A minor filling out Form I-9 can substitute a school record, report card, clinic or hospital record, or daycare record for the driver’s license or state ID that adults typically use. That document goes in the List B (identity) slot and gets paired with a List C document — usually a birth certificate or an unrestricted Social Security card — to prove work authorization. A minor who holds a U.S. passport or passport card can use that one document by itself. Everything below explains when each option works, and where the rules tighten.
List B Identity Documents a Minor Can Use
Form I-9 asks for either one List A document (proving identity and work authorization together) or the combination of one List B document (identity) plus one List C document (work authorization).1U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 4.2 Minors (Individuals under Age 18) Most minors go the List B plus List C route because they don’t have a passport.
Federal regulations open up List B for anyone under 18. In addition to the standard adult IDs, a minor may present:2eCFR. 8 CFR 274a.2 – Verification of Identity and Employment Authorization
- A school record or report card from a public or private school.
- A clinic, doctor, or hospital record. This is often the easiest option for younger minors who don’t yet have much of a school paper trail.
- A daycare or nursery school record, which matters for very young workers such as child actors in states that permit their employment.
All of these must be originals. Photocopies, faxes, and scans are not acceptable for in-person verification. The employer looks at the document, confirms it appears genuine and relates to the minor, and records its details on the form.
A Native American tribal document also qualifies as a List B identity document, but only if issued by a federally recognized tribe. Recognition can be checked through the Department of the Interior’s Bureau of Indian Affairs, and documents from Canadian First Nations don’t count.3U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 7.2 Native Americans
The choice of which acceptable document to present belongs to the employee. An employer cannot demand a specific document or reject a valid one in favor of something they’d rather see; doing so can violate the anti-discrimination provisions of the Immigration and Nationality Act.4U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 14.0 Some Questions You May Have About Form I-9
The List C Document Is Still Required
Whatever List B document a minor uses, they still need a separate List C document proving employment authorization. Two options cover almost every U.S.-born minor:
- An original or certified copy of a birth certificate issued by a state, county, municipal authority, or U.S. territory, bearing an official seal.5U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 13.3 List C Documents That Establish Employment Authorization
- An unrestricted Social Security card. Cards printed with “NOT VALID FOR EMPLOYMENT” or “VALID FOR WORK ONLY WITH DHS AUTHORIZATION” do not work for this purpose.5U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 13.3 List C Documents That Establish Employment Authorization
The birth certificate is usually the simpler path. Most families already have one, and it never carries a restrictive legend the way a Social Security card sometimes does.
The Passport Shortcut
A minor with a valid U.S. passport or passport card can present that single document and skip the List B plus List C combination entirely. The passport is a List A document, satisfying identity and work authorization at once. For parents who anticipate the paperwork friction of a first job, obtaining a passport card in advance is often the cleanest fix.
When a Minor Has No List B Document at All
Sometimes a minor genuinely cannot produce any List B document. A homeschooled teen may have no school record on file; medical records may not be reachable in time. Federal rules include a workaround here that adults don’t get.6U.S. Citizenship and Immigration Services. Completing Form I-9 for Minors
A parent or legal guardian completes Section 1 with the minor’s information and writes “minor under age 18” in the signature field rather than having the minor sign. The parent then fills out the Preparer and/or Translator Certification on Supplement A. In Section 2, the employer writes “Individual under age 18” in the List B space.1U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 4.2 Minors (Individuals under Age 18)
The employer still has to record an actual List C document. Work authorization always requires a document, and no parent signature substitutes for it. So even under this procedure, the minor needs the birth certificate or unrestricted Social Security card.
E-Verify Changes the Answer
Every option above assumes the employer follows the standard I-9 process. Employers enrolled in E-Verify operate under a tighter rule: any List B document they accept must contain a photograph, and that requirement applies to minors too.7E-Verify. May I Accept a List B Identity Document Without a Photo if I Participate in E-Verify A paper report card or a medical record without a photograph will not satisfy the identity requirement for an E-Verify employer.
For a minor working at a business that uses E-Verify, the practical List B options shrink to documents that carry a picture: a state-issued ID card, a school ID with a photograph, or, in place of the whole combination, a U.S. passport or passport card. If a tribal document lacks a photo, the E-Verify employer must ask for a different List B document.3U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 7.2 Native Americans The “parent stands in” workaround also does not solve the E-Verify problem, because the underlying List B document itself needs a photo.
Before a minor’s first day at a chain restaurant, large retailer, or federal contractor, it’s worth asking whether the employer uses E-Verify. If yes, arranging a state ID or passport card in advance saves everyone real trouble. E-Verify also makes providing a Social Security number in Section 1 mandatory rather than voluntary.8U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 3.0 Completing Section 1 – Employee Information and Attestation
When the Documents Must Be Presented
Section 1 has to be completed no later than the minor’s first day of employment, meaning the actual start date, not the day the offer was accepted. It can be done earlier, but only after the job offer is accepted.9U.S. Citizenship and Immigration Services. Instructions for Form I-9, Employment Eligibility Verification
Original, unexpired documents must be presented to the employer within three business days after the first day of employment. If the minor starts on Monday, documents are due by Thursday. For jobs lasting fewer than three business days, documents must be presented on the first day.9U.S. Citizenship and Immigration Services. Instructions for Form I-9, Employment Eligibility Verification Photocopies, faxes, and digital images aren’t accepted for standard in-person examination. Employers using the authorized alternative remote procedure can review documents over live video but must retain clear copies of both sides.10U.S. Citizenship and Immigration Services. Remote Examination of Documents (Optional Alternative Procedure to Physical Document Examination)
Use the current edition of the form (01/20/2025) downloaded from the USCIS website. Using an outdated edition is itself a violation.11U.S. Citizenship and Immigration Services. I-9, Employment Eligibility Verification
Age Certificates and State Work Permits Are Separate
An age certificate is not a Form I-9 document and cannot substitute for anything on List A, B, or C. It serves a different purpose under the Fair Labor Standards Act: an employer who keeps a valid age certificate on file has protection against unintentional child labor violations, because the certificate shows the employer verified the minor’s age before assigning work.12eCFR. 29 CFR 570.121 – Age Certificates
Most states issue age certificates through their labor department or local schools. There is no federal application process. Many states also require their own work permits before a minor can begin employment, and where state child labor laws are stricter than federal law, the stricter standard controls. Fees are typically modest, from nothing to around $50 depending on the state. Check with your state labor department, because both the paperwork and the age thresholds vary.