Form I-9 for Minors: Hiring Employees Under 18

Hiring teenagers for summer jobs, restaurants, retail stores, or other entry-level roles creates a common onboarding question: How do you complete Form I-9 when a new employee does not have a driver's license or other standard identity document?

Employees under 18 generally have the same Form I-9 requirement as adult employees. However, federal rules provide additional identity-document options and, in certain circumstances, a special parent or legal guardian procedure. Employers using E-Verify face an important limitation on those alternatives.

Here is how to build an onboarding process that accommodates younger workers without requesting unnecessary documents or overlooking verification requirements.

Do minors need to complete Form I-9?

Yes. Being under 18 does not exempt an employee from Form I-9 requirements. An employer generally must complete the form for each person hired to perform work in the United States for wages or other remuneration, subject to the usual exceptions.

The standard timing rules apply:

• Section 1: The employee must complete it no later than the first day of employment for pay. It may be completed earlier after the employee accepts the job offer.
• Section 2: The employer must complete it within three business days after that first day.
• Very short assignments: If employment will last fewer than three business days, Section 2 must be completed no later than the first day of employment.

Do not assume a school vacation, seasonal assignment, or parent's availability extends these deadlines.

What I-9 documents can an employee under 18 present?

Start with the normal document framework. An employee may present either:

• One acceptable List A document or document combination establishing identity and employment authorization; or
• One acceptable List B identity document plus one acceptable List C employment authorization document.

For example, an unexpired U.S. passport is a List A document. A minor who presents one does not also need a driver's license, Social Security card, or parent-signed identity statement.

Employees choose which acceptable documents to present. Give every new hire the complete Lists of Acceptable Documents rather than a shortened list of documents your managers prefer.

Additional List B options for minors

An individual under 18 who cannot present a standard List B document may use certain additional identity documents:

• A school record or report card;
• A clinic, doctor, or hospital record; or
• A day-care or nursery school record.

These are identity documents, not proof of employment authorization. An employee using one still needs an acceptable List C document.

A school ID card with a photograph is already a standard List B option. Do not confuse that option with the special school-record or report-card provision for minors.

List C is still required

The additional identity options do not eliminate the employment authorization requirement. Examples of List C documents include an unrestricted Social Security card or a qualifying original or certified copy of a U.S. birth certificate.

A Social Security card bearing a restrictive legend, such as “VALID FOR WORK ONLY WITH DHS AUTHORIZATION,” is not an acceptable List C document. The employee must choose another acceptable document or document combination; the employer should not prescribe which one.

Use the current USCIS Lists of Acceptable Documents to evaluate the document actually presented.

What if the minor cannot present an identity document?

USCIS provides a special procedure for employees under 18 who cannot present a List B identity document. This procedure involves a parent or legal guardian and does not waive the need for a List C document.

Under the procedure:

1. The parent or legal guardian completes Section 1 with the minor's information and enters “Individual under age 18” in the employee signature field.
2. The parent or legal guardian completes the preparer and/or translator certification. On the current Form I-9, that certification is in Supplement A.
3. The employer enters “Individual under age 18” under List B in Section 2, in the document title field.
4. The employer examines and records the employee's List C document and completes the employer certification.

Follow the current USCIS Handbook for Employers rather than improvising entries in an electronic system.

This is a specific alternative procedure—not a requirement that every employee under 18 have a parent sign. A minor who can complete Section 1 and present acceptable documents can follow the ordinary process. If someone merely helps prepare or translate the form, apply the regular preparer or translator requirements.

How does E-Verify change the rules for minors?

E-Verify employers must use a List B document containing a photograph when an employee presents List B and List C documents. This requirement also applies to employees under 18.

Consequently, an E-Verify employer cannot rely on a non-photo report card or the parent or guardian identity procedure described above as a substitute for the required photographic List B document.

A school ID with a photograph can be an acceptable List B choice. An acceptable List A document is another possible route, chosen by the employee.

If a minor cannot present documents that satisfy the applicable requirements, escalate the issue promptly to your compliance lead and consult current USCIS and E-Verify guidance. Do not invent an identity document entry or treat a parent's identification as the employee's document.

For employers hiring across multiple locations, managed Form I-9 and E-Verify support can help managers follow a consistent process instead of making separate judgment calls at each worksite.

Keep work permits separate from I-9 verification

A state employment certificate or youth work permit serves a different purpose from Form I-9. It is not automatically an acceptable I-9 document simply because a school or government agency issued it.

Likewise, completing Form I-9 does not establish that a minor may legally perform every assigned task or work any proposed schedule.

Federal and state child labor rules can restrict hours, occupations, equipment use, and other conditions. Confirm current requirements for the worker's age, duties, and location through the relevant labor agencies. Track any required youth employment paperwork separately from the I-9 document-selection process.

A practical checklist for high-volume employers

Before your next wave of teenage hiring:

• Provide clear advance instructions. Share the complete acceptable-document lists after an offer is accepted.
• Explain the E-Verify distinction. Managers need to know whether photographic List B identification is required.
• Train for both paths. Distinguish ordinary completion with acceptable documents from the special parent or guardian procedure.
• Check your software. Confirm that it supports the appropriate minor-related entries and Supplement A when applicable.
• Escalate early. Route unusual document situations to a designated compliance resource before deadlines pass.
• Avoid document demands. Do not require every teenager to bring a birth certificate, Social Security card, or parent.

This article provides practical information, not legal advice. Confirm current agency instructions and seek qualified guidance for unusual circumstances.

Need a consistent onboarding process for employees of every age? Contact Trak Services to discuss Form I-9 verification and E-Verify support.