Your solar customer stopped being the awarding body on January 1. For one filing, you became one.

The PWC-100 is now the contractor’s filing on covered solar and battery jobs. It is due within 30 days of the award, but never later than the first day your workers are employed on the public work. On a fast rooftop job, that second deadline controls.

AB 1104 made that change January 1, 2026. If your crew mobilizes before someone files the notice, the filing is already late.

AB 1104 put you in the awarding body’s seat for one filing

AB 1104, authored by Assemblymember Pellerin, is Chapter 632, Statutes of 2025. The Governor approved it October 11, 2025, after the Assembly concurred in the Senate amendments 79 to 0.

The law added Public Utilities Code section 769.2(g)(1): “The entity that engaged the contractor … is not an awarding body, as defined in Section 1722 of the Labor Code. Public works project requirements not found in this section do not apply to the entity.”

That entity is your customer. Before AB 1104, the building owner or business getting the array had to register with the Department of Industrial Relations as an awarding body, register the project, obtain prevailing wage rates, put those rates and notices into bid documents, and post wage information at the jobsite.

That compliance load was built for large public agencies. The bill’s author called it onerous for a small business that just wants rooftop solar.

The customer is now out of that paperwork. The contractor becomes the awarding body “only for the limited purposes” of Labor Code section 1773.3. That means the PWC-100 falls to you. It does not turn you into the awarding body for every public works rule.

The PWC-100 deadline can expire before the 30 days do

Labor Code section 1773.3 requires electronic notice to the Department of Industrial Relations in the department’s specified format. The form is the PWC-100.

The deadline has two parts. You must transmit it within 30 days of the award, but in no event later than the first day on which a contractor has workers employed on the public work.

Do not calendar only the 30th day. If you award the job and put workers on the roof sooner, the first-worker date cuts off the longer period.

The notice includes the contractor’s name and department registration number, each subcontractor’s name and registration number, the bid and contract award dates, contract amount, estimated start and completion dates, and jobsite location.

Section 1773.3 applies to public works contracts over $25,000 for construction, alteration, demolition, installation, or repair. The threshold is over $15,000 for maintenance work.

Net metering status is what pulls the job into section 769.2

AB 2143 added Public Utilities Code section 769.2 in 2022. Under subdivision (a), construction after December 31, 2023, of a renewable electrical generation facility and associated battery storage receiving service under the specified standard contract or tariff “shall constitute a public works project.”

Those tariffs come out of the net energy metering statutes. Section 2827 is the original net energy metering statute, and section 2827.1 is the successor tariff. Subdivision (d) of 769.2 refers to a standard contract or tariff developed pursuant to “Section 2827 or 2827.1.”

On a covered job, Public Utilities Code section 769.2(b) requires at least the general prevailing rate of per diem wages for each construction worker. An apprentice registered in a program approved by the Chief of the Division of Apprenticeship Standards must receive at least the applicable apprentice prevailing rate. You must maintain payroll records under Labor Code section 1776.

The paperwork continues after the PWC-100. Section 769.2(b)(3) says the contractor “shall biannually, on July 1 and December 31 of each year, submit to the commission digital copies of its certified payroll records.” Those records go to the California Public Utilities Commission through the SURGE portal at cpucsurge.org. SURGE stands for Solar-Utilities Reporting, Guidance, and Education. The commission retains them as public records for five years.

The 15 kW exemption is written for residential facilities

Public Utilities Code section 769.2(f)(1) exempts “a residential renewable electrical generation facility that is eligible to receive service pursuant to the standard contract or tariff developed pursuant to Section 2827.1 and has a maximum generating capacity of 15 kilowatts or less of electricity.”

The word “residential” does the work. The familiar shorthand, that this only applies over 15 kW, comes from that paragraph, and that paragraph is about residential facilities. It does not exempt a small nonresidential system as written.

Subdivision (f)(2) separately exempts a residential facility installed on a single-family home. Subdivision (f)(3) exempts a project already treated as a public work under Labor Code section 1720.

Subdivision (f)(4) exempts a facility “that serves only a modular home, a modular home community, or multiunit housing that has two or fewer stories.” A three-story apartment building is not exempt under that paragraph.

A paid wage violation no longer automatically kills the tariff

Before AB 1104, an enforced willful violation meant the facility was not eligible for the tariff. Amended Public Utilities Code section 769.2(d) now provides a cure.

The facility remains eligible under a section 2827 or 2827.1 tariff “if restitution has been made to the affected workers and all associated penalties and fines have been paid.”

That turns the violation into a money problem rather than the end of the array’s economics. It does not erase enforcement. The Labor Commissioner may issue a civil wage and penalty assessment within 18 months after completion of the facility. A worker may file an administrative complaint or a civil action. A joint labor-management committee may also bring a civil action.

AB 1104 also does not remove the customer’s liability for nonpayment of wages or materials under Article XIV, Section 3 of the California Constitution. The customer lost the awarding-body paperwork, not that liability.

The first phone call decides whether prevailing wage belongs in your bid

At quoting time, ask whether the array or associated battery will receive service under a section 2827 or 2827.1 tariff. Record the building type, story count, and whether battery storage is included. Those are the same kind of specifics a solar or battery backup call needs up front, just with a payroll deadline attached now.

Those are intake questions, not post-award research. If nobody captures the answers on the first call, you will be reconstructing them after the contract is signed. That is too late to price prevailing wage correctly, the same failure mode covered in what to ask on every electrical call.

Treat the PWC-100 as a pre-mobilization task. Put July 1 and December 31 on a recurring certified payroll calendar. Add tariff type, building type, story count, battery scope, contract amount, and planned first-worker date to your estimating checklist. Price covered labor before award, and do not send anyone to the site until the required PWC-100 has been transmitted.

Battery scope is worth double-checking against your own numbers too, since the incentive side of these jobs has moved as much as the compliance side. Our NEM 3.0 and SGIP guide covers what changed on the money a customer expects back.