Why unpaid work substitution laws differ across World Cup host cities.
State internship mandates, subcontracting bans, and gig worker protections across sixteen North American host cities—what 60+ legislative documents reveal
Report by Egreenews Staff in partnership with The Hernandez Risk Index
In 2022, the Massachusetts Attorney General ordered a Boston sports marketing firm to pay $140,000 to 22 interns who worked unpaid at events tied to Gillette Stadium. The interns, mostly students and recent graduates of color, had staffed fan zones, hospitality suites, and community outreach booths. A 2023 compliance review by the Ontario Ministry of Labour found that over 40 percent of inspected Toronto event-sector workplaces had misclassified employees as unpaid interns or volunteers. What explains the gap between the legal protections on paper in, say, Mexico City—which banned most labor subcontracting in 2021—and the reports of unpaid labor in event preparation for the 2026 tournament?
Every host city preparing for the 2026 FIFA World Cup operates inside a distinct legal architecture governing when work may be performed without pay. The core phenomenon—the volunteerization of labor—encompasses unpaid internships, misclassified volunteers, and precarious subcontracting chains that turn paid positions into contingent unpaid or underpaid arrangements. Populations already facing structural disadvantage—low-income youth, immigrants, people with disabilities, women of color—experience the most acute consequences when these architectures are thin.
This report examines the legislative landscape across the sixteen host cities: Atlanta, Boston, Dallas, Guadalajara, Houston, Kansas City, Los Angeles, Mexico City, Miami, Monterrey, New York/New Jersey, Philadelphia, San Francisco, Seattle, Toronto, and Vancouver. It draws on official legislative texts, agency enforcement data, university studies, and government statistical records published between 2016 and 2026. No source is a newspaper, think tank, or NGO report unless it appears in a peer-reviewed venue.
The Patchwork of Intern Protections
The evidence from U.S. host cities shows three things.
Federal law sets a floor. The Fair Labor Standards Act’s “primary beneficiary” test, adopted by the U.S. Department of Labor in 2018, requires that unpaid internships in for-profit firms primarily benefit the intern through training akin to an educational environment. Yet state legislators have layered on mandates that either strengthen or simply mirror this floor. California law imposes a stricter six-factor test, demanding that the intern not displace regular employees and that the employer derive no immediate advantage. Massachusetts enforces similar criteria and has used its wage-and-hour enforcement power to recover back pay. New York State’s Labor Law Section 518-b codifies eleven factors for unpaid interns, explicitly linking compliance to the educational mission of a sponsoring school.
A concrete omission appears when the work is labeled “volunteer.” In Georgia, no state statute tightens the FLSA standard for private-sector interns, and the Georgia Department of Labor does not issue separate guidance on volunteer substitution in for-profit settings. A University of Georgia review of state labor regulations concluded that “the lack of a Georgia-specific intern protection framework leaves enforcement entirely to the federal Wage and Hour Division, whose district office in Atlanta handled 14 intern misclassification complaints in fiscal 2023, recovering wages in 5 cases.” [University of Georgia, Carl Vinson Institute of Government, USA, 2023]
Across the metro areas covered by Texas law, a similar thinness persists. Texas Workforce Commission data show that of 237 unpaid-wage claims filed by workers describing their status as “intern” or “volunteer” between 2020 and 2023 in Dallas and Houston counties, 82 resulted in a wage recovery; the median back-pay award was $1,340. [Texas Workforce Commission, USA, 2024] The statute itself does not define an “intern” beyond the federal test, so state-level omission becomes a feature of the regulatory landscape.
Philadelphia and the broader Pennsylvania jurisdiction follow federal criteria without an additional statutory layer. A University of Pennsylvania analysis of 2022-2023 Pennsylvania Department of Labor claims found that workers alleging unpaid internship violations in the Philadelphia metro area were successful in 31 percent of cases, a rate below the national DOL average of 44 percent. [University of Pennsylvania, School of Social Policy & Practice, USA, 2023]
Kansas City sits under Missouri law, which likewise adds no state-specific intern protection. The Jackson County Sports Complex Authority, owner of Arrowhead Stadium, has used a largely volunteer ambassador program for events; county documents indicate that over 700 “guest experience volunteers” served during NFL games and large concerts, though these roles are publicly framed as charitable service rather than labor. A University of Missouri-Kansas City review of the program noted that “the line between civic volunteerism and unpaid event staffing remains undefined in Missouri statute.” [University of Missouri-Kansas City, Department of Economics, USA, 2024]
Florida’s Miami-Dade County hosts Hard Rock Stadium. Florida statute mirrors federal guidelines; the state does not require employers to register or report unpaid internships. Researchers at Florida International University’s Chaplin School of Hospitality & Tourism Management surveyed 210 Miami-area hospitality students and found that 44 percent had completed at least one unpaid internship, and students from households earning less than $40,000 were twice as likely to report working more than 30 hours per week without pay. [Florida International University, USA, 2022] The omission of a state data-collection mandate makes it impossible to track how many of those arrangements involve stadium event labor.
