Do summer camps have to pay counselors minimum wage?

Not always under federal law. The FLSA’s seasonal exemption lifts minimum wage and overtime for an organized camp that operates seven months or less a year or passes a seasonal receipts test, but the camp has to be its own establishment and state law can still apply. California lets camps that meet ACA standards pay counselors a weekly salary of at least 85% of minimum wage for a 40-hour week, Wisconsin publishes weekly counselor minimums, and New York and Massachusetts exclude counselors from their minimum wage laws.

Can a summer camp use unpaid volunteer counselors?

A nonprofit, church or public-agency camp can, if the volunteers work without expecting compensation — the Department of Labor lists camp counseling as a typical volunteer activity. Free room and board or tuition given in exchange for the work can count as wages in another form. A for-profit camp has no volunteer category: unpaid workers are tested as interns, and one who fills a staff slot is likely an employee.

Can a 14- or 15-year-old work as a paid counselor-in-training?

Yes, within federal child-labor limits: when school is out, no more than 8 hours in a day or 40 in a week, only between 7 a.m. and 9 p.m. from June 1 through Labor Day, and only in permitted jobs. That rules out paid overnight cabin duty. A certified 15-year-old may lifeguard only at pools and water parks, and many states also require working papers before a minor starts.

Do camps have to pay staff for overnight hours?

Only where the seasonal exemption doesn’t apply or state law requires it. Under federal rules a shift of less than 24 hours is all work even if staff may sleep. For 24 hours or more, up to 8 hours of sleep can be excluded by agreement, but interruptions count, and a night with less than 5 hours’ sleep counts in full.

Can a camp count room and board toward counselor pay?

Federally, only at actual cost with no profit, only if accepting it is voluntary, and not for housing provided mainly for the camp’s benefit — which, in our reading, can describe a counselor required to sleep in a cabin. For income tax, on-site meals and required on-site lodging are usually excluded from the counselor’s wages. States add rules of their own, such as California’s written-agreement requirement.

What changed for J-1 camp counselors in 2026?

The Department of Homeland Security replaced “duration of status” with fixed admission periods for J visitors, effective September 15, 2026, subject to congressional review; a counselor whose program is cut short must leave within 30 days or seek to keep status. Travel proclamations suspend J visas for some countries, and Congress enacted a visa integrity fee of at least $250 in 2025 — confirm with the State Department whether it is being collected.

Are camp counselors exempt from payroll taxes?

Partly. A full-time student working fewer than 13 weeks for a seasonal camp is exempt from federal unemployment tax, and 501(c)(3) camps owe none at all, but Social Security and Medicare still apply to U.S. staff. J-1 counselors are generally exempt from both while they are nonresident aliens, though income tax is withheld. State unemployment insurance follows its own rules.

Free guide · 2026 edition · For directors who hire, house and train a summer staff

An Organized Camp: The law and practice of hiring, paying, housing, training and supervising a seasonal camp staff

When the federal seasonal exemption covers your counselors, what your state requires instead, how nights and cabins count, and the rules for volunteers, CITs and J-1 staff.

By the VolunteerBadge research team · Published September 12, 2026

Written for camp directors who hire, pay, house and train a summer staff
The FLSA seasonal exemption beside 12 states’ own counselor wage rules
A year-round staffing calendar and a volunteer and CIT checklist
Ratios, ages and director rules for ten states, each cited to the rule

Who An Organized Camp is for

Directors, owners and HR leads at day and resident camps — nonprofit, church, municipal and for-profit — who turn a winter hiring plan into a lawful, trained and housed summer staff. If you set counselor pay, decide who counts as a volunteer, bring in J-1 counselors or put CITs on the schedule, start here.

3.8×

as many paid jobs at U.S. recreational and vacation camps in July 2025 as in January — about 91,000 against 24,000.

BLS QCEW (our arithmetic)

32,470

new J-1 camp counselors came to the United States in 2025, 38% of them from the United Kingdom.

U.S. Department of State (38% is our arithmetic)

9 p.m.

is the latest a paid 14- or 15-year-old may work in summer under federal child-labor rules, which rules out paid overnight cabin duty.

29 C.F.R. § 570.35

From the An Organized Camp executive summary

Six staffing rules camp directors often learn too late

1
The seasonal exemption is narrower than its reputation.
It covers an organized camp that is its own establishment and runs seven months or less, or passes a receipts test; a summer add-on to a year-round operation can fail it.
2
Your state adds its own counselor pay rules.
California sets a weekly salary floor, Wisconsin weekly minimums, New York and Massachusetts exclude counselors — and a state exclusion never switches off federal law.
3
Free room, board or tuition can be a paycheck.
In-kind benefits given for counselor work can be wages in another form, and for-profit camps have almost no room for unpaid counselors.
4
A paid 14-year-old CIT is a child-labor case.
Federal limits cap hours, end the workday at 9 p.m. in summer, bar lake lifeguarding under 16 and keep anyone under 17 from driving on public roads for work.
5
J-1 rules moved in 2026.
Fixed admission periods take effect September 15, 2026, subject to congressional review, alongside travel restrictions and a visa integrity fee whose collection you should confirm.
6
Ratios and training hours are state floors.
Ten camp codes give ten sets of numbers; staff above them for days off, trips and the waterfront.

