Onboarding Holiday Seasonal Hires in the US: Forms, Rules and Timing
Holiday hiring in the US runs to a tight calendar. Thanksgiving falls on November 26 this year, so most seasonal staff start in the week before it or on Black Friday itself. Every one of them needs the same federal paperwork as a permanent employee, plus whatever their state adds, and the deadlines don't stretch because the job ends in January.
This post covers the rules that catch seasonal hires: I-9 timing, W-4 and state withholding, E-Verify, minors and work permits, what "seasonal" actually changes, and state sick leave. Then it shows how to collect the lot before the first shift.
Form I-9 has no seasonal exemption
Every employee hired after November 6, 1986 needs a Form I-9, however short the job. The deadlines are the same as for anyone else (Form I-9 instructions):
| Step | Who | Deadline |
|---|---|---|
| Section 1 | The employee | No later than their first day of employment, and not before they accept the offer |
| Section 2 | You | Within 3 business days after their first day of work for pay |
| Section 2, job under 3 business days | You | By the end of their first day of work |
Someone who starts on Black Friday, November 27, needs Section 2 done by Wednesday, December 2. For Section 2 you examine their original documents in person, unless you use E-Verify and the alternative procedure for remote examination. With twenty people starting in one week, book the time to do it, because this is the step that slips. More detail is in our Form I-9 guide.
Returning seasonal staff
Someone who comes back each year may not need a new form at all. USCIS treats a seasonal worker on a seasonal layoff with a reasonable expectation of returning as continuing in employment, not a new hire. Whether that expectation exists depends on things like your history of recalling staff and whether the job was filled by someone else.
If they did leave, and you rehire them within 3 years of the date their previous Form I-9 was completed, you can either complete a new form or complete Supplement B on the old one. After 3 years, they need a new Form I-9.
Form W-4 and state withholding
Short-term workers are treated the same as full-time employees for federal income tax withholding, Social Security, Medicare and FUTA. IRS Publication 15 says to ask every new employee for a signed Form W-4 when they start. If they don't give you one, withhold as if they checked Single or Married filing separately and made no other entries. For someone who works only part of the year, Publication 15 also allows the part-year employment method in section 6 of Pub. 15-T.
Students working a holiday job often claim exemption from withholding. Under the same publication, an exempt W-4 is effective only for the calendar year it is given in. To stay exempt, they give you a new one by February 15. A student who claims exempt in November 2026 and keeps working into the new year needs a fresh W-4 by February 15, 2027, or you start withholding.
Most states with an income tax have their own certificate as well, such as California's DE 4 or New York's IT-2104. The new hire paperwork checklist has more on these.
E-Verify, where you use it
E-Verify is voluntary for most private employers but required by some states, Arizona and South Carolina among them, and for federal contractors with the FAR clause. If you use it, the seasonal hire gets a case like anyone else, created no later than the third business day after they start work for pay. The Form I-9 guide has a table of state rules.
Minors and work permits
Holiday retail and hospitality hire a lot of teenagers. Federal law under the FLSA limits 14 and 15 year olds to work outside school hours, and to:
- 3 hours on a school day, including Fridays, and 18 hours in a school week
- 8 hours on a non-school day, and 40 hours in a non-school week
- between 7 a.m. and 7 p.m. (9 p.m. only from June 1 through Labor Day, so not in the holiday season)
Federal law sets no hours limits for 16 and 17 year olds. Where a state's rule is stricter, the stricter rule applies.
Many states also require a work permit, which the federal government calls an employment certificate. A few examples:
| State | What you need |
|---|---|
| California | A Permit to Employ and Work (Form B1-4), issued by the school after the minor, a parent and you complete Form B1-1. You keep it on file. It expires five days after the next school year opens. |
| New York | Working papers for anyone under 18, issued by the school. The state says a new digital process, with employer accounts, starts in 2027. |
| Pennsylvania, Illinois | An employment certificate from the school: under 18 in Pennsylvania, under 16 in Illinois. |
| Texas, Florida | No employment certificate. The state issues an age certificate on request. |
The Pennsylvania, Illinois, Texas and Florida rows come from the Department of Labor's state table, last revised January 1, 2024. Check with your state labor department before you rely on it.
Seasonal, temporary or part-time: what changes
For withholding, the I-9 and the minimum wage, nothing. The label matters in a few specific places.
- Health coverage under the ACA. The IRS uses two different terms. A "seasonal employee" is hired into a job whose customary annual employment is six months or less, starting at about the same time each year. That matters for the look-back measurement method. A "seasonal worker", which includes retail workers employed only during holiday seasons, matters when you count whether you have 50 or more full-time employees.
- The coverage options notice. You still give it to each new employee, part-time or full-time, and it counts as given at hire if you give it within 14 days of their start date.
