Child Actor Laws in California: Permits, Coogan Trust & Hours

Child actor laws in California set out a tight framework: before a minor can be hired for film, television, theater, commercials, or monetized online content, a parent or guardian must obtain an Entertainment Work Permit, the production has to follow strict daily hour caps that tighten with the child’s age, a studio teacher must deliver schooling on set, and 15% of the child’s gross earnings must be deposited into a blocked trust account the child cannot touch until 18.

The Entertainment Work Permit

No minor can legally work in California entertainment without an Entertainment Work Permit issued by the Division of Labor Standards Enforcement.¹ A parent or guardian applies online. The standard permit lasts six months, renews at no charge, and must keep being renewed until the minor turns 18.

If work is about to start and there is no time to wait, a first-time applicant can get a temporary 10-day permit for a one-time $50 fee, issued immediately after the online application is submitted. A Social Security Number is not required for the 10-day version.²

The application requires proof of the child’s age and documentation from their school. Minors 14 through 17 must also complete sexual harassment prevention training as part of the permit process.¹

The Coogan Law and the 15% Trust

California Family Code Sections 6750 through 6753 require that 15% of a minor performer’s gross earnings be set aside in a blocked trust account, commonly called a Coogan Account.³

The parent or guardian must open the account at a California-based bank, credit union, brokerage firm, or registered investment company within seven business days of the contract being signed. The institution must be insured by the FDIC, SIPC, or NCUSIF.⁴ Once the employer receives the trustee’s statement and a certified birth certificate, the employer has 15 business days to deposit the 15%.³

If the parent or guardian has not provided a trustee’s statement within 180 days after the minor starts working, the employer must forward the 15% to the Entertainment Community Fund, which becomes the trustee of those funds and must be notified to the parent by certified mail.³ The money is caught either way.

Nobody can withdraw from the trust before the minor turns 18 without a court order. At 18, the beneficiary presents a certified copy of their birth certificate to the financial institution and takes control of the account. An emancipated minor can access the funds earlier with a declaration of emancipation.⁴

Court approval of the contract is permitted but not required. Even without court approval, the employer must still set aside the 15%, which closes the obvious loophole.³

One boundary worth knowing: the 15% set-aside does not apply when a minor works as an extra, background performer, or in a similar capacity. If the extra is placed through a casting agency, that agency is still treated as the minor’s employer for other purposes under the Coogan Law.³⁵

How Many Hours a Child Can Be on Set

California limits both actual work time and total time at the workplace, and the cap gets tighter the younger the child. Every age group also requires a full 12-hour break between dismissal and the next day’s call time, with no exceptions.⁶

15 days to 6 months: up to 2 hours at the workplace, with no more than 20 minutes of actual work. Light greater than 100 foot-candles can hit the baby for no more than 30 seconds at a time.
6 months to 2 years: up to 4 hours at the workplace, with no more than 2 hours of work.
2 to 6 years: up to 6 hours at the workplace, with no more than 3 hours of work.
6 to 9 years: up to 8 hours at the workplace. On school days, 4 hours of work, 3 hours of school, 1 hour of rest. On non-school days, work can rise to 6 hours.
9 to 16 years: up to 9 hours at the workplace. On school days, 5 hours of work, 3 hours of school, 1 hour of rest. Non-school days, up to 7 hours of work.
16 to 18 years: up to 10 hours at the workplace. On school days, 6 hours of work, 3 hours of school, 1 hour of rest. Non-school days, up to 8 hours of work.

Hair and makeup count as work time, even when done at the child’s home by production personnel.⁷ A two-hour styling session before cameras roll eats directly into the allowable hours. Meal periods are not counted as work time, but must be provided within six hours of call or the previous meal, and the workday can be extended by up to 30 minutes to fit a meal.⁸

School and the Studio Teacher

School-aged minors must receive at least three hours of instruction per day when school is in session, and no block shorter than 20 minutes counts toward the total.⁶ A studio teacher delivers that instruction and coordinates with the child’s regular school.

