Youth Work Permit and Employment Protection Act of 2025

OFFICE OF COUNCILMEMBER ANITA BONDS
CHAIR, COMMITTEE ON EXECUTIVE ADMINISTRATION AND
LABOR THE JOHN A. WILSON BUILDING
1350 PENNSYLVANIA AVENUE, NW
WASHINGTON, DC 20004
October 9, 2025

Nyasha Howard, Secretary
Council of the District of Columbia
1350 Pennsylvania Avenue, N.W.
Washington, DC 20004

Dear Secretary Howard,

Today, I am introducing the “Youth Work Permit and Employment Protection Act of
2025”, along with my colleague Councilmember Matthew Frumin. Please find enclosed a signed copy
of the legislation. Additionally, I am requesting that this bill be referred to the Committee on Executive
Administration and Labor due to its oversight of the Department of Employment Services and its
jurisdiction over Title 32 of the D.C. Code.

Nationwide, illegal child labor is on the rise. According to the US Department of Labor, the
number of minors found to be employed in violation of child labor laws has increased by over 315%
over the last decade, from 1,393 minors in Fiscal Year 2013 to 5,792 minors in Fiscal Year 2023.1
Unfortunately, the challenge of estimating how many violations go unreported means that the true
extent of illegal child labor is likely much worse. At the same time, state legislatures across the nation
have taken action to roll back laws that restrict child labor and protect children from harmful labor
practices. In just 2022 and 2023, at least 11 states introduced legislation that weakens protections for
employed minors.2, 3 In several states, policymakers have enacted laws that extend working hours for
minors, lift restrictions on certain occupations, and remove requirements for work permits and age
verification.
Against the backdrop of this national debate on child labor policy, and the increasing
prevalence of illegal child labor, the District must take a close look at its own laws governing the
employment of minors. D.C. Code 32-201 to 32-224,4 also known as “An Act to regulate the
employment of minors within the District of Columbia”, prohibits minors under 14 from gainful
employment. Alongside other protections for employed minors, it requires special ‘youth work
permits’, restricts the hours and occupations for employed minors, sets special rules for minors
employed in special occupations, and establishes penalties for violations. Unfortunately, this part of
the Code has not been substantially amended since 1976 (and largely remains unchanged since it was
originally enacted by Congress in 1928), resulting in serious problems that completely undermine the
law’s strong protections against harmful labor practices.

1 US Department of Labor Wage and Hour Division, WHD by the Numbers 2022 “Child Labor,”
https://www.dol.gov/agencies/whd/data/charts/child-labor.
2 Jennifer Sherer and Nina Mast, Child labor laws are under attack in states across the country (Washington D.C.:
Economic Policy Institute, 2023), 6-7.
3 Forrest Saunders, “Could Florida become next state to loosen child labor laws?”
4 https://code.dccouncil.gov/us/dc/council/code/titles/32/chapters/2/subchapters/I

Most disturbing among the current law’s many problems is that there is no existing
District agency charged with monitoring, implementing, and enforcing our child labor
protections. The law places responsibility on the ‘Board of Education’, an independent agency that
existed prior to Mayoral control of the District’s school system in 2007. Since then, the District’s
school system (including DC Public Schools and DC Public Charter Schools) has continued to
issue ‘youth work permits’, but implementation has been fractured and inconsistent in the absence
of a clear legal framework and centralized oversight. Importantly, there is no clear legal mandate
for a District agency to investigate child labor violations, assess penalties against employers, or
conduct public education on the law’s requirements.

This proposed bill will modernize the District’s child labor law by re-writing its provisions
in plain, clear language, in -line with our modern legislative drafting conventions. It places
responsibility for implementing and enforcing the law with the Department of Employment
Services (DOES), the District’s lead labor agency. DOES is well-equipped to oversee the
issuance of ‘youth work permits’, maintain records on youth employment, conduct public
education campaigns, investigate violations, and assess administrative penalties against employers
who illegally employ minors. The proposed bill also clarifies the Office of the Attorney General’s
role to act in the public interest by bringing civil suits against employers who violate the law, in -
line with their role in enforcing other labor protections in District law.
Importantly, this proposed legislation does not seek to permanently address all
policy questions related to child labor; rather, it will establish a functioning framework for
the District to fully implement our protections for employed minors, allowing future
policymakers to continually update and improve the law. However, I look forward to
receiving feedback from experts and stakeholders during the legislative process so that we may
incorporate their recommendations for best practices.

