California PWC-100 Public Works Contract Form: Filing and Penalties

The PWC-100 form in California is the electronic notice an awarding body files with the Department of Industrial Relations (DIR) before a public works contractor can start work. It is filed through DIR’s online portal, it captures the contract, contractor, and schedule details DIR uses to monitor prevailing wage compliance, and it is due within 30 days of the contract award or by the first day any worker is on the jobsite, whichever comes first. Miss that deadline, or list an unregistered contractor on it, and your agency is exposed to a $100-per-day civil penalty.

Which Projects Require a PWC-100

The filing requirement kicks in when a public works contract exceeds $25,000 for construction, alteration, demolition, installation, or repair work, or exceeds $15,000 for maintenance work.1California Legislative Information. California Labor Code 1773.3 – Public Works Contract Notice Below those thresholds, no PWC-100 is needed, though prevailing wage rules still apply to any public works project over $1,000.2California Legislative Information. California Labor Code 1771 – Payment of General Prevailing Rate

The thresholds apply to the prime contract between the agency and the contractor, not to individual subcontract values.3California Special Districts Association. New California Law Has Immediate Impact on Public Works Projects A $30,000 prime contract triggers a filing even if no single subcontract crosses $15,000.

The duty to file sits with the awarding body: the county, city, school district, special district, state agency, or other public entity that issued the contract. Counties, cities, school districts, special districts, and state agencies all qualify. The contractor doing the work cannot file on the agency’s behalf, and if the form is not submitted, the agency bears the penalty.

What to Gather Before You File

Pull everything together before you log in. The statute requires the electronic notice to include the contractor’s name and DIR registration number, the name and DIR registration number of every subcontractor listed on the winning bid, the bid and award dates, the contract amount, estimated start and completion dates, and the jobsite location.1California Legislative Information. California Labor Code 1773.3 – Public Works Contract Notice

Have the following in front of you:

  • Project name and a short description of the work.
  • The contract award amount and the estimated total project cost. Total project cost includes all public works contracts on the project but excludes land acquisition and non-public-works costs.4Department of Industrial Relations. Instructions for Web Form PWC 100
  • Key dates: first advertised bid date, estimated or actual start date, and estimated or actual completion date.
  • CSLB license numbers for the general contractor and every listed subcontractor. The portal uses these to search and populate contractor records.
  • DIR Public Works Contractor Registration (PWCR) numbers for each contractor and subcontractor. Look these up on DIR’s contractor search tool if you don’t have them.5San Jose/Evergreen Community College District. PWC-100 Filing Instructions
  • Project type classification, which determines the prevailing wage schedule for the trades on your project.

Every contractor and subcontractor you list must hold a current DIR registration at the time the contract is awarded. An unregistered contractor cannot legally bid on, be listed in a bid proposal for, or perform any public work.6California Legislative Information. California Labor Code 1771.1 – Contractor Registration Requirements If a listed subcontractor turns out to be unregistered, the general contractor can substitute a registered sub with the awarding body’s consent.

How to File the PWC-100 Online

The PWC-100 is filed electronically through DIR’s Public Works online portal. There is no paper version. The awarding body’s designated user logs in, creates a new project record, and works through a sequence of screens for project details, contractor information, and dates.

When you reach the contractor screens, enter the CSLB license number and let the system search DIR’s database to pull up the contractor’s name and registration status. If the registration does not come back active, stop. Listing an unregistered contractor exposes the awarding body to penalties, so verify every contractor’s status before you reach this screen.

After you enter all project and contractor data, the system generates a summary page. Check every registration number, every date, and the contract amount before submitting. The portal does have an update function for corrections after submission, but a clean first filing avoids creating a record trail that could draw attention during a compliance audit.

On successful submission, the system generates a unique DIR Project ID number. Send this number to your general contractor right away. Contractors need it to submit certified payroll reports to DIR throughout the project, and without it the eCPR system will not accept their records.7Department of Industrial Relations. Notice to Awarding Bodies and Contractors Regarding DIR’s eCPR System The awarding body also receives a submission confirmation. Keep a copy in your project file as proof of filing.

The Filing Deadline

File within 30 days of the contract award, or by the first day any contractor has workers on the jobsite, whichever comes first.1California Legislative Information. California Labor Code 1773.3 – Public Works Contract Notice The “first day of work” trigger is what catches most agencies. If your contractor mobilizes quickly and puts workers on site before your 30 days are up, you are already late if the form has not been submitted.

A narrow exception exists for emergency contracts awarded under Public Contract Code sections 10122, 20113, 20654, or 22050. The 30-day window from award still applies, but the outer limit shifts to the last day workers are on the project rather than the first. That gives agencies responding to collapsed infrastructure or natural disasters room to handle the emergency before filing.

Updating the PWC-100 After You File

The filing is not one and done. The form has to reflect the project’s current state as it evolves. When the general contractor brings on a subcontractor who was not listed in the original bid, the awarding body updates the PWC-100 to add that subcontractor’s name, CSLB license number, and DIR registration number. The same applies when the contract amount changes significantly or the completion date shifts.

The awarding body must withhold final payment to the contractor until at least 30 days after all required information has been submitted, including a complete list of every subcontractor that worked on the project.1California Legislative Information. California Labor Code 1773.3 – Public Works Contract Notice Releasing final payment early and then discovering an unregistered subcontractor in the record can land the agency in penalty territory.

Penalties for Late or Missing Filings

Consequences fall on both the agency and the contractors.

Awarding Body Penalties

An awarding body that fails to provide the required notice, or that permits an unregistered contractor or subcontractor to work on a public works project, faces a civil penalty of $100 for each day in violation, up to a maximum of $10,000 per project.1California Legislative Information. California Labor Code 1773.3 – Public Works Contract Notice The Labor Commissioner may waive the penalty for a first-time violation that was unintentional and did not hinder DIR’s ability to monitor compliance. Two or more willful violations within a 12-month period can make the agency ineligible for state construction funding for one year.

Contractor Penalties

A contractor or subcontractor that performs public work without a valid DIR registration faces a $100-per-day civil penalty, capped at $8,000, plus any penalty registration fee owed under Labor Code 1725.5. A higher-tier contractor that subcontracts with an unregistered lower-tier sub faces a separate $100-per-day penalty capped at $10,000. A contract entered into with an unregistered contractor is subject to cancellation, and violating a stop-work order issued by the Labor Commissioner is a misdemeanor punishable by up to 60 days in county jail, a fine up to $10,000, or both.6California Legislative Information. California Labor Code 1771.1 – Contractor Registration Requirements

If the Project Has Federal Funding

Filing the PWC-100 handles the state side. It does not satisfy federal requirements. When a California public works project receives federal financial assistance, the federal Davis-Bacon Act may apply on top of state prevailing wage rules, covering federally funded construction contracts exceeding $2,000.8U.S. Department of Labor. Davis-Bacon and Related Acts On mixed-funded projects, contractors typically compare the federal and state wage rates for each trade and pay whichever is higher. The awarding body still files the PWC-100 with DIR, and separately makes sure the correct federal wage determination is included in the contract documents. The two sets of requirements run in parallel; meeting one does not satisfy the other.