As part of New York’s FY 2025-2026 Budget, the State’s Legislature passed major updates to the New York’s child labor laws, the largest seen in decades. The legislation sharply increases civil penalties, strengthens reporting and certification requirements, and eliminates several longstanding exemptions and loopholes for employing minors. Employers across all industries—especially retail, food service, and hospitality—should treat this as a clear signal that child labor enforcement is now a top state priority.
1. Civil Penalties Increase Dramatically
Effective immediately, employers face much steeper fines for child labor violations under Part W of the Budget Bill:
| Violation | Previous Penalty | New Penalty |
|---|---|---|
| First violation | up to $1,000 | up to $10,000 |
| Second violation | up to $2,000 | $2,000–$25,000 |
| Third or subsequent | up to $3,000 | $10,000–$55,000 |
If a violation results in serious injury or death of a minor, the fines now increase dramatically:
| Violation (Injury/Death) | Previous Penalty | New Penalty |
|---|---|---|
| First | triple max penalty | $3,000–$30,000 |
| Second | triple max penalty | $6,000–$75,000 |
| Third or subsequent | triple max penalty | $30,000–$175,000 |
Forework Tip: Even a first-time violation can now cost five figures. Employers should audit all hiring practices involving minors immediately—particularly in seasonal or part-time roles.
2. Expanded Compliance and Reporting Requirements
Two years from the law’s effective date, Part X of the Budget Bill will bring additional changes to how employers and minors are registered and certified:
- New State Database: The NYSDOL will create a centralized database tracking both employers and their minor employees.
- Employer Certification: Businesses must formally certify compliance, confirming that minors only perform legally permitted work.
- Electronic Working Papers: Minors will soon be able to apply for and register work permits electronically, replacing the traditional in-person system.
These changes are aimed at improving enforcement transparency and eliminating paperwork gaps that have historically allowed violations to go unnoticed.
3. Removal of Certain Exemptions
The new law also eliminates outdated exceptions that previously allowed minors to work under special circumstances, including:
- The exemption for newspaper carriers, and
- The allowance permitting employment of a 15-year-old deemed incapable of further instruction with a special certificate.
These changes reflect a broader push to align New York’s child labor framework with federal standards and to protect vulnerable youth from exploitation.
4. Ongoing Requirements for Employers of Minors
Even before these new provisions, New York employers were already subject to strict restrictions under the New York Labor Law and NYSDOL guidance, including:
- Maximum weekly and nightly hours based on age and school session status;
- Posting of work schedules for all minor employees, showing start/end times and meal breaks; and
- Ensuring minors hold valid working papers before beginning work.
The latest amendments add stronger enforcement mechanisms to these long-standing requirements.
What Employers Should Do Now
With heightened penalties and stricter compliance rules on the horizon, HR and payroll teams should act quickly:
- Audit all youth employment practices — including work hours, job duties, and scheduling.
- Verify all working papers and maintain organized documentation for inspection.
- Train hiring managers and supervisors on new restrictions and penalty risks.
- Plan for electronic certification and reporting changes slated to take effect in 2027.
- Update handbooks and postings to align with new requirements.
The Bottom Line
New York’s updated child labor laws make one thing clear: enforcement is intensifying, penalties are rising, and employers are expected to maintain airtight compliance.At Forework, we help employers navigate complex wage and hour laws with software that’s built for compliance—because protecting workers (and your business) starts with getting payroll right.