New research shows that work permits reduce child labor violations: State legislators must strengthen, not eliminate, youth work permits
In the past two years, states across the country have weakened child labor protections just as violations of these standards have risen, revealing significant weaknesses in both state and federal child labor laws and their enforcement.
Fortunately, there are proven strategies for strengthening standards that protect children, such as youth work permits—which outline the potential hours and work duties for a minor worker. In particular, youth work permits ensure that jobs children start as young as age 14 or 15 come with safe conditions and hours that don’t interfere with their education and development. In this post, we share highlights from new research that sheds light on the effectiveness of youth work permits and suggest how states can strengthen permit programs as legislative sessions begin this month.
States have led the way on protecting youth workers, but youth work permits are under threatStates have historically played an important role in setting child labor standards that exceed minimum federal standards set by the 1938 Fair Labor Standards Act (FLSA). Though the FLSA governs work hours for minors under age 16 and outlines prohibitively hazardous occupations for minors under age 18, many other safeguards—like rest breaks or protections from overnight shifts for 16-year-olds—are absent from federal law and left up to states.
Youth work permits are similarly not required under federal law. The majority of states and the District of Columbia require them in some form (see Figure 1), but they have recently come under attack by right-wing think tanks and industry groups seeking to provide employers unfettered access to cheap labor. Since 2023, eight states have proposed eliminating youth work permits, and three have signed these measures into law.
Figure 1
Proponents of eliminating youth work permits argue that work permits are not effective at deterring violations, are overly burdensome on employers, and take away parents’ right to decide whether to let their child work. However, none of these claims are accurate, as we explain below.
New data show work permits help prevent child labor violationsRecent research using comprehensive data from the Department of Labor’s Wage and Hour Division provides the first quantitative evidence that work permits help prevent child labor violations. Between 2008 and 2020, states that mandated employment certificates saw 15.5% fewer child labor violation cases and 35.2% fewer minors involved in these violations compared with states that had no such requirements (see Figure 2).
Figure 2
The impact is particularly consistent in high-risk industries. In the accommodation and food services sector—which accounts for over half of all child labor violations—states with work permit requirements saw 18.5% fewer violation cases and 34.6% fewer minors involved in violations. Further, states with work permit requirements saw nearly 30% lower civil penalties per minor involved in the violations, suggesting these requirements also help prevent more serious forms of child labor exploitation.
The research also revealed that work permits are particularly important during periods of low unemployment—like we are experiencing today—as employers turn to children to fill job vacancies. When unemployment rates decrease by one percentage point, child labor violations increase by 5.7%.
States with lower per capita income saw more violations, highlighting the need for protective measures in economically challenged areas. The data also showed a significant correlation between the arrival of unaccompanied migrant children and increased child labor violations, emphasizing the importance of maintaining strong protective measures for vulnerable youth.
The research leaves no room for doubt: Work permits are a proven policy tool that help prevent child labor violations. Rolling back these requirements would remove a crucial layer of protection at a time when we’re seeing concerning increases in child labor violations nationwide.
The work permit approval and documentation process plays an essential roleYouth work permits are often simple, one-page forms that are quickly processed by employers and serve important purposes—ensuring a child’s work is safe and age-appropriate, informing parents of their child’s rights and affirming their consent, and aiding in investigations of potential violations. In states like Wisconsin, the work permit process not only serves a documentation function but also generates the revenue needed to investigate potential violations.
To the extent that the processing of youth work permits takes time and effort, the process is deliberate, and when permits are denied, it’s for good reason. In 2023, the Maine Labor Department reported denying about 200 out of 4,700 youth work permit applications because the proposed work duties involved hazardous work that is prohibited for minors.
If youth employment is intended to benefit young workers and not simply their employers, then a system that allows hiring minors with maximum speed and convenience for the benefit of employers seeking cheap labor should not be the goal.
Work permits ensure informed consent from parents and guardiansThe decision about whether a child can or should seek employment rests with families. Work permits formalize parental consent, requiring employers to give parents information about the child’s job in writing and ensuring that a child’s potential work activities are safe and age-appropriate. Eliminating work permits takes away a parent’s right to make an informed decision about whether a job is appropriate for their child.
At the same time, most parents are not experts on workplace health and safety or labor and employment law, and they should not be held responsible for identifying occupations that may be particularly hazardous or illegal for minors. This is why permit systems that engage all stakeholders—parents, schools, employers, and the government—are the best way to ensure compliance with the law and the well-being of children.
State legislators should strengthen—not weaken or eliminate—their youth work permit systemsAs state legislators prepare for legislative sessions to begin, they should oppose misguided attempts to eliminate youth work permits and look to strengthen them by making sure the process is clear, accessible, and effective at keeping minors safe at work. Lawmakers can expand their use of the work permit system as an opportunity to educate young workers and their families about their rights and the work duties they cannot by law be asked to perform. State labor agencies can also require employers to receive training on federal and state child labor laws.
In 2024, Illinois strengthened its work permit process in a comprehensive bill that bolstered child labor standards and enforcement, and a similar bill was recently approved in the Michigan Senate and awaits consideration in the House. These bills should serve as a guide to other states on how to modernize their child labor laws and support the rights of young people to access job opportunities that are safe and age-appropriate.
Donald Trump’s Project 2025 proposes allowing states to opt out of federal child labor laws and seeks to make it easier for employers to hire children for hazardous jobs. At a moment when federal standards are likely to come under attack, the responsibility of state lawmakers to raise their own standards is especially urgent.
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