It’s time for the District to reaffirm our strong commitment to protecting our children
from harmful employment practices. Each year, we make significant investments into our
children’s education, skills training, and career readiness; it is essential that we ensure these
investments are complemented with a well-regulated and transparent system governing their
employment. I strongly urge all my Council colleagues to support me in taking quick action to
correct this serious lapse in our law, so that the District may proudly guarantee a safe working
environment for our employed minors.

Thank you,

Anita Bonds

1
_________________________ ______________________ 2
Councilmember Matthew Frumin Councilmember Anita Bonds 3
4
5
A BILL 6
_______________ 7
8
IN THE COUNCIL OF THE DISTRICT OF COLUMBIA 9
____________________________ 10
11
12
To prohibit the employment of minors younger than 14 years of age, to regulate the hours of 13
employment of minors between the ages of 14 and 17, to require that employers post 14
notice of the regulations for employment of minors, to prohibit the employment of minors 15
in occupations deemed dangerous, to provide for the Mayor to issue rules identifying 16
certain places of employment and occupations deemed dangerous, to require the Mayor 17
to hold public hearings prior to issuing rules identifying certain places of employment 18
and occupations deemed dangerous, to require that employers procure a work permit or 19
special occupation permit for each minor employed, to require the Department of 20
Employment Services to issue work permits and special occupation permits to minors, to 21
require that the department of Employment Services maintain records of issued permits, 22
to regulate the employment of minors in special occupations, to require that employers 23
provide the Department of Employment Services with proof of an employee’s age upon 24
demand, to require that the Department of Employment Services enforce this act and 25
assess administrative penalties, to provide for the Department of Employment Services to 26
inspect workplaces where minors are employed, to provide for the Department of 27
Employment Services to revoke a minor’s work permit, to provide for the Attorney 28
General to bring civil actions under this act, and to repeal An Act to regulate the 29
employment of minors within the District of Columbia. 30
31
BE IT ENACTED BY THE COUNCIL OF THE DISTRICT OF COLUMBIA, That this 32
act may be cited as the “Youth Work Permit and Employment Protection Act of 2025”. 33
Sec. 2. Definitions. 34
For the purposes of this act, the term: 35
(1) “Employ” means to suffer or permit to work for renumeration. 36
(2) “Employable minor” means a minor who is at least 14 years of age. 37
(3) “Employer” means an individual, firm, association, or corporation that 38
employs another individual in the District, except that the term employer shall not include the 39
District government or the federal government. 40
(4) “Infant” means an individual younger than 12 months of age. 41
(5) “Minor” means an individual younger than 18 years of age. 42
(6) “Department” means the Department of Employment Services. 43
(7) “Special occupation” means: 44
(A) Performance on the stage of a licensed theater within the District in a 45
professional theatrical production; 46
(B) Performance in a musical or dance recital or concert; 47
(C) Participation in a radio or television program; 48
(D) Participation in a motion picture, video, or other media production; or 49
(E) Participation in a circus. 50
(8) “In session” means any week when the District of Columbia Public School 51
systems hold regular, non-summer school classes. 52
Sec. 3. Employment of minors. 53
(a) A minor younger than 14 years of age shall not be employed in the District, except in: 54
(1) Irregular or casual work usual to the home of an employer such as babysitting; 55
(2) Work for a business owned solely by the minor’s parent or guardian; provided 56
that such employment shall not be specifically prohibited by a provision of this act or by a 57
regulation promulgated pursuant to this act or by a federal law or regulation. 58
(b) A minor who is 14 or 15 years of age shall not be employed: 59
(1) For more than: 60
(A) 3 hours on a school day, including Fridays; 61
(B) 8 hours on a non-school day; or 62
(C) 18 hours in any one week when school is in session; 63
(D) 40 hours in any one week when school is not in session; and 64
(2) Before 7:00 a.m. or after 7:00 p.m. of any day, provided, that between June 1 65
and Labor Day when school is not in session, a minor 14 or 15 years of age may be employed 66
until 9:00 p.m. 67
(c) A minor who is 16 or 17 years of age shall not be employed: 68
