IBC section references are to the 2021 edition, as summarized in ICC permit technician training material.
Buy America at submittal: what proof do you collect?
- Know which rule applies. BABA covers infrastructure projects funded with federal financial assistance (grants, many state and local projects). FAR Buy American covers direct federal construction contracts. They have different tests.
- BABA tests by category. Iron and steel: all manufacturing from initial melting through coatings in the US. Manufactured products: made in the US with more than 55 percent of component cost domestic. Construction materials: all manufacturing processes in the US. Cement, aggregates and binding agents are excluded from the construction materials category.
- Collect it with the submittal. Ask for the manufacturer's domestic content certification with each product submittal, before the purchase order. A reorder after rejection costs schedule.
- Waivers come from the funding agency, not the contractor. If a product cannot comply, raise it early.
Insurance certificates: why a COI is not coverage
The standard certificate of liability insurance (ACORD 25) states that it is issued as a matter of information only and confers no rights on the certificate holder. Additional insured status comes from an endorsement to the policy, not from a line on the certificate.
- Collect the certificate and the endorsements your subcontract requires before the sub mobilizes.
- Check limits, additional insured wording and waiver of subrogation against the subcontract exhibit.
- Track expiration dates; a lapsed policy mid-project is a payment hold and an audit finding.
What does BAU AI do here today?
Some of it, and we would rather be exact. After award, Lex keeps the safety log and daily reports and sends alerts before safety documents expire, and Fina tracks pay applications and retention. BAU AI does not file certified payroll or submit compliance reports to agencies; that stays with your team.
At bid time, Clara reads the solicitation and lists the wage, DBE, bond, insurance and Buy America requirements with page cites, so they are known before you commit. Dora flags insurance and flow-down clauses in the contract and subcontract.
Frequently asked questions
Who submits certified payroll on a federal project?
Each contractor and subcontractor prepares its own weekly certified payroll, and the prime contractor is responsible for submitting all of them to the agency or the entity that maintains the records. WH-347 is an optional format.
How long do OSHA injury records have to be kept?
Five years after the end of the calendar year the records cover, under 29 CFR 1904.33. The 300A summary is posted each year from 1 February to 30 April.
Does a certificate of insurance make us an additional insured?
No. The ACORD 25 certificate says it confers no rights on the holder. Additional insured status requires an endorsement to the policy, so collect the endorsement as well as the certificate.
Does Buy America apply to private projects?
BABA applies to infrastructure projects funded with federal financial assistance, and FAR Buy American applies to direct federal contracts. A privately funded project is usually outside both unless its contract or another funding source requires domestic content.
Where is bid-time compliance covered?
Davis-Bacon wage determinations, DBE goals, bonds and FAR clauses as they appear in a solicitation are covered in the bid-time compliance guide.
Sources
Primary sources checked on 21 October 2026. Rules change; confirm against the current text and your contract before you rely on them.
- 29 CFR 5.5, Contract provisions and related matters (certified payroll), eCFR
- 40 U.S.C. 3142, Rate of wages for laborers and mechanics (Davis-Bacon threshold)
- Texas Government Code chapter 2258, Prevailing wage rates
- 29 CFR 1904.1, 1904.29, 1904.32, 1904.33, 1904.39, 1904.41 (OSHA recordkeeping), eCFR
- 2 CFR part 184, Buy America preferences for infrastructure projects, eCFR
- FAR 52.225-9, Buy American, Construction Materials
- ICC permit technician training, IBC 2021 Sections 110 and 111
- ACORD 25 certificate of liability insurance, sample form (NYC DYCD)
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