PWA Documentation Checklist for Tax Credit Projects

The short answer

A taxpayer claiming or transferring the increased credit must keep records sufficient to show prevailing wage and apprenticeship (PWA) compliance. At a minimum, that means payroll records for every laborer and mechanic employed by the taxpayer, contractors and subcontractors, including qualified apprentices (26 CFR 1.45-12(b)).

This checklist separates what the regulation lists from the extra records we recommend, so you can see which is which.

By Alex Jones and Reed Dalton. Adapted from the DSPTCH IRA Field Guide (January 2025). Updated November 2026.

Prevailing wage records

26 CFR 1.45-12(c) lists these as records that may demonstrate compliance:

Identifying information for each laborer and mechanic
Location and type of construction
Labor classifications, with the wage determination and executed contracts that support them
Hourly wage and fringe rates for each classification
Support for bona fide fringe contributions and costs
Total hours per worker per pay period
Total wages per worker per pay period, including deductions
Support for paying apprentices below the prevailing rate
Amount, timing and calculation of correction and penalty payments, including penalty waiver eligibility
Failures to pay, and what was done to prevent or fix them
Complaints about wages below the prevailing rate

Apprenticeship records

26 CFR 1.45-12(d) lists these:

Written requests for qualified apprentices
Agreements with registered apprenticeship programs
Program standards, including the ratio each program sets
Total labor hours, identifying hours by each qualified apprentice
The daily ratio of apprentices to journeyworkers
Good faith effort records: requests, correspondence and denials
Amount, timing and calculation of any penalty payments
Failures to meet the requirements, and what was done about them
Complaints about apprenticeship compliance

Extra records we recommend

The regulation does not list these. They come from the DSPTCH IRA Field Guide and help you answer the questions a reviewer asks next.

Project

Map of every work site, including laydown yards and offsite assembly
Wage determination clarifications and Department of Labor responses
Key contract dates and beginning of construction details
Alteration and repair logs after placed in service

Each contractor

Contract language covering PWA obligations
Authorized payroll representative
Pay period schedule and reporting cadence
Fringe, overtime and whistleblower policies
Debarment status check

Each pay period

Daily hour and site logs
Overtime calculation check
Fringe annualization check
Open corrective actions and their responses
Apprentice wage progression check

Documentation FAQ

Who has to hold the records?

The regulation gives three options. The taxpayer can collect and keep records from every contractor and subcontractor. All parties can give records to a third party vendor to keep. Or each party can keep unredacted records for its own employees. In every case, unredacted records must be available to the IRS on request (26 CFR 1.45-12(e)).

Does selling the credit move the recordkeeping to the buyer?

No. If a credit is transferred under section 6418, the requirement to keep PWA records stays with the eligible taxpayer that determined and transferred the credit (26 CFR 1.45-12(a)).

Is the WH-347 form required?

No. The regulation says records may include completed Forms WH-347. What matters is that your records show the same information.

How long do we keep PWA records?

The rule ties retention to section 6001: keep records as long as they may be material to administering a tax law (26 CFR 1.6001-1(e)). Ask your tax advisor how that applies to your credit and its compliance period.

How long does a good faith effort request last?

For the period requested, up to 365 days, or 366 in a leap year (26 CFR 1.45-8(f)(1)). Older checklists may show a shorter cycle, including our 2025 Field Guide, so use the current rule.

Keep reading

Sources: 26 CFR 1.45-12, 26 CFR 1.45-8, 26 CFR 1.6001-1(e). Citations are to the section 45 regulations; other credits with PWA requirements apply similar rules. General information only, not legal or tax advice.