Working with Minors

Minor talent must be onboarded as an employee. The parent or guardian will need to prepare and sign all digital onboarding forms for their child. Current and valid employment verification documents, work permit, and a Coogan Trust bank account must be provided for the child. 

How to Complete Form I-9 for a Minor

In Section 1 of the I-9 form, the minor’s parent or legal guardian:

• Completes the minor’s information and checks the box by the minor’s citizenship status.

• Enters “minor under age 18” in the signature of employee field.

• Completes the Preparer and/or Translator Certification section.

• Provides a supporting document from List C for their minor.

To see a list of all acceptable List C documents, please visit the U.S. Citizenship and Immigration Services page on Form I-9 Acceptable Documents.

Work Permit

Any minor from 15 days to 18 years of age requires a valid Work Permit.

IF THERE IS NO WORK PERMIT, THE MINOR CANNOT WORK AND MUST BE SENT HOME.

There are two options for work permits. For first time registrants, there is a one-time, 10-day work permit that you can get online for the same day and which costs $50. Or there is a free 6-month permit that you can renew. This permit can take anywhere from 7-10 days or longer to receive from the date of online application submission.

For more information and instructions on how to apply for an entertainment work permit for minors, please visit the relevant page on the California Department of Industrial Relations website.

Coogan Trust Accounts

The parent or guardian of minor talent must supply proof of a Coogan Trust Account in their minor’s name in order for payment to be received for any work their minor performs in the entertainment industry.* 15% of the minor’s gross wages must be withheld by the employer and deposited into the Coogan account within 15 days of employment. The parent must supply the Coogan Trust routing and account numbers to the employer. These wages will also be taxed.

* The entertainment industry is defined in state regulations as "...any organization, or individual, using the services of any minor in: motion pictures of any type (film, videotape, etc.), by any medium (theater, television, videocassette, etc.); photography; recording; modeling; theatrical productions; publicity; rodeos; circuses; musical performances; and any other performances; and any other performances where minors perform to entertain the public." [8 CCR 11751]

VERY IMPORTANT:

Not all banks will provide Coogan Trust Accounts, so please make sure to call your bank in advance and check. Wells Fargo and Bank of The West locations, as well as a handful of credit unions, will open this type of blocked account. They require an appointment and specific documentation, so please call the bank in advance to book an appointment and plan accordingly. You have 15 days from the first date of work to open the account. These accounts can be closed or frozen due to inactivity so please make sure to check with your bank to find out their terms to avoid rejected payments if your minor does not work regularly.

It is important to note that you will need to provide the correct routing number for ACH payment when completing the direct deposit form. Coogan Trust Accounts have one routing number for check deposit that will show on the account’s deposit slips and another routing number for direct deposit/ ACH payment that will show on the Statement of Trustee that the bank will provide you.

Other On-Set Requirements

• The parent or guardian of minor talent must be present for any minor under 16 years of age.

• One studio teacher must be present for every 10 minors under 16 years of age.

• Studio teachers may require early meal periods for minor talent if they determine that a child is uncomfortable or hungry.

Hours of Work

California child labor laws set the amount of time youth are permitted to work and remain at the place of employment within a 24-hour period based on age, as follows:

• Children who are at least 15 days old, but are not yet 6 months old, may remain at the place of employment for a maximum of 2 hours. In addition, they:

  • May only work for up to 20 minutes in a day.

  • May not be exposed to light of intensities greater than 100 foot-candles for more than 30 seconds at a time.

  • A nurse and a studio teacher must be provided for each 3 or fewer babies who are between 15 days old and 6 weeks old, and for each 10 or fewer infants who are 6 weeks old to 6 months old.

• Youth who are at least 6 months old, but are not yet 2 years old, may remain at the place of employment for a maximum of 4 hours per day and may work for no more than 2 hours, with the remaining amount of time spent either in rest or recreation.

• Youth who are at least 2 years old, but are not yet 6 years old, may remain at the place of employment for a maximum of 6 hours and may work no more than 3 hours, with the remaining amount of time being spent in rest, recreation, and/or education.

• Youth who are at least 6 years old, but are not yet 9 years old, may remain at the place of employment for a maximum of 8 hours per day. In addition:

  • When school is in session, they may work no more than 4 hours, with at least 3 hours of the remaining time being spent in schooling and at least 1 hour spent in rest and recreation.

  • When school is not in session, they may work no more than 6 hours, with 1 hour of rest and recreation.

• Youth who are at least 9 years old, but are not yet 16 years old, may remain at the place of employment for a maximum of 9 hours per day. In addition:

  • When school is in session, they may work no more than 5 hours, with at least 3 hours of the remaining time being spent in schooling and at least 1 hour spent in rest and recreation.

  • When school is not in session, they may work no more than 7 hours, with 1 hour of rest and recreation.

• Youth who are at least 16 years old, but are not yet 18 years old, may remain at the place of employment for a maximum of 10 hours per day. In addition:

  • When school is in session, they may work no more than 6 hours, with at least 3 hours of the remaining time being spent in schooling and at least 1 hour in rest and recreation.

  • When school is not in session, they may work no more than 8 hours, with 1 hour spent in rest and recreation.

  • When permission has been obtained for the youth to work during school hours for a period not to exceed 2 consecutive days, they may work for no more than 8 hours.

Excused School Absences

A school may excuse the absences of a pupil who hold an entertainment work permit. The law limits the number of excused absences for a child holding an entertainment work permit to five absences per school year, each of which may consist of up to five days.

A child excused from school attendance because of employment in the entertainment industry must be instructed during the absence by a studio teacher certified by the Labor Commissioner in accordance with the California Code of Regulations. All work, grades, and credit that the pupil completes with the studio teacher must be accepted by the school district or county superintendent of schools.