1,393 Prevailing Wage Violations Exposed Across a 14-Project Solar Portfolio — in One Week

The Client

Every project is its own LLC. Every LLC has its own construction financing and tax equity partnership. And every tax equity closing requires clean prevailing wage documentation — or the deal doesn't close.

That's the reality for this nationally recognized solar developer, one of the ten largest in the United States, with approximately 100 prevailing wage projects under construction annually across multiple states. At any given time, the client manages 50+ active projects through a network of over a dozen EPC contractors and their subcontractors. A single compliance gap on a single project can hold up tens of millions in tax equity capital.

The Challenge

The client's prevailing wage compliance process was entirely manual. Their team had built a complex system of Excel templates that EPC contractors were required to fill out for each project. This data was then piped into a BI dashboard for tracking. The process was fragile, time-consuming, and error-prone:

• Manual data entry across dozens of contractors. Each EPC had to manually enter hours, wage rates, and classification data into standardized Excel sheets — for themselves and all their subcontractors. With a dozen-plus EPCs, each with 3–4 subs, errors were inevitable.
• No real-time validation. The client's project management team could confirm data was being entered, but lacked the capacity to verify wage rates, overtime calculations, or apprenticeship ratios in real time. Issues compounded silently until the end of a project.
• Audit-stage surprises. An external consultant reviewed documentation only at the end of each project. By then, the volume of questions and discrepancies was overwhelming, with findings arriving too late to cure affordably.
• Tens of millions in annual exposure. Under IRA prevailing wage rules, a single underpayment — even by a dollar — that isn't corrected within the quarter triggers a $5,000 penalty. Apprenticeship violations escalate from $50/hour to $500/hour if the IRS determines "intentional disregard." Across 100 projects a year, the portfolio-level exposure runs into the tens of millions.

"There's so much pain in this process. We're spending hundreds of hours chasing Excel files, and we still can't tell you if we're actually compliant on any given project."
— VP of Construction, top-10 U.S. solar developer

The Engagement

The client chose to pilot Dili on an initial batch of 14 projects spanning Illinois and Virginia — deliberately selecting projects that were close to or past mechanical completion. This was the hardest possible test: a lookback across completed work with data scattered across SharePoint, inconsistent contractor formats, and missing documentation.

Timeline

Milestone	Date
Initial platform demo	October 2025
MSA signed	November 2025
Batch 1 work order (14 projects) executed	November 2025
Data ingestion and processing begins	January 2026
Priority project report delivered for tax equity transaction	February 2026
Batch 2 work order signed	February 2026

What Dili Did

Processed 83,000+ Labor Hours in Days, Not Months

Dili ingested and analyzed the entire portfolio in approximately one week — a process that had previously taken the client's team months of manual effort.

Across 2 states (Illinois and Virginia), 9,569 individual time entries, and 29 unique contractors.

Handled Messy, Real-World Data — Not Just Clean CSVs

This is where the difference between software and a compliance platform shows up. The data came in every conceivable format, and Dili's team worked through each one:

One contractor provided two separate Excel files — one for daily hours worked, another for pay rates — with no certified payroll at all. Dili's team developed a workaround to combine and ingest these non-standard files, then built a repeatable template so the contractor could continue submitting in their preferred format while still flowing into the system.

Other contractors submitted Illinois CTP forms, WH-347s, payroll exports, and ad-hoc spreadsheets. Dili's platform read and normalized all of them. No contractor was asked to change their workflow — Dili met them where they were.

Surfaced 1,393 Compliance Issues the Client Didn't Know About

Across the 14-project portfolio, Dili identified 1,393 compliance issues that the client's manual process had not caught:

Issue Category	Count	What It Means
Wage underpayments	311	Workers paid below the applicable prevailing wage rate
Apprenticeship violations	748	Missing apprentices, ratio violations, missing program documentation
Reporting & data quality	334	Missing fringe data, incorrect overtime allocation, unsigned certifications

Apprenticeship gaps were the single biggest risk. Nearly every project was missing Appendix A documentation — the core document substantiating apprenticeship ratios and program standards. One project had zero apprentice hours with no good faith effort documentation, creating exposure to intentional disregard penalties that could have turned $3,100 in fines into $31,000.

The largest single project in the portfolio — with over 22,000 labor hours — had 217 issues that had accumulated undetected. Another project carried over $100,000 in potential penalty exposure, virtually all of which could have been avoided with timely detection and correction.

Delivered a Tax-Equity-Ready Report Under Deadline Pressure

Midway through the engagement, one project became urgent: a tax equity investor required a prevailing wage compliance report as a condition of a pending transaction. The client's VP flagged it as top priority.

Dili pivoted immediately, completed the analysis, and delivered a preliminary compliance report within days. The tax equity partner accepted Dili's report format with no revisions — no back-and-forth, no reformatting, no follow-up questions.

The Results

What Came Next

Based on the results of the pilot, the client immediately signed a second work order covering additional projects. But the scope of the conversation shifted. This was no longer about a one-time lookback — it was about moving the client's entire prevailing wage operation onto Dili, permanently.

With approximately 100 projects under construction annually and 30+ more in pre-construction, the client is now transitioning from reactive, end-of-project audits to proactive, real-time compliance management. Dili works directly with their EPC contractors on an ongoing basis. Bi-weekly review meetings, automated reminders, and direct contractor onboarding are replacing the old cycle of manual data entry, BI dashboards, and end-of-project surprises.

The direction is clear: prevailing wage compliance becomes infrastructure, not overhead. The client's construction team focuses on building projects, and Dili handles the compliance layer end-to-end.

"I envision this works so well that my team can forget about prevailing wage, and you guys take them all."
— VP of Construction