(1) For more than: 69
(A) 6 consecutive days in any one week; 70
(B) 48 hours in any one week; or 71
(C) 8 hours in any one day; and 72
(2) Before 6:00 a.m. or after 11:30 p.m. of any day. 73
(d) An employable minor shall not be employed during school hours, unless the 74
employable minor is engaged in approved work study programming, has been excused from 75
further attendance at school, or is allowed flexible study school hours pursuant to Article II, 76
section I of An Act To provide for compulsory school attendance, for the taking of a school 77
census in the District of Columbia, and for other purposes, approved February 4, 1925 (43 Stat. 78
806; D.C. Official Code § 38-202). 79
(e) The provisions of this subsection shall not apply to an employable minor with a valid 80
special occupation permit issued pursuant to section 9. 81
Sec. 4. Notice and recordkeeping. 82
(a)(1) An employer who employs a minor, other than pursuant to section 3(a) shall keep a 83
notice of the requirements of this act, and of any regulation promulgated by the Mayor pursuant 84
to section 13, posted in a conspicuous and accessible place in or about the premises at which the 85
minor is employed. 86
(2) The Department shall provide the notice required pursuant to paragraph (1) of 87
this subsection to an employer upon request, and shall include at minimum the following 88
information: 89
(A) The hours of work for minors as provided in section 3; 90
(B) The occupations prohibited to minors under federal and District law or 91
regulations; and 92
(C) The minimum wages for minors. 93
(b) An employer who employs a minor, other than pursuant to section 3(a) shall keep a 94
list of all minors employed, and an accurate time record showing the hours each minor began and 95
ended work each day, accessible in the place of employment. 96
Sec. 5. Employment dangerous or prejudicial to life prohibited; Mayor to hold public 97
hearing. 98
(a) A minor shall not be employed in a place of employment or in an occupation that the 99
U.S. Secretary of Labor, pursuant to the Fair Labor Standards Act, approved June 25, 1938 (29 100
U.S.C. § 201 et seq.), or the mayor pursuant to rulemaking, has determined is dangerous or 101
prejudicial to the life, health, safety, or welfare of minors. 102
(b) An employable minor shall not be employed in operating a freight or nonautomatic 103
elevator, or in a quarry, tunnel, or excavation. 104
(c) An employable minor younger than 16 years of age shall not be employed in any of 105
the following occupations: 106
(1) In the operation of machinery operated by power other than hand or foot 107
power; or 108
(2) In or assisting in oiling, wiping, or cleaning machinery. 109
(d) Subsection (c) of this section shall not apply to a vocational education program or 110
training administered or otherwise approved by the Mayor. 111
(e) The Mayor, pursuant to Title I of the District of Columbia Administrative Procedure 112
Act, approved October 21, 1968 (82 Stat. 1204; D.C. Official Code § 2-501 et seq.), shall issue 113
rules identifying places of employment and occupations deemed dangerous or prejudicial to the 114
life, health, safety, or welfare of minors. In addition to the requirements of the District of 115
Columbia Administrative Procedure Act, approved October 21, 1968 (82 Stat. 1204; D.C. 116
Official Code § 2-501 et seq.), before adopting or repealing a rule authorized pursuant to this 117
subsection, the Mayor shall hold at least one public hearing on the proposed rule or repeal. 118
Sec. 7. Work permit- application. 119
(a) The Department shall develop and maintain an online system through which minors 120
may access a work permit or special occupation permit application that can be signed and 121
submitted to an employer with proof of age. 122
(b) Acceptable proof of a minor’s age includes: 123
(1) A birth certificate, attested transcript issued by a registrar of vital statistics or 124
other officer charged with the duty of recording births, or valid passport; 125
(2) A record of age as given in the records of the school first attended by the 126
minor, if obtainable, or in the earliest available school census; 127
(3) A baptismal record or duly certified transcript thereof showing the date of 128
birth and place of baptism of the minor; or 129
(4) Other documentary evidence determined acceptable by the Department. 130
Sec. 8. Work permit required. 131
(a) Except for minors employer pursuant to section 3(a), no employable minor may be 132
employed unless the employer procures a work permit or special occupation permit pursuant to 133
this act. 134
(b) The work permit or special occupation permit required by this act shall include the 135
