Summer hiring season is here, and thousands of New Jersey employers are bringing on teen workers — often without realizing that hiring minors in New Jersey now comes with one of the strictest compliance frameworks in the country. In 2023, the state overhauled the entire “working papers” system and shifted the legal burden onto employers in ways most business owners still don’t fully understand.
The penalties for getting it wrong aren’t small. Violations can stack per day, per minor, and per offense — and a single injured teen on a job site without proper paperwork can trigger double workers’ compensation benefits paid directly out of the employer’s pocket, not their insurance carrier’s.
Here’s what every New Jersey employer needs to know before hiring their next minor — and where most businesses get into trouble.
The Rules Changed. Most Employers Haven’t Caught Up
Every minor under 18 who works in New Jersey is required to have working papers — formally called an employment certificate — before starting any job. This has been true for decades. But the process has changed dramatically.
As of 2023, New Jersey moved the entire system to a state-run online platform. Schools are no longer involved. Instead, minors, caregivers, and employers all interact directly with the New Jersey Department of Labor and Workforce Development through an online portal. Employers are now required to register, obtain a unique identification code, and manage their role in the application process themselves — a role that used to be handled by school officials.
This is where most employers run into problems. The new system requires specific steps in a specific order, with email confirmations and approval gates that can’t be skipped. A misstep anywhere in the chain means the minor cannot legally start work — and if they do, the employer is on the hook.
A new application is also required each time a minor changes employers, changes job duties, or returns for a new season. The one-and-done approach many employers assume applies here does not.
Age Tiers: The Basics
New Jersey sets permitted work by age, and the rules get surprisingly granular. The short version:
- Under 14: Very limited — primarily newspaper delivery and narrow agricultural roles, each with their own permit requirements.
- 14 and 15: A wider range of jobs opens up, but with the tightest hour restrictions and the longest list of prohibited tasks.
- 16 and 17: Most non-hazardous jobs are permitted, including some that involve power equipment — but the rules around what they can and cannot touch are highly specific and vary by industry.
- 18+: Legally adults, though age certificates may still be requested for certain roles.
The trouble is that the official permitted-occupation lists are not comprehensive, and the prohibited-occupation lists carry narrow, industry-specific exceptions that trip up even experienced HR staff. A 16-year-old can work in a restaurant that serves alcohol — but only in certain roles, under certain conditions, and never in others. A 15-year-old can use some machines but not others that look nearly identical. Getting this right requires knowing the specific statute that applies to your industry.
Hour and Break Restrictions
There are daily caps, weekly caps, consecutive-day caps, school-year rules, summer rules, and night-work restrictions — and they shift based on the minor’s age, the type of business, and even the time of year. Restaurants, seasonal amusements, and bowling alleys all have their own carve-outs.
One rule that applies across the board: any minor working more than 6 consecutive hours is entitled to an uninterrupted 30-minute meal break. Shorter breaks do not reset the clock.
Beyond that, the specifics matter enormously — and misreading them is one of the most common sources of violations.
Prohibited and Hazardous Occupations
New Jersey prohibits minors under 18 from a long list of hazardous jobs, and the list is more expansive than federal law requires. Toxic substance exposure, most power-driven machinery, certain elevators and hoisting equipment, alcohol-related establishments, demolition work, aircraft fueling, pool and billiard rooms, and a number of others are all restricted — often with narrow exceptions that require careful reading.
Workers under 16 face an even tighter restricted list. Many employers assume that if a machine is in their workplace and an adult uses it safely, a minor can too. That assumption is often wrong and often costly.
Wages, Benefits, and Worker’s Compensation
Minors are generally entitled to the state minimum wage, must be paid at least twice per month with detailed pay stubs, and accrue earned sick leave at the same rate as adult workers. Overtime rules for 16- and 17-year-olds have specific exemptions that depend on the job type.
The most important thing employers should understand: workers’ compensation coverage applies to minors regardless of whether they were legally employed. If a minor is injured while working without proper papers, or in a prohibited occupation, the employer may owe double the standard workers’ comp benefits — paid personally, not by the insurance carrier — and the minor retains the right to sue in Superior Court on top of that.
This single exposure point is why child labor compliance is a far bigger risk than most small businesses realize.
Penalties
New Jersey’s administrative penalty schedule runs into the thousands per violation, with each day counting as a separate offense and each minor employed in violation counting separately as well. Federal court penalties under the Fair Labor Standards Act go higher still. For a business with multiple teen employees and a few paperwork gaps, the exposure can compound quickly.
Frequently Asked Questions
Do I really need to register as an employer just to hire one teen for the summer?
Yes — and the registration process has specific requirements that must be completed before your minor employee can even begin their own application. The order of operations matters. We help clients walk through this correctly the first time.
What jobs can a 14- or 15-year-old legally do in my business?
That depends heavily on your industry, the specific equipment in your workplace, and the tasks involved. The official permitted lists are not exhaustive, and the exceptions are narrow. This is one of the most common questions we help clients answer based on their specific operations.
Can my 16-year-old employee work late hours during the summer?
There are expanded hour allowances in the summer window, but they vary based on the type of business, whether the minor has written parental permission, and whether school is in session. The specifics are where most violations occur.
What happens if a teen gets hurt and I didn’t get the paperwork right?
The employer — not the insurance carrier — can be held personally liable for double the standard workers’ compensation benefits, and the minor can pursue an additional civil suit. This is the single biggest financial risk of non-compliance, and it’s why we strongly recommend a compliance review before any minor starts work.
Are there exceptions for family businesses or short-term seasonal work?
Some narrow exceptions exist, but they are more limited than most business owners assume — and misreading them is a common cause of violations. If you’re considering hiring a family member or running a short-term seasonal operation, this is worth a conversation before you start.
Marzano Human Resources Consulting
If you’re bringing on minors this season — or if you’ve already hired some and want to make sure you’re on solid ground — contact our office.