Workers under 18 need Form I-9, too: accept either List A documentation or a List B document plus a List C document. I’ll walk you through the document options, deadlines, and separate youth-employment checks - without asking workers for extra proof.
Here’s what to check before their first shift:
My approach: <u>keep I-9 records and youth-work approvals separate</u>, and keep ID images and document numbers out of scheduling notes.
Let each employee choose from the Lists of Acceptable Documents. A List A document establishes both identity and employment authorization. Examples include a U.S. passport, Permanent Resident Card, or Employment Authorization Document. If the employee provides acceptable List A documentation, don't request List B or List C documents.
If the employee can't present standard List B ID, review the under-18 alternatives below.
With List B plus List C, the documents serve separate purposes. List B establishes identity. Common options include a state-issued driver’s license or ID card; a federal, state, or local government ID; or a school ID with a photograph. A state-issued ID or license meets List B requirements if it includes a photo or the required identifying details. List C establishes employment authorization.
An unrestricted Social Security card is acceptable for List C, but it isn't required. Cards with any of these markings aren't acceptable List C documents:
“NOT VALID FOR EMPLOYMENT”
“VALID FOR WORK ONLY WITH INS AUTHORIZATION”
“VALID FOR WORK ONLY WITH DHS AUTHORIZATION”
Don't demand a specific document or extra proof because the employee is under 18.
The under-18 options below replace standard List B ID only when the worker can't present it. Each establishes identity only and must be paired with an acceptable List C document.
If you use E-Verify, any List B document paired with List C must contain a photograph. Check the document itself - don't assume it includes a photo based on its category.
| Document | Required List C pairing | E-Verify photo requirement |
|---|---|---|
| School record or report card | One acceptable List C document | The particular record must contain a photograph. |
| Clinic, doctor, or hospital record | One acceptable List C document | The particular record must contain a photograph. |
| Day-care or nursery school record | One acceptable List C document | The particular record must contain a photograph. |
These are approved Form I-9 options. Accept any record that reasonably appears genuine and relates to the employee. If no acceptable List B document exists, use Step 2.
Under-18 I-9: Parent or Guardian Procedure
Use the parent or legal guardian procedure if the minor has no acceptable List B document. If the minor can use a school, clinic, or daycare record, follow the standard process and pair that document with a List C document.
This procedure establishes identity only. The minor must still present an acceptable List C document. E-Verify employers cannot use this procedure. This is especially critical when managing scalable event scheduling where compliance checks must be automated. Instead, the minor must present either a List A document or a photo-bearing List B document along with a List C document.
The parent or legal guardian completes Section 1 and Supplement A. In Section 1, use the minor’s personal and immigration-status information. In the employee signature field, enter:
“Individual under age 18”
Then complete Supplement A’s Preparer and/or Translator Certification.
If someone else helps prepare or translate Section 1, that person must complete a separate applicable certification in Supplement A.
In the List B document title field, enter:
“Individual under age 18”
Under List C, record the document title, issuing authority, document number, and expiration date, if any. Then enter the employment-start date, sign and date Section 2, and fill in the employer information fields.
Event staff under 18 follow the standard I-9 deadlines. The employee must complete Section 1 by the first day of work for pay. The employer or authorized representative must complete Section 2 within three business days after that day - or on the first day if employment lasts fewer than three business days. Apply this deadline to the employment period, not automatically to each event shift.
The employer that hires and pays the worker generally completes and keeps Form I-9. Using an authorized representative does not remove the employer’s responsibility for compliance.
Review original, acceptable documents unless an official exception permits otherwise. The documents must reasonably appear genuine and relate to the worker; you don’t need forensic expertise. Check expiration dates and any USCIS-recognized extensions, but don’t request extra documents or tell workers which documents to present.
Record each document’s title, issuing authority, number, and expiration date, if any. Before signing, compare those entries with the documents presented.
The same review standard applies in person and through an authorized remote process. Remote examination requires an eligible E-Verify employer following the DHS-authorized procedure, including live video review, retained document copies, and a notation on Form I-9. An emailed photo or simple video call alone is not enough.
A qualifying receipt for replacing a lost, stolen, or damaged document generally gives the worker 90 days from the first day of work for pay to present the replacement. Initial or renewal applications don’t automatically qualify, and other USCIS receipt categories follow separate rules. Receipts are not acceptable for employment lasting fewer than three business days.
When the replacement arrives, examine it and update Form I-9. Track the replacement deadline with the I-9 records; use scheduling tools for caterers to manage shift coverage while you review work permits and duty limits in Step 4.
Once Form I-9 is complete, check youth-employment rules as a separate step. State rules may be stricter than federal rules. Review federal, state, and applicable local requirements, and follow the strictest applicable rule before approving an assignment.
Check the worker’s age, school schedule, required work permits, breaks, and allowed hours. For ages 14–15, federal rules generally limit work to 3 hours on a school day, 18 hours in a school week, 8 hours on a nonschool day, or 40 hours in a nonschool week. Work must generally take place outside school hours, between 7:00 a.m. and 7:00 p.m. From June 1 through Labor Day, the evening limit extends to 9:00 p.m. Federal rules generally allow unlimited nonagricultural work hours for ages 16–17, but hazardous-work restrictions still apply.
Look at the actual tasks - not just the “event staff” title. Review setup, food service, cleanup, equipment use, alcohol service, and driving. Count setup and cleanup toward shift limits. Before assigning alcohol-related work or transportation, check restrictions tied to the worker’s age and the venue.
Consult U.S. Department of Labor youth-employment guidance and the relevant state labor agency. A required work permit does not replace acceptable I-9 documentation. Track the permit separately.
Use separate scheduling checklists for I-9 compliance and youth-work approval. The I-9 checklist tracks form and document deadlines. The youth-work checklist tracks permits, allowed tasks, shift limits, breaks, venue restrictions, and supervisor approval. Recheck youth-employment approval whenever duties, hours, or venues change.
Use Quickstaff to organize approved shifts, availability, reminders, communications, and event details. It does not handle I-9 verification or youth-employment review. Limit scheduling notes to approved tasks and shift restrictions; do not store Social Security numbers, passport numbers, or ID images in scheduling notes.
Confirm three things: the document path, the deadline, and the work assignment. The employee chooses an acceptable document set: List A or List B plus List C. For employees under 18, List B alternatives include school, medical, or childcare records, but List C is still required. The guardian procedure verifies identity - it does not approve an assignment. It applies only when no acceptable List B document exists and the employer does not use E-Verify.
After completing the I-9, check the deadlines. Confirm that Section 1 was completed by the first day of employment and Section 2 within three business days afterward. If employment lasts fewer than three business days, Section 2 must be completed on the first day.
Keep I-9 review separate from assignment approval. Check documents and form entries against current USCIS guidance, track receipt replacement deadlines, and approve work assignments separately under federal, state, and applicable local youth-employment rules.
No. A properly completed Form I-9 stays valid while the employee continues working for your company. You don’t need a new form for every event.
If you rehire an employee after a break in service, you can generally use Supplement B instead of completing a new Form I-9 - as long as you rehire them within three years of completing the original form.
No. You don’t need to update a minor’s Form I-9 when they turn 18. A properly completed form stays valid as long as the employee continues working for your company.
If the employee’s work authorization expires and requires reverification, use Supplement B instead of completing a new Form I-9.
No. A youth work permit does not qualify as List B identification for Form I-9. Keep work permit records for minor employees as required by labor regulations. To verify identity and employment eligibility, use the federal Lists of Acceptable Documents.
Employees choose which acceptable documents to present. Employers should not direct that choice.