following: 136
(1) The minor’s name, date of birth, place of birth, place of residence, grade last 137
completed, the evidence the employer accepted as proof of the minor’s age, and any other details 138
necessary for the identification of the minor; 139
(2) The name and address of the employer for whom the work permit or special 140
occupation permit authorizes the minor to be employed, 141
(3) The nature of the specific occupation in which the minor will be employed; 142
(4) A unique number assigned to the work permit or special occupation permit, 143
and the date of its issue; and 144
(5) The signature of the employer. 145
(c)(1) Each work permit shall be signed by the minor, if the minor is 16 years of age or 146
older. If the minor is under 16 years of age, the permit shall be signed by the minor, age 147
permitting, and the minor’s parent or legal guardian. 148
(2) All special occupation permits issued pursuant to section 9 of this section shall 149
be signed by the minor, age permitting, and the parent or guardian, and agent if applicable, of the 150
minor for whom it is issued. 151
(d)(1) For each minor employed, the employer shall maintain a record containing a copy 152
of the signed permit and a copy of any application materials, including the evidence of age, at the 153
place of employment. Such permit shall be accessible to an inspector or other person authorized 154
to enforce this act. 155
(2) An employer shall submit the appropriate signed permits to the Department 156
within 14 days after the first day of employing a minor. 157
(3) The Department shall maintain a record of all submitted permits and annually, 158
between June 1 and July 1, conduct an audit of all work permits and special occupation permits 159
submitted by employers in the previous year. 160
(e) A work permit or special occupation permit shall only be valid for the employer and 161
specific occupation designated on the permit. 162
Sec. 9. Special occupation permits for minors employed in special occupations. 163
(a) A minor may be employed in a special occupation; provided that the employer 164
procures a special occupation permit, which shall comports with the requirements of this section 165
and section 7 and 8, except as provided in this section. 166
(b) An application for special occupation permit shall be made by the parent or guardian, 167
and by the agent or employer if applicable, of the minor to the Department. The Department shall 168
only issue a special occupation permit if the Department is satisfied that adequate provisions 169
have been made for the educational instruction of the minor, for safeguarding the minor’s health, 170
and for the proper supervision of the minor. The Department may require the employer to 171
provide the necessary resources to satisfy the requirements of this subsection. 172
(c) A minor shall not appear in more than 2 live performances in connection with a 173
special occupation in one day, or more than 8 performances in one week. A minor shall not 174
appear in a live performance or otherwise be required to work in connection with a special 175
occupation before 7:00 a.m. or after 11:30 p.m. 176
(d) A licensed practical nurse with substantial pediatric experience, or a pediatric nurse 177
practitioner, shall be provided for each 3 or fewer infants younger than the age of 30 months. 178
(e) Within any 24-hour period, the time during which a minor 7 years of age or younger 179
is permitted at the place of employment in a special occupation shall be limited as follows: 180
(1) An infant younger than the age of 6 months shall not remain at the place of 181
employment for more than 3 hours, which shall consist of not more than 20 minutes of work. 182
(2) A minor between the ages of 6 months and 30 months shall not remain at the 183
place of employment for more than 4 hours, which shall consist of not more than 2 hours of 184
work, with the balance of the 4-hour period being rest or recreation. 185
(3) A minor between the ages of 30 months and 7 years shall not remain at the 186
place of employment for more than 6 hours, which shall consist of not more than 3 hours of 187
work, with the balance of the 6-hour period being rest, recreation, or education. 188
Sec. 10. Employer to furnish, on demand, proof of age of an employee. 189
(a) Upon reasonable suspicion that an employee is a minor for whom a work permit is not 190
on file, the Department may issue a written notice to the employee’s employer requesting proof 191
of the employee’s age, consistent with section 7(b). 192
(b) The notice shall be served on the employer by personal service to the employer or 193
