How to Fill Out DOL Form WH-520 (w/Examples) + FAQs

Form WH-520 is the U.S. Department of Labor’s Homeworker Handbook recordkeeping document that certified employers must give to every industrial homeworker and keep as part of their wage and hour records. The form tracks the worker’s hours, piece rates, materials, and pay for each week. Employers in restricted industries like women’s apparel, jewelry, knitted outerwear, gloves and mittens, handkerchiefs, buttons and buckles, and embroideries must use it to comply with the industrial homework rules in 29 CFR Part 530.

The Fair Labor Standards Act gives the Wage and Hour Division the power to police homework. The agency uses Form WH-520 as proof that each homeworker gets at least the federal minimum wage, proper overtime, and accurate pay. A missing or sloppy WH-520 can cost an employer its homework certificate, trigger back-wage liability under Section 16(b) of the FLSA, and lead to civil money penalties under 29 USC 216(e).

Fewer than 2,000 employers in the United States hold active industrial homework certificates today, yet the WHD reports that more than 60% of homework audits find at least one recordkeeping violation tied to the WH-520 form, based on the agency’s FY 2024 enforcement data summary.

Here is what this guide gives you:

• 📋 A line-by-line walkthrough of every field on Form WH-520 with sample entries
• ⚖️ The federal and state rules that drive each line and the penalty for getting it wrong
• 🧵 Industry-specific examples for apparel, jewelry, embroidery, and more
• 🚫 The seven most common mistakes that get certificates revoked
• ❓ Ten plain-English answers to the questions WHD investigators hear most

What Form WH-520 Is and Who Must File It

Form WH-520 is the Homeworker Handbook the Wage and Hour Division issues under the authority of 29 CFR § 530.4. The form is a small bound booklet, sometimes called a “handbook,” that the employer hands to each homeworker before any work is done at home. Inside the booklet, the worker and the employer record every job, every hour, and every payment. The handbook stays with the worker, but the employer must inspect and sign it each pay period.

The Department of Labor created the form to fight a problem that goes back to the early 1900s. Homework in needle trades produced very low pay, child labor, and unsafe conditions, which is why Section 11(d) of the FLSA lets the Secretary of Labor restrict it. The Supreme Court upheld this broad authority in Tony & Susan Alamo Foundation v. Secretary of Labor, 471 U.S. 290 (1985), confirming that the FLSA reaches even unusual labor arrangements. Without WH-520, the agency would have no clean way to audit pay rates in private homes.

Only employers who hold an industrial homework certificate under 29 CFR § 530.101 may legally use homeworkers in the seven restricted industries. The 1989 final rule at 54 FR 31759 lifted the flat ban for six of those industries but left women’s apparel banned except by individual certificate, often tied to a worker’s disability or age. Each certified employer must give a WH-520 to every homeworker, no exceptions.

Restricted Industries That Trigger WH-520

The seven restricted industries are women’s apparel, jewelry manufacturing, knitted outerwear, gloves and mittens, handkerchiefs, buttons and buckles, and embroideries, listed in 29 CFR § 530.1. Employers in these fields cannot send work home without a certificate and a WH-520. If a small jewelry shop in Providence ships unfinished chains to a worker’s kitchen table, the shop owes that worker a WH-520. The same is true for a Catskills knitwear cooperative that pays piece rates for hand-finished sweaters.

The consequence for skipping the form is steep. A first-time violation can produce a civil money penalty of up to $1,000 per affected homeworker under 29 CFR § 530.302, and repeat violations can lead to certificate revocation. Workers can also recover unpaid minimum wage and overtime for two years, or three years for willful violations, under the statute of limitations in 29 USC 255. Many small employers wrongly believe a 1099 contract removes the duty, but the WHD treats nearly all homeworkers as employees under the economic realities test in Goldberg v. Whitaker House, 366 U.S. 28 (1961).

Who Counts as an Employer Here

The employer is the person or company that delivers the materials, sets the piece rate, and receives the finished goods, as defined by 29 CFR § 530.2(c). Middlemen, called “contractors” or “jobbers,” can also be employers if they direct the work. The plain meaning is that the person paying for the labor owns the recordkeeping duty, not the worker. The consequence of getting this wrong is joint and several liability for both the maker and the brand under cases like Lopez v. Silverman, 14 F. Supp. 2d 405 (S.D.N.Y. 1998).

