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

California’s child actor laws require an Entertainment Work Permit before a minor can be hired, cap on-set time based on the child’s age, mandate a studio teacher for school-aged performers, and set aside 15% of gross earnings in a blocked trust account under the Coogan Law. The framework covers film, television, theater, commercials, and, since 2024, monetized social media content. Federal child labor rules exempt child performers, so California’s regime is what actually governs most productions filming in the state.

The Entertainment Work Permit

Every minor working in California entertainment needs an Entertainment Work Permit issued by the Division of Labor Standards Enforcement.¹ A parent or guardian applies online. The standard permit runs six months, renews at no charge, and must be kept current until the minor turns 18.

Applicants who need to start work immediately can request a 10-day temporary permit for a one-time $50 fee, issued right after the online application is completed. A Social Security Number is not required for the temporary version.²

The application requires proof of age and documentation from the child’s school. Minors between 14 and 17 must complete sexual harassment prevention training as part of the process.¹ Failure to produce a valid permit on set is treated as prima facie evidence that the minor is being employed illegally.

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 deposited into a blocked trust account, commonly called a Coogan Account.³ The law is named for Jackie Coogan, the 1920s child star whose parents spent nearly all of his earnings before he reached adulthood.

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 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 (formerly The Actors’ Fund of America), which becomes trustee of those funds. The employer must notify the parent by certified mail when this happens.³

No one can withdraw funds before the minor turns 18 without a court order. At 18, the beneficiary accesses the account by presenting a certified copy of their birth certificate to the financial institution. Emancipated minors can access the funds with a declaration of emancipation.⁴

The 15% set-aside does not apply to employers of minors working as extras, background performers, or in a similar capacity.³

Court-Approved Contracts

Entertainment, sports, and artistic contracts involving minors can be submitted to superior court for approval under Family Code Section 6750. A parent or guardian files the petition in the county where the minor lives, works, or where the employer has its principal office. The court order approving the contract triggers the 15% set-aside, but the trust obligation applies either way: even when a contract is not submitted for court approval, the employer must still set aside 15% of gross earnings.³

Work Hour Limits by Age

California caps both how long a child can actually work and how long they can be present at the workplace. Every age bracket also requires a 12-hour break between dismissal and the next call time, with no exceptions.⁵

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

Time in makeup and hairdressing counts as work time, even when done at the minor’s home with production personnel.⁶ It’s one of the most commonly overlooked rules on set. A two-hour hair session before cameras roll eats directly into the child’s allowable work hours.

Meal periods do not count as work time but must be provided within six hours of call time or the previous meal. Workdays can be extended up to 30 minutes to accommodate a meal.⁷

Education and the Studio Teacher

School-aged children working on set must receive at least three hours of instruction per day when school is in session. No single block shorter than 20 minutes counts toward that total.⁵ A studio teacher provides the 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.⁸

For minors under 16, the studio teacher also serves as a welfare worker with authority to monitor working conditions, physical surroundings, signs of fatigue, and whether the demands on the child are appropriate for their age and stamina.⁹ That gives the teacher real power on set. If a child is being pushed too hard, the schedule bends to the child, not the other way around.

Parental Presence on Set

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. This applies to every minor under 18. The employer must provide 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 reinforces those protections.⁹

Social Media and Content Creators

In 2024, Governor Newsom signed two bills bringing online content under child performer protections. AB 1880 extends the Coogan Law to minors employed as content creators on platforms like YouTube, applying the same 15% trust requirement that governs traditional entertainment work. SB 764 establishes financial and legal protections for minors featured in monetized online content created by their parents or guardians, requiring a percentage of earnings to be placed in trust.¹⁰

The gap this closed was substantial. A child on a studio-produced show had robust financial protections; a child generating millions of views on a parent-run channel had none. Both now sit under the same framework.

Where Federal Law Sits

Federal child labor rules under the Fair Labor Standards Act exempt child actors and performers. The exemption covers minors employed as actors or performers in motion pictures, theatrical productions, or radio and television productions who actively participate in a broadcast or production. It does not extend to stand-ins, script writers, directors who are neither seen nor heard by the audience, or technical crew such as engineers and stagehands.¹¹ Because the federal government steps back, California’s rules are what productions filming in the state must satisfy.

Taxes on a Child’s Earnings

Entertainment earnings are taxable, and parents sometimes get caught off guard. If a minor can be claimed as a dependent and earns above certain thresholds, a separate return is required. For the 2025 tax year, a dependent with earned income over $15,750 must file, and the threshold for unearned income is $1,350.¹² A working child actor will typically clear those thresholds quickly.

The kiddie tax also reaches investment income generated by the 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 8615.¹³ Unearned income includes interest, dividends, and capital gains from the trust. Aggressive investment inside the account can create a tax liability that needs planning.

Penalties for Violations

Violating California’s child labor laws is a misdemeanor. Employing a minor in entertainment without the required permit, exceeding work-hour limits, or otherwise violating the child labor statutes can bring fines up to $10,000 and imprisonment of up to six months, or both. Willful violations sit at the harsher end of that range.¹⁴ Productions caught cutting corners also face the practical consequence of being shut down while the issue is resolved.

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
4
California Legislative Information. California Family Code 6753
5
California Department of Industrial Relations. California Code of Regulations Title 8 Section 11760 – Working Hours of Minors
6
California Department of Industrial Relations. California Code of Regulations Title 8 Section 11763 – Work Time
7
California Department of Industrial Relations. Entertainment Industry Summary Chart – Hours of Work
8
California Department of Industrial Relations. Studio Teachers
9
California Department of Industrial Relations. California Code of Regulations Title 8 Section 11755.3 – Studio Teacher’s Authority
10
Office of the Governor. Governor Newsom Joins Demi Lovato to Sign Legislation to Protect the Financial Security of Child Influencers
11
eCFR. 29 CFR 570.125 – Actors and Performers
12
Internal Revenue Service. Check if You Need to File a Tax Return
13
Internal Revenue Service. Instructions for Form 8615
14
California Department of Industrial Relations. Summary Chart – Minors in the Entertainment Industry