Studio teachers must hold a valid California teaching credential: a combined elementary and secondary credential, a California Multiple Subject K-12 credential, or a single-subject credential in English, math, social science, science, or a foreign language.⁹

For minors under 16, the studio teacher also serves as a welfare worker. The teacher has authority to consider working conditions, physical surroundings, signs of fatigue, and whether the demands on the child are appropriate for their age and stamina.¹⁰ That is a real power on set. If the teacher objects, the production has to adjust.

Parent Presence and On-Set Safety

A parent or guardian must be present at all times while a minor is working, and has the right to remain within sight and sound of the child during both work and rest periods. The employer is responsible for a safe and sanitary environment, appropriate dressing facilities, and protection from hazardous conditions or equipment. For children under 16, the studio teacher’s welfare authority adds a second layer of oversight.¹⁰

Child Influencers and Online Content

In 2024, Governor Newsom signed two bills extending the state’s protections to minors in monetized online content. AB 1880 brings YouTube and similar content creators under the Coogan Law, requiring the same 15% trust set-aside. SB 764 adds financial and legal protections for minors featured in monetized content made by their parents or guardians, requiring a percentage of earnings be placed in trust.¹¹ The gap had been real: a child on a studio-produced show had full protections while a child on a family-run channel had none.

Why Federal Law Doesn’t Fill the Gap

Federal child labor rules under the Fair Labor Standards Act exempt children employed as actors or performers in motion pictures, theatrical productions, or radio and television productions. The exemption covers performers who actively participate in a broadcast or production, but not stand-ins, script writers, directors who are neither seen nor heard, or technical crew like engineers and stagehands.¹² Because the federal government steps back, California’s rules are what actually govern a production filming in the state.

Taxes on a Child Performer’s Earnings

Entertainment income is taxable, and the thresholds come up fast. For the 2025 tax year, a dependent with earned income over $15,750 must file, and the threshold for unearned income is only $1,350.¹³

The “kiddie tax” applies to investment income in a Coogan account. If a child’s unearned income exceeds $2,700, the excess is taxed at the parent’s marginal rate rather than the child’s, reported on IRS Form 8615.¹⁴ Unearned income includes interest, dividends, and capital gains from the trust, so an aggressively invested Coogan account can create a tax bill parents did not plan for.

Penalties for Violations

Employing a minor in entertainment without the required permit, exceeding work-hour limits, or otherwise violating the child labor statutes is a misdemeanor. Penalties include fines up to $10,000 and imprisonment of up to six months, or both, with willful violations drawing the higher end. Failure to produce a valid work permit is treated as prima facie evidence of illegal employment.¹⁵ A production that cuts corners on child performer compliance risks criminal exposure and a shutdown while the issue is sorted out.

1
California Department of Industrial Relations. Entertainment Work Permit for Minors
2
Labor Commissioner’s Office. Procedures for Obtaining an Entertainment Work Permit for Minors
3
California Legislative Information. California Family Code 6752
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California Legislative Information. California Family Code 6753
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California Legislative Information. California Family Code 6750
6
California Department of Industrial Relations. California Code of Regulations Title 8 Section 11760 – Working Hours of Minors
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California Department of Industrial Relations. California Code of Regulations Title 8 Section 11763 – Work Time
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California Department of Industrial Relations. Entertainment Industry Summary Chart – Hours of Work
9
California Department of Industrial Relations. Studio Teachers
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California Department of Industrial Relations. California Code of Regulations Title 8 Section 11755.3 – Studio Teacher’s Authority
11
Office of the Governor. Governor Newsom Joins Demi Lovato to Sign Legislation to Protect the Financial Security of Child Influencers
12
eCFR. 29 CFR 570.125 – Actors and Performers
13
Internal Revenue Service. Check if You Need to File a Tax Return
14
Internal Revenue Service. Instructions for Form 8615
15
California Department of Industrial Relations. Summary Chart – Minors in the Entertainment Industry