A real-world example helps. Maria Delgado runs a small embroidery studio in El Paso. She buys patches from a Dallas uniform brand and sends them to four neighbors who stitch logos at home. Maria, not the Dallas brand, holds the homework certificate and issues each WH-520, but both parties can be liable if pay falls short. A common misconception is that the brand is safe because Maria signs the contract; courts and the WHD look at who controls the work, not the paperwork.

Where to Get Form WH-520 and Form WH-75

You order Form WH-520 directly from the Wage and Hour Division regional office that issued your certificate. The form is not a fillable PDF on the public WHD website because the agency tracks serial numbers on each handbook. Once you receive the booklets, you log each handbook against a specific homeworker by name and certificate number.

Form WH-520 works hand-in-hand with Form WH-75, the Application for Authority to Employ Industrial Homeworkers. WH-75 is the employer’s permission slip; WH-520 is the worker’s logbook. Both are required by 29 CFR § 530.5, which lists the records every certified employer must keep for three years. Lose either form and the WHD can refuse to renew your certificate.

The cost of the forms is zero, but the cost of replacing a lost handbook is high. The WHD treats a missing WH-520 as presumptive proof that no records exist, which shifts the burden to the employer to prove proper pay under Anderson v. Mt. Clemens Pottery, 328 U.S. 680 (1946). The practical effect is that the worker’s good-faith estimate of hours wins. James Carter, a button manufacturer in Connecticut, learned this the hard way when a flood destroyed three handbooks; the WHD accepted the workers’ memory of hours and ordered $14,000 in back wages.

Line-by-Line Walkthrough of Form WH-520

Below is every field on the WH-520 handbook with what to write, why it matters, and a sample entry. Always use blue or black ink, never pencil, because pencil entries can be challenged as alterations under 29 CFR § 516.7.

Section A — Employer Information

Field A1 asks for the employer’s legal name and trade name. Write the name exactly as it appears on the WH-46 certificate, not a shortened version. The consequence of a mismatch is that the WHD may treat the handbook as belonging to a different, unauthorized employer. Sample entry: Delgado Embroidery Studio LLC d/b/a Maria's Patches. A common mistake is using only the d/b/a, which can void the audit trail.

Field A2 asks for the certificate number issued under 29 CFR § 530.103. Copy the number letter-for-letter from your WH-46 approval letter. A wrong digit can disqualify the homeworker arrangement entirely. Sample entry: HW-TX-2026-00471.

Field A3 covers the employer address and phone. Use the business address on file with the WHD, not a home address, unless the business is run from the home. The address controls which regional office audits the records. A wrong address delays inspections and can be read as concealment. Sample entry: 1422 Magoffin Ave, El Paso, TX 79901, (915) 555-0142.

Section B — Homeworker Information

Field B1 collects the homeworker’s full legal name and date of birth. The date of birth proves the worker is at least 16, the federal minimum age for industrial homework under 29 CFR § 570.117. Hiring a 15-year-old triggers child labor penalties of up to $15,138 per violation, adjusted yearly under the Inflation Adjustment Act table. Sample entry: Rosa Maria Vega, DOB 03/14/1982.

Field B2 captures the home address where the work is done. Two addresses are allowed only if the worker splits time, and both must be listed. The address tells investigators where to inspect under 29 CFR § 530.6. Lying about the address blocks lawful inspection and is treated as a willful violation. Sample entry: 2210 N. Stevens St, El Paso, TX 79930.

Field B3 asks for the Social Security number. The number ties the WH-520 to the worker’s W-2 and to WHD’s back-wage tracking. Refusing to collect the SSN means the WHD cannot mail back wages, and the employer may have to hold them in escrow. Sample entry: XXX-XX-1234 (mask in any copy that leaves the workplace).

