California Coogan Law: Trust Accounts, 15% Rule, and Permits

California’s Coogan Law requires employers of child performers to deposit 15% of the minor’s gross earnings into a blocked trust account that no one can touch until the child turns 18. The law is named for Jackie Coogan, the silent-film child star who discovered as an adult that his parents had spent nearly all of his childhood earnings. Today the protections reach beyond traditional actors to cover young athletes, musicians, voice-over artists, and children featured in monetized social media content.

Who the Law Covers

California Family Code Section 6750 applies to any contract in which an unemancipated minor provides creative or artistic services: acting, dancing, singing, playing music, stunt work, voice-over, songwriting, and directing all qualify. It also covers minors who participate as players in a sport and minors who license their name, likeness, or voice recording for entertainment use.¹

As of 2024, the statute explicitly includes “content creators” — individuals who create or share digital content on an online platform under a direct contractual relationship with third parties. That reaches vloggers, podcasters, social media influencers, and streamers.¹

One boundary to know: extras, background performers, and those working in similar capacities are excluded from the 15% trust set-aside, though other child labor protections still apply.²

The 15% Rule

The employer must set aside exactly 15% of the minor’s gross earnings under the contract and deposit that money into the Coogan Trust Account. This applies whether or not the contract has been submitted for court approval. “Gross earnings” means the full contract amount before deductions for agent commissions, manager fees, taxes, or anything else. The remaining 85% goes to the parent or guardian, who handles taxes and expenses out of that portion.²

The 15% is treated as the minor’s own separate property. Parents, guardians, and trustees cannot withdraw any of it or redirect it toward household expenses. No matter what the family’s finances look like, the child’s share stays locked away.

Opening the Trust Account

A parent or legal guardian must open a Coogan Trust Account within seven business days after the minor’s entertainment contract is signed by all parties. The account must be held at a California-based bank, savings and loan, credit union, brokerage firm, or company registered under the Investment Company Act of 1940. Whichever institution you choose, it must carry federal insurance through the FDIC, SIPC, or NCUSIF at all times.³

Within 10 business days of the contract signing, the trustee must prepare a written statement under penalty of perjury identifying the institution, the account, the minor beneficiary, and the trustee, with documentation from the institution confirming the account exists (an account agreement or passbook works). Bring the child’s Social Security number, a certified copy of the birth certificate, and, for guardians, a certified copy of the guardianship order.³

Get the names right across every document. The child’s name on the trust account has to match the name on the work permit and the entertainment contract exactly. Any mismatch, and the production’s payroll department may reject the deposit or delay processing.²

Employer Deposit Deadlines

Once the employer receives a copy of the trustee’s statement along with the minor’s certified birth certificate and any guardian documentation, the employer has 15 business days to deposit the 15% into the trust account. The clock runs from receipt of those documents, not from the start of employment. Many production companies use entertainment-specialized payroll services to handle these recurring transfers.²

If a parent, guardian, or trustee fails to provide the trustee’s statement within 180 days after the child starts working, the employer must forward the 15% to The Actors’ Fund of America instead. The Fund then becomes trustee of those earnings, and the employer’s obligation ends. This fallback exists so a parent’s paperwork delay doesn’t cause the child’s money to vanish.²

Why the Trust Account Controls the Work Permit

Under California Labor Code Section 1308.9, when the Labor Commissioner issues written consent for a minor to work under an entertainment contract, that consent becomes void after 10 business days unless a copy of the trustee’s statement proving the Coogan Trust Account exists is attached to it. Once attached, the work permit remains valid for six months.⁴

Failing to open the trust account quickly doesn’t just risk the child’s earnings. It can void the child’s authorization to work, put the production company in legal jeopardy, and cost the child the job.

How the Money Can Be Invested

Trust funds don’t have to sit in a basic savings account. California Family Code Section 6753 allows the trustee to invest in several low-risk categories:

Broad-based index funds or diversified equity funds registered under the Investment Company Act of 1940, invested broadly across a domestic or foreign regional economy (not a sector fund), with at least $250 million in assets under management.
U.S. government bonds, certificates of deposit, money market instruments, and money market accounts.
Mutual funds that invest solely in the government securities and instruments above.

