New York State is preparing to implement a significant change to prevailing wage compliance that will affect contractors and subcontractors working on public works and covered private projects. Under Labor Law § 220-j, the New York State Department of Labor (NYSDOL) must develop and implement a new electronic certified payroll reporting system by December 31, 2025.
Under the new requirement, contractors will submit records through a centralized online portal administered by NYSDOL. Updates and further guidance will be posted on NYSDOL’s website once the system is finalized.
Key Impacts for Construction Businesses
For construction businesses, the new requirement reflects a broader shift toward digital compliance.
Key statutory provisions include:
- Expanded Responsibilities: Each contractor and subcontractor must submit their own certified payroll electronically through the NYSDOL-prescribed system.
- Greater Transparency in Reporting: Portions of electronically submitted payroll data will be published in a public, searchable online database, excluding personal identifying information.
- Penalties for Late or Missing Submissions: Contractors and subcontractors who fail to furnish required electronic payroll records may receive a $100-per-day penalty, following a 14-day grace period.
These changes may signal a broader shift toward digital reporting and compliance across the state.
New York Contractors Can Prepare Now for the Payroll Modernization
While NYSDOL finalizes the system, contractors can begin preparing now for a smooth transition.
Recommended steps include:
- Reviewing existing certified payroll processes to identify gaps that may affect electronic reporting
- Confirming that payroll software or internal systems can generate records consistent with § 220-j requirements
- Updating subcontractor documentation and expectations to reflect the upcoming change to electronic reporting
Contractors who take time now to prepare will be better equipped to meet the new reporting obligations.
How Grassi’s Construction Advisors Can Help
If you need assistance reviewing your payroll procedures or understanding how these changes may affect your operations, connect with a Grassi Construction advisor to prepare your team to transition confidently into the new reporting environment.
Frequently Asked Questions
What is New York’s new electronic certified payroll reporting system? New York Labor Law § 220-j requires the New York State Department of Labor (NYSDOL) to develop an electronic certified payroll reporting system and public database by December 31, 2025. Once operational, contractors and subcontractors on covered projects will be required to submit certified payroll records electronically through this system.
When will New York’s electronic certified payroll system go live? NYSDOL must develop and implement the online system and public database no later than December 31, 2025.
Will certified payroll records be publicly accessible in New York? Yes. Labor Law § 220-j requires NYSDOL to create a public, searchable online database of certified payroll records. This database will exclude personally identifiable information and include searchable payroll record subsets.
What are the penalties for failing to submit electronic certified payroll records? Contractors and subcontractors who do not furnish required electronic payroll records may receive a $100-per-day penalty. This penalty cannot be levied until 14 days after the contractor or subcontractor fails to submit the required records.