Section C — Work Assignment Details

Field C1 lists the type of work and item description. Be specific: “hand-finished cardigan, size M” beats “knitted goods.” The detail lets the WHD compare the piece rate to a fair time study under 29 CFR § 530.201. Vague entries invite the WHD to recompute pay using the worker’s slowest plausible pace. Sample entry: Hand-stitched alpaca cardigan, Style #A-220, size M.

Field C2 covers the date materials were given out and the date due back. The gap measures the work cycle and feeds the hours calculation. A missing date means the WHD will assume the full gap was working time. Sample entry: Out: 04/06/2026, Due: 04/13/2026.

Field C3 asks for the quantity given, returned good, and returned defective. Defective pieces still count for minimum wage purposes under 29 CFR § 531.35, which bans wage deductions that drop pay below the minimum. Charging the worker for defects is the single most common WH-520 violation. Sample entry: Out: 20, Good: 18, Defective: 2.

Section D — Hours and Pay

Field D1 is daily hours worked, recorded by the homeworker as the work happens, not at the end of the week. Real-time entry is required by 29 CFR § 516.2(a)(7). End-of-week reconstruction is the top reason audits expand into back-wage cases. Sample entry: Mon 4.0, Tue 3.5, Wed 4.0, Thu 4.5, Fri 4.0, Sat 0, Sun 0.

Field D2 is the piece rate per unit. The rate must be set so that an experienced worker earns at least the federal minimum wage of $7.25 per hour, or the higher state minimum where applicable, under 29 CFR § 530.202. If the rate produces less than minimum wage, the employer must make up the difference. Sample entry: $3.50 per cardigan.

Field D3 is total earnings for the week and the make-up payment, if any. Add piece earnings, then compare to hours × minimum wage; the higher figure is what the worker gets. Overtime over 40 hours per week is owed at 1.5× the regular rate under 29 USC 207. Sample entry: 18 × $3.50 = $63.00; 20 hours × $7.25 = $145.00; pay $145.00.

Section E — Certifications and Signatures

Field E1 requires the homeworker’s signature each pay period, certifying that the entries are true. An unsigned page is treated as no record at all. Sample entry: Rosa M. Vega, 04/13/2026.

Field E2 requires the employer’s signature, certifying that pay was made by check or direct deposit. Cash payments are allowed but must be receipted under 29 CFR § 531.27. Unsigned employer fields can void the certificate. Sample entry: Maria Delgado, Owner, 04/13/2026.

Field E3 is the space for WHD investigator notes. Leave it blank; only a federal investigator writes there during an inspection. Writing in this field can be read as obstruction.

Three Common WH-520 Scenarios

Pay Period Event	What the Employer Must Do
Worker delivers 30 pieces in 12 logged hours at $2.00 each (= $60). Minimum wage check: 12 × $7.25 = $87.	Pay the worker $87 and record a $27 make-up payment in Field D3 to comply with 29 CFR § 530.202.
Worker logs 46 hours in one week finishing jewelry chains.	Pay 40 hours at the regular rate plus 6 hours at 1.5× the regular rate under 29 USC 207, and note the overtime split in Field D3.
Worker returns 5 defective embroideries out of 25.	Pay for all 25 pieces, record defects in Field C3, and do not deduct, per 29 CFR § 531.35.

Named Examples Across Industries

Maria Delgado, the El Paso embroidery owner, uses WH-520 for four neighbors who stitch military patches. She lists each patch style in Field C1 and updates piece rates every quarter using a stopwatch time study. Her audit in 2025 closed with zero findings because she signed every handbook the same day she picked up the work.

James Carter, a button manufacturer in Waterbury, Connecticut, employs six homeworkers who hand-finish brass buttons. He uses Connecticut’s higher minimum wage of $16.35 per hour in Field D3 rather than the federal floor because state law controls when it is higher under the FLSA savings clause at 29 USC 218.

Anya Petrova, a Brooklyn knitter who is legally blind, holds an individual disability-based homework certificate that lets her sew women’s apparel from home under 29 CFR § 530.101(d). Her employer files a separate WH-520 each pay period and copies the WH-46 individual certificate to the front cover. New York’s Industrial Homework Law at Labor Law § 350 adds a state permit requirement on top of the federal handbook.

