A child who signs a modeling contract enters the workforce, and the law treats that work seriously. In California and New York, a child model’s earnings must be protected, the hours they work are limited and a parent or guardian must sign off on the permits that make the job lawful. Parents who handle a child’s first booking often focus on the photoshoot itself and overlook the paperwork that follows. This guide sets out the core rules in the two states where most child modeling work takes place.
The Coogan Law in California
California’s Coogan law dates back to 1939, when the child actor Jackie Coogan discovered that his parents had spent most of his earnings. The Legislature responded with a rule that the family could not take the child’s money. The current framework sits in Family Code sections 6750 to 6753. Those sections require an employer to set aside 15 percent of a minor’s gross earnings in a blocked trust account, known as a Coogan account.
The employer must deposit that share within 15 business days of receiving the trustee’s statement. The money belongs to the child, and it stays in the account until the child reaches 18, unless a court approves an earlier withdrawal. SAG-AFTRA’s explanation of the law notes that a change in 2000 confirmed that a minor’s entertainment earnings belong to the child, not to the parents.
California also requires the account before the work begins. Parents must open a Coogan account at a California bank, and they must provide proof of that account before the state will issue an entertainment work permit. Without that proof, the child lacks a valid permit, and the employer cannot lawfully put the child to work.
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Work Permits and Hours
A child who works in the entertainment industry in California needs an Entertainment Work Permit from the state’s Division of Labor Standards Enforcement. The Division issues a temporary permit for a single short engagement, which the Backstage guide to Coogan law describes as a one-time, 10-day permit. A standard permit covers longer or repeat work. The permit also depends on the trust account and the school arrangements that the family has put in place.
The state also limits hours, and the limits depend on age. Parents should check the current hours rules before booking a shoot that runs late, because a long day can breach the permit even when the child is well and the parent is present. California’s rules also require a parent or guardian to be on set with the child, which gives the family a direct role in supervising the work.
New York’s Child Model Act
New York took a different route. Until 2013, models under 18 fell outside the state’s child labour protections, and the Model Alliance, founded by former model Sara Ziff, campaigned to close that gap. The Child Model Act took effect in 2013 and classified print and runway models under 18 who live or work in New York as child performers.
Under the Act, a child model must hold a Child Performer Permit issued by the state Department of Labor before work begins. The Department states that the permit is free and valid for one year, and a temporary permit allows a child to work for 15 days. An employer who engages a child model must hold a Certificate of Eligibility from the Department and must notify the Department at least two days before the child starts. The Department also requires a parent or guardian to review information about eating disorders before applying for the permit.
The Act brings models under the same protections that apply to other child performers. Those protections include the trust account and the limits on working hours, as well as a designated responsible person to monitor children under 16 on the premises. FLJ’s analysis of the rights of fashion models covers the Child Model Act alongside the broader employment rules that govern adult models.
Protecting the Trust Account
A Coogan or trust account protects a child only if the parent manages it properly. California’s Family Code requires the trustee to account for the funds each year, following the rules that govern trustees in the Probate Code. Parents who act as trustees must keep records of every deposit, every withdrawal and every investment. Using the money for household costs or other family expenses without court approval breaches the trustee’s duty.
Parents also need to plan for tax. A practitioner’s guide to child performer tax rules explains that California requires the parent or guardian to pay the tax on earnings from the minor’s trust account, which means the family must budget for that liability from the start. Parents should confirm the tax position with an accountant before the first payment arrives.
Parents’ Rights and Their Limits
Parents hold the right to consent to a child’s work, to attend the shoot and to decide, together with the child, whether to take a booking. That authority has limits. The state can refuse a permit, the employer can refuse a child who lacks one and the trust rules apply whatever the parents prefer. A parent cannot sign away those protections on the child’s behalf.
Parents should also watch for exploitation that the paperwork does not reveal. The Model Alliance’s Models’ Bill of Rights includes special provisions for models under 18, which FLJ has summarised. Those provisions cover the protection of private changing areas and the need for transparent accounting, both of which give a young model a practical measure of safety on set.
Social Media and Child Content
Child modeling now overlaps with child content creation. California has extended its Coogan framework to some online work. Under Assembly Bill 1880, which took effect on 1 January 2025, the set-aside rules cover children who work as vloggers, podcasters, social media influencers and streamers for a third party. A separate measure, Senate Bill 764, sets out duties for parents who monetise content that features their own children. Families who post children’s content for brand deals should check whether the rules apply before accepting the first payment.
Start With the Paperwork
Parents who want a child in front of the camera should start with the permit, the trust account and the employer’s registration, in that order. Each step protects the child from the risk of an unpaid or unlawful booking. The same checklist applies whether the job is a print campaign, a runway show or an online video.
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