This is a summary of published state regulations and union terms for production staff, current as of September 2026. It isn't legal advice. Child labor rules change and differ by state, so confirm them with the labor department where you shoot before you book a minor.
Why state law is the rulebook
The Fair Labor Standards Act's child labor provisions don't apply to "any child employed as an actor or performer in motion pictures or theatrical productions, or in radio or television productions," under 29 U.S.C. § 213(c)(3). That exemption leaves the rules to the states, and they vary a lot. California and New York have detailed entertainment-specific regulations, so they're the two compared here. If you're shooting somewhere else, don't assume either one applies.
SAG-AFTRA's Codified Basic Agreement follows the same logic. Section 50 says that when minors are employed in California, or taken out of California under a contract made there, California law governs. Everywhere else, the producer has to find and follow the local law, plus the union's own minimums.
Hours by age in California and New York
This is the table the 1st AD needs before the first draft of the schedule. "At work" means time at the place of employment. "Work" means time actually working, with school and rest making up the difference.
| Age | California, school day | California, no school | New York, school day | New York, no school |
|---|---|---|---|---|
| 15 days to 6 months | 2 hrs at work, 20 min work | Same | 2 hrs at work, 20 min work | Same |
| 6 months to 2 years | 4 hrs at work, 2 hrs work | Same | 4 hrs at work, 2 hrs work | Same |
| 2 to 6 years | 6 hrs at work, 3 hrs work | Same | 6 hrs at work, 3 hrs work | Same |
| 6 to 9 years | 8 hrs at work, 4 hrs work, 3 hrs school | 6 hrs work | 8 hrs at work, 4 hrs work, 3 hrs school | 6 hrs work |
| 9 to 16 years | 9 hrs at work, 5 hrs work, 3 hrs school | 7 hrs work | 9 hrs at work, 5 hrs work, 3 hrs school | 7 hrs work |
| 16 to 18 years | 10 hrs at work, 6 hrs work, 3 hrs school | 8 hrs work | 10 hrs at work, 6 hrs work, 3 hrs school | 9 hrs work |
California figures are from Title 8, Section 11760. New York figures are from Part 186-6.2, which covers work outside live theater. California's meal period isn't counted in the hours at work, and it can't be longer than half an hour (Section 11761). In New York, meal periods are counted inside rest and recreation and time at the workplace.
The two states line up closely, but the differences matter. A 17-year-old on a Saturday in New York can work nine hours. The same actor in Los Angeles gets eight. New York also allows up to two extra hours to finish a one-day assignment for children six months and older, but the child can't work the next day. And when a New York child comes to set after a full school day, the allowed time at the workplace drops by three hours.
New York sets clock limits, too. Outside live performance, a child performer can't work before 5:00 a.m., after 10:00 p.m. on a night before a school day, or after 12:30 a.m. on a non-school day. California's Section 11760(g) lets producers ask the Labor Commissioner in writing, at least 48 hours ahead, for permission for a minor to work earlier or later than the law otherwise allows, such as for night exteriors.
Twelve hours between days
Both states require 12 hours between a minor's dismissal and their next call. California adds two wrinkles. If the child's regular school starts less than 12 hours after dismissal, the production has to school them at the workplace the next day. And under Section 11763, makeup or hair done at the child's home counts as work time, can't start before 8:30 a.m., and still needs the 12-hour gap.
A worked example. Maya, 11, is dismissed from the set in Burbank at 7:40 p.m. on Thursday after a late scene. Her earliest call Friday is 7:40 a.m. Her school starts at 7:30 a.m., less than 12 hours after dismissal, so under Section 11760(i) the production has to school her at the workplace on Friday. Friday is a school day, so she gets nine hours at work, no more than five of them working and at least three in school. With a 7:40 a.m. call, nine hours runs to 4:40 p.m., and because California doesn't count a meal period of up to half an hour in those hours, a 30-minute lunch moves her latest release to 5:10 p.m. The turnaround calculator handles multiple release times, and turnaround rules compared sets minors' rules next to adult cast and crew.