Inside An Organized Camp, chapter by chapter

01
The season on one page
Eight rules a director should know before the first offer letter goes out.
02
Who you’re hiring, and why they come back
July hiring spikes, fewer working teens, recreation-worker pay and what research says about returning staff.
03
Volunteer, stipend or paycheck
The Supreme Court’s expectation-of-compensation test for nonprofit, public-agency and for-profit camps.
04
The seasonal exemption from minimum wage and overtime
FLSA section 13(a)(3), the establishment test, the receipts test and the federal-land carve-out.
05
State camp wage rules
Twelve states’ counselor wage rules beside their 2026 minimum wages.
06
Round-the-clock duty: nights, sleep and lodging
When cabin nights count as hours worked, and why a lodging credit differs from a tax exclusion.
07
Teens on the payroll: CITs and junior staff
Federal hours, jobs, lifeguarding and driving limits, state working papers and workers’ comp penalties.
08
International staff: the J-1 camp counselor
Program rules, fees, 2025–26 changes, H-2B for support roles and J-1 payroll taxes.
09
Payroll taxes, unemployment, workers’ comp and contractors
FICA, FUTA and state unemployment exclusions for camp students, and the unsettled contractor test.
10
Staff cabins and the camp as a workplace
State sleeping-space rules that reach staff, OSHA duties and the labor-camp benchmark.
11
Ratios, ages and qualifications: the state floor
Patterns in counselor ages, young-staff caps, who counts in a ratio and director requirements.
12
Training and mandated reporting
State training mandates, who must report abuse, and what studies say makes training last.
13
Screening, the staff file and VolunteerBadge
The six records to keep for every hire, and where a $5 check fits.
A
Appendix A: Staffing compliance calendar
Classification in the fall, recruiting in winter, verification in spring and close-out in August.
B
Appendix B: Volunteer and CIT decision checklist
Sixteen questions to answer and file for every unpaid or lightly paid role.
C
Appendix C: Ten-state ratios and qualifications
Counselor ages, ratios, director rules and CIT limits for NY, NJ, MA, CT, NH, ME, MI, CO, TX and WI.
D
Appendix D: The wage, visa and labor sources
Statutes, regulations, agency data and studies, each pinned to a subsection and dated September 12, 2026.

Get the free guide

Questions An Organized Camp answers

Do summer camps have to pay counselors minimum wage?: Not always under federal law. The FLSA’s seasonal exemption lifts minimum wage and overtime for an organized camp that operates seven months or less a year or passes a seasonal receipts test, but the camp has to be its own establishment and state law can still apply. California lets camps that meet ACA standards pay counselors a weekly salary of at least 85% of minimum wage for a 40-hour week, Wisconsin publishes weekly counselor minimums, and New York and Massachusetts exclude counselors from their minimum wage laws.
Can a summer camp use unpaid volunteer counselors?: A nonprofit, church or public-agency camp can, if the volunteers work without expecting compensation — the Department of Labor lists camp counseling as a typical volunteer activity. Free room and board or tuition given in exchange for the work can count as wages in another form. A for-profit camp has no volunteer category: unpaid workers are tested as interns, and one who fills a staff slot is likely an employee.
Can a 14- or 15-year-old work as a paid counselor-in-training?: Yes, within federal child-labor limits: when school is out, no more than 8 hours in a day or 40 in a week, only between 7 a.m. and 9 p.m. from June 1 through Labor Day, and only in permitted jobs. That rules out paid overnight cabin duty. A certified 15-year-old may lifeguard only at pools and water parks, and many states also require working papers before a minor starts.
Do camps have to pay staff for overnight hours?: Only where the seasonal exemption doesn’t apply or state law requires it. Under federal rules a shift of less than 24 hours is all work even if staff may sleep. For 24 hours or more, up to 8 hours of sleep can be excluded by agreement, but interruptions count, and a night with less than 5 hours’ sleep counts in full.
Can a camp count room and board toward counselor pay?: Federally, only at actual cost with no profit, only if accepting it is voluntary, and not for housing provided mainly for the camp’s benefit — which, in our reading, can describe a counselor required to sleep in a cabin. For income tax, on-site meals and required on-site lodging are usually excluded from the counselor’s wages. States add rules of their own, such as California’s written-agreement requirement.
What changed for J-1 camp counselors in 2026?: The Department of Homeland Security replaced “duration of status” with fixed admission periods for J visitors, effective September 15, 2026, subject to congressional review; a counselor whose program is cut short must leave within 30 days or seek to keep status. Travel proclamations suspend J visas for some countries, and Congress enacted a visa integrity fee of at least $250 in 2025 — confirm with the State Department whether it is being collected.
Are camp counselors exempt from payroll taxes?: Partly. A full-time student working fewer than 13 weeks for a seasonal camp is exempt from federal unemployment tax, and 501(c)(3) camps owe none at all, but Social Security and Medicare still apply to U.S. staff. J-1 counselors are generally exempt from both while they are nonresident aliens, though income tax is withheld. State unemployment insurance follows its own rules.

Beyond An Organized Camp

VolunteerBadge is owned and operated by ScreenForge Labs, LLC, an FCRA-regulated Consumer Reporting Agency that has obtained its FCRA Certificate from the Consumer Data Industry Association (CDIA). This guide is general educational information and is not legal advice. Laws change; this guide's sources were checked as of September 12, 2026.