Every investment must mature on or before the minor’s 18th birthday. Any proceeds earned must be redeposited into the trust or used to buy more qualifying investments, and the investments must be available through the financial institution holding the trust.⁵

Moving the Account to a New Institution

Families can switch financial institutions, but both sides have obligations. The institution sending the funds must notify the receiving institution in writing that the money is subject to the Coogan Law and must explain the statutory requirements that attach to it. The funds stay in trust and blocked throughout the transfer.⁶

After the move, the parent or guardian must promptly notify the minor’s employer in writing about the new institution and account number, with an updated trustee’s statement. Skipping this step disrupts payroll deposits and can trigger the 180-day countdown to The Actors’ Fund.⁶

Family Vloggers and Social Media

California extended Coogan-style protections to children who appear in family social media content through SB 764 (enacted in 2024) and Family Code Sections 6651 through 6653. These rules target parents monetizing their children’s appearances in vlogs and social media posts, where no traditional employer exists.

A minor is considered engaged in vlogging work when three conditions are met in a given month: at least 30% of the parent’s compensated video or image content features the child, those posts meet the platform’s compensation threshold or earn at least $0.10 per view, and the parent earns at least $1,250 from that content in the month.⁷

Once those thresholds are met, the vlogger-parent must establish a trust account within seven business days. The set-aside is not a flat 15%. Instead, the vlogger deposits a share of gross earnings proportional to the minor’s actual appearance time in the compensated content. When multiple children appear in the same content, the percentage is split equally among them.⁸

Record-keeping is substantial. Vlogger-parents must give each featured child monthly records showing the number of compensated posts, total minutes of content, how many minutes included the child, total compensation earned, and the amount deposited into the trust. If a vlogger knowingly violates these provisions, the minor can sue for actual damages, punitive damages, and attorney’s fees.⁸

Penalties for Non-Compliance

Employers who violate child entertainment labor laws, including trust deposit rules, face criminal penalties under California Labor Code Section 1303. A standard violation is a misdemeanor carrying a fine between $1,000 and $5,000, up to six months in county jail, or both. A willful violation raises the maximum fine to $10,000, with the same potential jail time.⁹

Employing a minor whose work permit has become void for lack of a Coogan trust account is itself a misdemeanor, and failure to produce the Labor Commissioner’s written consent is treated as prima facie evidence of illegal employment.¹⁰ Most productions will not let a minor on set without verified trust account documentation.

Accessing the Money at 18

No one can withdraw money from a Coogan Trust Account before the beneficiary turns 18 unless a superior court issues a written order allowing it. The court retains ongoing jurisdiction, and a parent, guardian, minor (through a representative), or trustee can petition to amend or terminate the trust by showing good cause. In practice, early access is granted only in unusual circumstances.³

Once the beneficiary turns 18, the process is straightforward. The now-adult performer brings a certified copy of the birth certificate to the financial institution. After the institution verifies age, the blocked status is removed and the individual gains full control of the balance.³

Taxes on Trust Earnings

The Coogan Law protects a child’s earnings from their parents. It does not protect them from the IRS. A minor’s earned income from entertainment work is taxable, and the child (or a parent filing on their behalf) must report it. The 85% paid to the parent for the child’s support is technically the child’s income too; the parent is custodian of it, not the earner.

Investment returns generated inside the trust — interest, dividends, and capital gains from the permitted investments — count as unearned income subject to the “kiddie tax.” For the 2026 tax year, the first $1,350 of a child’s unearned income is tax-free, the next $1,350 is taxed at the child’s own rate, and anything above $2,700 is taxed at the parents’ marginal rate. For a performer with a substantial trust balance invested in index funds or government bonds, this can create a real tax bill even though the child cannot touch the money. Working with a tax professional experienced in entertainment income helps keep estimated payments and filings on track.

1
California Legislative Information. California Code Family Code 6750
2
California Legislative Information. California Code Family Code 6752
3
Justia Law. California Code Family Code 6750-6753
4
California Legislative Information. California Code Labor Code 1308.9
5
California Legislative Information. SB 1162 Senate Bill – Chaptered
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SAG-AFTRA. Coogan Law Full Text
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California Legislative Information. California Code Family Code 6651
8
LegiScan. California Senate Bill 764
9
Justia Law. California Labor Code 1285-1312 – Minors
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California Legislative Information. California Labor Code 1308.5