Permits for the child and for the company
Both states issue separate permits to the child and the employer.
| California | New York | |
|---|---|---|
| Child's permit | Entertainment Work Permit, six months, renewable free; one-time 10-day temporary permit for new applicants at $50 | Child Performer Permit, valid 12 months; temporary permits available |
| Employer's authorization | Entertainment Permit to Employ Minors | Certificate of Eligibility to Employ Child Performers, renewed at least 30 days before it expires |
| Notice before work | Not listed on the permit page | Notice of Use of Child Performers at least 2 business days before the child starts |
| Trust account | 15% of gross earnings to a Coogan account | 15% of gross earnings to a child performer trust account |
California's 10-day temporary permit can't be issued immediately for infants between 15 days and one month old because a medical certification is required. New York's permit is only valid for paid work if the parent has attached trust account details.
Collect the permit with the deal, not at base camp. The minor work permit entry covers the California application, and the Coogan account entry explains when the 15% has to be deposited.
Studio teachers and supervision
California requires a studio teacher for minors from 15 days to their 16th birthday, and Section 11762 says no minor under 16 can be sent to wardrobe, makeup, or hair, or employed in any way, unless under the general supervision of a studio teacher. The exception is a call of up to an hour for wardrobe, makeup, publicity, or audio recording on a day school isn't in session, when a parent or guardian can accompany the child instead. The ratios and infant nurse requirements are in the studio teacher entry, and the studio teacher role page covers rates and hiring.
New York asks for a designated responsible person to supervise and safeguard child performers, which can be the parent. For infants, it requires one registered nurse and one responsible person for every three or fewer babies from 15 days to six weeks, and for every ten or fewer from six weeks to six months, matching California's infant ratios.
SAG-AFTRA's Section 50 adds requirements that apply outside California:
- If a minor is guaranteed three or more consecutive days, or scheduled for scenes on three or more consecutive days, the producer provides a teacher from the first day whenever the child's school is in session.
- Ratios are no more than 10 minors per teacher, or 20 if they're in no more than two grade levels.
- A minor must be taught an average of at least three hours a day, and no block shorter than 20 minutes counts.
- A parent or guardian must be present at all times while the minor works, with the right to be within sight and sound.
- For minors under 14, the producer designates one person on each set to coordinate the child's welfare.
- A moving car or bus can never be used as a classroom.
How this changes the schedule
A child's hours are the tightest limit on most shooting days they appear in. The AD's usual moves:
- Put the child's scenes first in the day, so the clock starts with work instead of waiting.
- Build school blocks into the day's plan with the teacher. Twenty-minute blocks count, so a setup change is a chance to bank school time.
- Shoot the child's coverage first and turn around on adults, then use a stand-in for the reverse if you need to.
- Board school holidays and summer days for heavy child scenes, because California gives a 9 to 16-year-old seven work hours on non-school days instead of five.
- Keep a written record of arrival, work, school, meal, and dismissal times. New York requires it, and SAG-AFTRA productions record tutoring on Exhibit G.
The scheduling guide for child actors has a boarded example.
Mistakes that come up
Booking a family's twins as one role without checking that both have permits. Each child working needs their own.
Assuming a non-union shoot is exempt. In California the studio teacher requirement comes from state regulation.
Using a California permit in Georgia. The rules follow where the child is working, unless the California contract rule in the SAG-AFTRA agreement applies, and even then the local state may have its own requirements.
Paying the minor's full wages to the parent. The trust account share has to go to the account, and the cast deal memo template has a place to record it.
Tracking minors in Storiara
Storiara's Cast & Crew module stores cast availability, and the day out of days is generated from the schedule, so you can see every day a child is working before you lock the schedule. Hour limits, school blocks, and permit numbers aren't tracked automatically, so keep them with the studio teacher's records.