employer’s representative, or by certified mail. 194
(c) If the employer does not provide proof the employee’s age within 10 days after 195
receiving notice, the employer shall cease employing the employee until the Department receives 196
proof of the employee’s age. 197
Sec. 11. Penalties, enforcement, and prosecutions. 198
(a)(1) The Department shall administer and enforce the provisions of the act, including by 199
conducting sua sponte and complaint-initiated investigations into whether violations have 200
occurred, holding hearings, and instituting actions for penalties. 201
(2)(A) The Department, its inspectors, and other person authorized to enforce this 202
act may visit and inspect, at any time, all places where minors are reasonably believed to be 203
employed, and shall have authority to enter any place or establishment covered by the terms of 204
this act for the purposes of enforcing this act. 205
(B) The Department, its inspectors, and any other person authorized to 206
enforce this act shall have access to any records necessary to enforce this act upon demand; 207
provided, that an employer or individual may not be found to be in violation of this subparagraph 208
unless the employer had an opportunity to challenge the demand before a judge, including an 209
administrative law judge. 210
(b)(1)(A) The Department shall assess an administrative penalty against an employer or 211
individual who: 212
(i) Employs a minor in violation of this act, or of a regulation 213
promulgated pursuant to this act; 214
(ii) Interferes with the Department, its employees, or any other 215
person authorized by the District to inspect places of employment of minors; or 216
(iii) Otherwise violates the provisions of this act. 217
(B) Each day during which a violation of this act occurs or continues to 218
occur shall constitute a separate violation. 219
(2)(A) The administrative penalty assessed pursuant to this subsection shall not 220
exceed $1,000 for each violation of this act; provided, that the Department shall assess an 221
administrative penalty not to exceed $10,000 for each violation of this act that results in the 222
employment of a minor who is injured or dies in the course of that employment. 223
(B) The Department may not collect an administrative penalty under this 224
subsection unless the Department has provided the employer or individual alleged to have 225
violated this act notification of the violation, notification of the amount of the administrative 226
penalty to be imposed, and an opportunity to request a formal hearing held pursuant to the 227
Administrative Procedure Act, approved October 21, 1968 (82 Stat. 1204; D.C. Official Code § 228
2-501 et seq.). 229
(c)(1) If a minor is employed in violation of any of the provisions of this act, or of any 230
regulation promulgated by the Mayor pursuant to this act, the Department shall revoke the 231
minor’s work permit or special occupation permit, and shall order the minor’s employer to 232
immediately cease employing the minor. 233
(2) If the minor is younger than 16 years of age, the Department shall notify the 234
minor’s parent, guardian, or custodian. 235
(d) The Attorney General, acting in the public interest, including the need to deter future 236
violations, may bring a civil action in a court of competent jurisdiction against an employer or 237
other individual violating this act. Upon prevailing in court, the Attorney General shall be 238
entitled to reasonable attorney’s fees and costs, and statutory penalties equal to any 239
administrative penalties provided by law. 240
Sec. 12. Rules. 241
The Mayor, pursuant to Title I of the District of Columbia Administrative Procedure Act, 242
approved October 21, 1968 (82 Stat. 1204; D.C. Official Code § 2-501 et seq.), shall issue rules 243
to implement the provisions of this act. 244
Sec. 13. An Act to regulate the employment of minors within the District of Columbia, 245
Approved May 29, 1928 (45 Stat. 998; D.C. Official Code § 32-201 et seq.), is repealed. 246
Sec. 14. Fiscal impact statement. 247
The Council adopts the fiscal impact statement in the committee report as the fiscal 248
impact statement required by section 4a of the General Legislative Procedures Act of 1975, 249
approved October 16, 2006 (120 Stat. 2038; D.C. Official Code § 1-301.47a). 250
Sec. 15. Effective date. 251
This act shall take effect following approval by the Mayor (or in the event of veto by the 252
Mayor. Action by the Council to override the veto), and a 30-day period of congressional review 253
as provided in section 602(c)(1) of the District of Columbia Home Rule Act, approved December 254
24, 1973 (87 Stat. 813; D.C. Official Code § 1-206.02(c)(1)). 255