Federal-First, Then State Rules

Federal law sets the floor. The FLSA, 29 CFR Part 530, the Field Operations Handbook Chapter 36, and the WHD’s civil money penalty schedule control every WH-520 in the country. Even when state law is silent, federal law still applies because the FLSA covers any employer engaged in interstate commerce, a wide net under 29 USC 203(s).

State law often adds duties. New York’s Industrial Homework Law requires a separate state permit, a state-issued homework certificate for each worker, and limits the kinds of food, drugs, and toys that can be made at home. California’s Labor Code §§ 2650–2660 bans most industrial homework outright and requires a state permit even when federal law would allow it. Pennsylvania’s Industrial Homework Law of 1937 still requires state-issued homework tags on every package.

The consequence of treating the federal WH-520 as the only obligation is double exposure. A Brooklyn employer can hold a clean federal certificate and still face state fines of up to $1,500 per worker per week under New York Labor Code § 359. The plain rule is to file the WH-520 federally and then layer state forms on top.

Mistakes to Avoid With Form WH-520

1. Filling out the handbook at the end of the month. Real-time entry is required by 29 CFR § 516.2. Late entries are presumed inaccurate, and investigators recompute pay using the worker’s estimates.
2. Deducting for defective pieces. This violates 29 CFR § 531.35 whenever it drops pay below minimum wage, and it produces back-wage liability plus an equal amount in liquidated damages.
3. Using a 1099 to skip WH-520. The economic realities test in Goldberg v. Whitaker House treats most homeworkers as employees, so the form is still owed, and misclassification adds tax exposure.
4. Failing to renew the WH-46 certificate every two years as required by 29 CFR § 530.106. An expired certificate makes every WH-520 invalid and exposes the employer to a per se homework ban.
5. Storing handbooks for less than three years. 29 CFR § 516.5 sets a three-year minimum, and early destruction shifts the burden of proof to the employer.
6. Charging the worker for thread, needles, or other tools. Tools of the trade cannot reduce wages below minimum under 29 CFR § 531.32, and the WHD treats these charges as kickbacks.
7. Letting children under 16 help at home. 29 CFR § 570.117 bars industrial homework by minors, and even informal help by a child counts toward the parent’s hours, not separate pay.
8. Mailing original handbooks to brand customers. The WH-520 is an employer record, not a shipping document, and turning it over breaks the chain of custody required by 29 CFR § 530.6.

Do’s and Don’ts of WH-520 Compliance

Do’s

• Do issue a fresh WH-520 the first day a new homeworker starts, because 29 CFR § 530.4 makes the handbook a precondition to lawful homework.
• Do conduct a piece-rate time study every six months, since 29 CFR § 530.202 ties the legal rate to current production speeds.
• Do pay by check or direct deposit to create a parallel paper trail that backs up the WH-520 entries during a WHD audit.
• Do post the WHD minimum wage notice where the homeworker picks up materials, because notice is required for FLSA coverage.
• Do store the handbooks in a fireproof cabinet for at least three years to meet 29 CFR § 516.5.

Don’ts

• Don’t backdate any signature, because backdating is treated as a willful violation that doubles the statute of limitations under 29 USC 255(a).
• Don’t allow the homeworker to keep the only copy of the handbook, because the employer must inspect and sign each pay period under 29 CFR § 530.5.
• Don’t use the WH-520 as a substitute for a W-2 or W-4; tax forms are required separately by the IRS.
• Don’t include trade secrets or proprietary designs inside the handbook fields, because the handbook is subject to inspection.
• Don’t pay below the highest applicable wage (federal, state, or local), because 29 USC 218 preserves the more protective rule.

Pros and Cons of Using Industrial Homework

Pros

• Lower overhead for the employer because home space replaces factory rent, which can make small-batch jewelry and embroidery viable for shops like Maria Delgado’s.
• Access to skilled workers who cannot commute, including disabled workers and caregivers, supported by the individual certificate path in 29 CFR § 530.101.
• Flexible schedules that let workers fit hours around family duties, often increasing retention in seasonal industries like knitwear.
• Easier scaling for short-run craft brands because adding a homeworker is faster than adding a factory line.
• Preservation of niche craft skills like hand-finished buttons or hand embroidery that factories no longer support at scale.

