Child-labor law got a lot more attention starting in 2023 after a wave of reporting showed migrant minors working overnight shifts at slaughterhouses, auto plants, and fast food chains. DOL enforcement actions have climbed every year since. For 2026, the agency has child-labor compliance listed as a top strategic priority, and the civil money penalty for a serious child-labor violation is $15,138 per minor involved. For employers, the rules haven't shifted much since the 1938 Fair Labor Standards Act, but enforcement and scrutiny have.
The FLSA Federal Baseline for Child Labor The FLSA sets three age bands. Workers under 14 can't generally be employed in non-agricultural work, with narrow exceptions for newspaper delivery, entertainment, and family businesses. Workers aged 14 and 15 can work limited hours in specific non-hazardous jobs, with hour limits during school days and school weeks. Workers aged 16 and 17 can work unlimited hours in most jobs, but 17 occupations classified as hazardous (roofing, operating certain machinery, mining) remain off-limits until age 18.
The hour limits for 14 and 15-year-olds are specific: no more than 3 hours on a school day, 18 hours in a school week, 8 hours on a non-school day, and 40 hours in a non-school week. No work before 7 a.m. or after 7 p.m. during the school year (9 p.m. from June 1 to Labor Day).
State Laws That Go Beyond Federal Rules States set their own child-labor rules, and many are stricter than the FLSA. Some states lowered minimum ages in 2023 and 2024 (Iowa, Arkansas, Florida) while others raised penalties and tightened work permit rules (California, Washington, New Jersey). An employer with multi-state operations has to know both the federal floor and each state ceiling.
Work permit requirements vary. About 40 states require minors to obtain an employment certificate or "working papers" before starting a job, typically from the school district. Agricultural exemptions are broader than non-agricultural ones in most states.
What Counts as a Hazardous Job for Minors? The DOL publishes 17 Hazardous Occupation Orders covering non-agricultural work and 11 for agricultural work. The lists include operating power-driven meat processing equipment, roofing, excavation, driving motor vehicles as a primary duty, and working with certain chemicals. The full list sits at the DOL website, and the penalty for violations of these rules is higher than standard child-labor penalties.
Why Child-Labor Enforcement Surged in 2026 DOL child-labor enforcement actions increased over 40% in fiscal year 2024, and funding for inspectors expanded in the 2025 budget. Penalties escalate quickly when violations involve hazardous work or result in injury. A fatal workplace injury to a minor triggers maximum penalties and frequently criminal referrals.
Third-party staffing arrangements don't shield employers. The DOL routinely holds the ultimate employer jointly liable when staffing agencies supply underage workers, even if the direct hiring was handled by the agency. This matters especially in food processing, logistics, and construction.
Staying Ahead of Child-Labor Law Compliance The practical checklist: verify age documentation at hiring and keep it on file, know the specific hour and job restrictions for each age band, require work permits where state law mandates them, audit staffing agency relationships to confirm their own age verification practices, and train hiring managers on the hazardous occupation orders. Build child-labor compliance into the same onboarding workflow that handles I-9 verification.
The U.S. Department of Labor's Wage and Hour Division publishes current child-labor rules, fact sheets, and state-by-state guides at dol.gov/agencies/whd/youthrules . That's the first stop for any employer reviewing its child-labor law compliance, and the DOL's YouthRules initiative has age-specific guides employees and parents can use too.
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