- New hire reporting. Report each new hire to your state within 20 days of hiring them, or sooner where your state says so. A returning seasonal worker counts as a new hire again if they were separated from you for at least 60 consecutive days.
Paid sick leave covers seasonal staff in some states
There is no federal paid sick leave law for most private employers, but several states have one, and their laws cover seasonal and temporary staff. Three examples:
| State | Who is covered | Accrual | When they can use it |
|---|---|---|---|
| California | Anyone who works 30 or more days for you in a year in California, including part-time and temporary staff | 1 hour per 30 hours worked; you allow at least 40 hours or 5 days a year | You can require them to wait until their 90th day |
| New York | Every employee, regardless of part-time or seasonal status | 1 hour per 30 hours worked; up to 40 hours a year with 5 to 99 employees, 56 with 100 or more | See the state's FAQ |
| Washington | Full-time, part-time, temporary and seasonal employees | 1 hour per 40 hours worked | 90 calendar days after their first day |
A six-week holiday job may end before the 90th day, but the hours still accrue, and returning staff may carry a balance. Cities such as New York City add their own rules. California also requires a Notice to Employee at hire, which includes paid sick leave.
This is general information, not legal or tax advice. State and local rules vary and change, so check with your state labor and tax departments, or an employment lawyer, for your situation.
What WorkZerk does for a holiday intake
- Each seasonal hire fills everything in on their phone from a private link, with no account or password.
- The Staff onboarding (United States) pack asks for Form W-4, Form I-9 Section 1, an optional state withholding form, direct deposit details and an emergency contact.
- The tax forms, the I-9 and the account number are marked Sensitive: stored encrypted, visible only to admins, and every view is recorded.
- Automatic reminders chase anyone who hasn't finished, and the Requests screen shows who is finished, part way or not started.
- When the season ends, closing the portal keeps every document and takes everyone off your usage.
What it does not do: WorkZerk is not payroll and not an electronic I-9 system. It doesn't complete Section 2 or Supplement B, examine documents, run E-Verify, file new hire reports, track sick leave or apply for work permits. It collects the forms and details you and your payroll need.
Setting it up in WorkZerk
1. Turn on two-factor authentication
Asking people to upload documents needs two-factor authentication on your account. Set it up under Account, then Two-factor authentication (opens in WorkZerk in a new tab).
2. Create a portal for the season
Open Portals (opens in WorkZerk in a new tab) and click New portal. Name it something your hires will recognize, such as "Holiday staff 2026".
3. Add the US staff pack
On the portal's Requests panel, pick Staff onboarding (United States) from the pack picker under Templates: United States. Untick anything this intake doesn't need before you add it. If every hire works in a state with no income tax, untick the state withholding form. See starter request packs.
4. Add a work permit for minors
The pack doesn't ask about age. Click + Insert and add a Choice request, "Are you under 18?", with Yes and No. Then add an Upload request, "Work permit", and under Show only when, pick that question and "Yes". In California, tick Require expiry so the permit's end date is tracked.
5. Hand over the notices
For the coverage options notice and any state notice, add a Choice request with one option, such as "I have read this", and attach the document with Attach a document, link or YouTube video. Each person's tick is recorded. See attaching a document or video to a request.
6. Get your people in
- You have a list. Use Import people from CSV on the portal, then Email their invites to queue a batch. See importing contacts from a CSV and batched invite emails.
- You are still hiring. Turn on the portal's self-registration link and put it in the email you send once someone accepts your offer. Section 1 can't be completed before they accept.
7. Shorten the reminders
The Outstanding requests reminder in Automations (opens in WorkZerk in a new tab) is on from the start and emails anyone who hasn't finished after 7 days. Holiday start dates don't leave 7 days, so shorten it. Remind everyone not finished on the Requests screen chases the whole portal at once. See onboarding that runs itself.
8. Complete Section 2 and approve
Open Requests (opens in WorkZerk in a new tab). By person lists what each hire still owes, and uploads wait under Needs review. Examine each person's original documents within 3 business days of their start date, complete Section 2, then approve the upload.
9. Close the portal after the season
When you need nothing more from them, open the portal's settings and close it. Their links stop working and automated emails to them stop. Every document stays on file. See portal lifecycle.
Closing also takes everyone off your usage. Your plan includes 25 active people, and each one above that costs 5 cents a day, only while they hold a live link on an open portal. If sixty seasonal hires are your only active people for 20 days, that is 35 over, so 35 × 5c × 20, or $35.
Next fall, reopen the same portal. The same links come back to life, so returning staff don't need a new invite.
Getting started
Start a free WorkZerk trial at workzerk.com, then work through the steps above before your first seasonal hire starts. If you get stuck, the getting started guide walks through a first portal end to end, or email us at [email protected].