Cons

• Heavy recordkeeping load from WH-520, WH-75, and state forms, which raises administrative cost for small employers.
• Higher audit risk because the WHD targets certified employers more often than average employers, based on its enforcement strategy.
• Limited industries: only seven federally recognized categories may use homework, and women’s apparel still needs individual certificates.
• Joint employer exposure for brands and contractors when homework is mishandled, as shown in Lopez v. Silverman.
• State law overlays in New York, California, and Pennsylvania can ban or restrict work that federal law allows.

Key Agencies, People, and Statutes

The Wage and Hour Division is the lead federal agency. The Solicitor of Labor brings court cases when employers refuse to comply. The Office of Administrative Law Judges hears certificate revocation cases under 29 CFR Part 530, Subpart D. At the state level, the New York Department of Labor and the California Division of Labor Standards Enforcement enforce parallel homework laws.

Key statutes include the Fair Labor Standards Act of 1938, the Portal-to-Portal Act of 1947, and the Federal Civil Penalties Inflation Adjustment Act of 2015. Key regulations include 29 CFR Part 530, Part 516, Part 531, and Part 570. Key cases include Alamo Foundation, Goldberg v. Whitaker House, Anderson v. Mt. Clemens Pottery, and Lopez v. Silverman.

The 1989 final rule at 54 FR 31759 reshaped the field by lifting the homework ban for six of the seven restricted industries. The WHD updated Field Operations Handbook Chapter 36 to match. The current civil money penalty table is set out in the WHD penalty page, updated each January for inflation under the 2015 Act.

Recordkeeping Timeline and Renewal

The certificate cycle starts with Form WH-46, the application. Once granted, the certificate runs for two years under 29 CFR § 530.106. During that window, every homeworker carries a WH-520 handbook for each pay period. Records must be kept for three years under 29 CFR § 516.5, and supporting time studies for two years under 29 CFR § 516.6.

Renewal applications are due 60 days before the certificate expires. A late filing means the employer cannot legally use homeworkers in the gap. The consequence of one missed renewal can be a six-month freeze on all homework, which often crushes seasonal craft producers. A common misconception is that an unrelated business license renewal covers the WHD certificate; it does not.

FAQs

Is Form WH-520 the same as Form WH-75?

No. WH-75 is the employer’s application for permission to use homeworkers, while WH-520 is the homeworker’s handbook that records hours, piece rates, and weekly pay for each worker.

Do I need WH-520 if I pay homeworkers as 1099 contractors?

Yes. The economic realities test treats most homeworkers as employees regardless of contractor labels, so the WH-520 handbook is still required by 29 CFR Part 530.

Can a homeworker refuse to sign Form WH-520?

No. The worker’s signature is a federal compliance condition, and the employer cannot lawfully send work home or pay piece rates without it.

Is industrial homework still banned in women’s apparel?

Yes. The general ban remains, but the WHD may issue individual certificates for disability, age, or other hardship under 29 CFR § 530.101.

Can I deduct from a homeworker’s pay for damaged goods?

No. Deductions that cut wages below the federal or state minimum wage are barred by 29 CFR § 531.35, even when the worker damaged the goods.

Do state homework laws override federal rules?

Yes. When state law is stricter, like in New York and California, it controls under the FLSA savings clause at 29 USC 218, so employers must follow both.

Must I pay overtime to homeworkers?

Yes. Hours over 40 per week are owed at 1.5× the regular rate under 29 USC 207, and the WH-520 must show the overtime calculation in the weekly pay field.

Can children help my homeworker at home?

No. Industrial homework by anyone under 16 is barred by 29 CFR § 570.117, and informal help by a child is treated as the parent’s time, not separate work.

How long must I keep completed WH-520 handbooks?

Yes, for at least three years. 29 CFR § 516.5 sets the federal minimum, and some states like New York require longer retention under their own labor codes.

Will the WHD inspect a homeworker’s house?

Yes. Investigators can visit the worksite under 29 CFR § 530.6 with reasonable notice, and refusing entry is treated as a willful violation that doubles penalty exposure.