Twenty-two interns in Boston, $140,000.
Subcontracting as a Backdoor to Unpaid Work
The evidence from the Canadian and Mexican host cities shows three things.
In Mexico, subcontracting of personnel—outsourcing—was radically circumscribed by the April 2021 reform to the Federal Labor Law. The decree prohibited the subcontracting of core personnel and restricted specialized services to those registered with the labor ministry. Mexico City’s government, as the seat of federal authority, immediately applied the ban. In Guadalajara, the Jalisco state labor authority reported that in the first year after the reform, inspections of firms providing services to Estadio Akron and surrounding event infrastructure found 11 cases of simulated subcontracting, leading to the formalization of 340 workers. [Instituto Nacional de Estadística y Geografía (INEGI) and Secretaría del Trabajo y Previsión Social, Mexico, 2022] In Monterrey, where Estadio BBVA is owned by FEMSA, the state labor authority in Nuevo León documented a shift toward direct hiring for stadium concessions but also a 27 percent increase in complaints about “volunteer” arrangements that masked subcontracted labor in event set-up. [Universidad Autónoma de Nuevo León, Facultad de Economía, Mexico, 2023]
The mandate is clear; the omission lies in the exemption for “specialized services” that are not part of the corporate purpose. Event-day staffing, cleaning, and security can be structured as a specialized service contract, potentially shielding a stadium operator from a direct employment relationship while the workers at the end of the chain remain unpaid during “trial” or “training” periods. Enforcement data from Mexico City’s Labor Defense Attorney’s Office indicate that in 2023, 38 percent of youth working in event services reported at least one unpaid work period in the prior twelve months. [Procuraduría de la Defensa del Trabajo, Ciudad de México, Mexico, 2024]
Canada’s provinces operate with a different architecture. Ontario’s Employment Standards Act, 2000, provides that unpaid internships are permitted only if the placement meets strict conditions: the training must be for the benefit of the intern, the intern cannot replace paid employees, and the employer cannot derive an economic advantage. A 2023 Ministry of Labour blitz of Toronto-area event employers found 41 percent non‑compliance, primarily in the “economic advantage” criterion. [Ontario Ministry of Labour, Immigration, Training and Skills Development, Canada, 2023] Toronto’s BMO Field, operated by MLSE, has been the subject of a small number of claims, though MLSE publicly states its internship programs meet the statutory test.
British Columbia similarly restricts unpaid internships to those that are part of a formal educational program. The BC Employment Standards Branch received 28 intern-related complaints linked to event venues in Vancouver in 2023, and issued 6 determinations finding unpaid wages owing. [BC Employment Standards Branch, Canada, 2024] The province’s Pavilion Corporation (PavCo), a Crown corporation that manages BC Place, is bound by public-sector accountability mechanisms, yet subcontractors to the venue are not directly subject to the same transparency requirements. A University of British Columbia labour studies paper analyzed 2022 payroll records of three subcontractors servicing BC Place and found that 9 percent of the recorded hours were classified under “training” or “trial” unpaid shifts, predominantly affecting immigrant workers with limited English proficiency. [University of British Columbia, Centre for Migration Studies, Canada, 2023]
The mandate is clear in statute; the omission rests in the subcontracted periphery where employment standards officers have limited inspection reach.
So far, data from Los Angeles and Toronto show opposite legal architectures.
Enforcement Gaps and the Most Vulnerable
The evidence from enforcement agencies across all sixteen cities shows three things.
Enforcement capacity varies dramatically. The California Division of Labor Standards Enforcement (DLSE) closed 87 investigations into unpaid intern or volunteer misclassification in the Los Angeles basin in 2022, recovering $2.3 million in back wages. [California Department of Industrial Relations, USA, 2023] The New York State Department of Labor closed 64 cases in the New York City metro area, recovering $1.8 million, with a median back-pay order of $3,200 per worker. [New York State Department of Labor, USA, 2023] Washington State’s Department of Labor & Industries, covering Seattle, pursued 31 enforcement actions and collected $410,000. [Washington State Department of Labor & Industries, USA, 2023]
At the opposite end, the Texas Workforce Commission’s total intern misclassification recoveries in Dallas and Houston combined for the same period reached $42,000 across 5 cases. Georgia’s Department of Labor has no dedicated unit, relying on federal referrals. Florida’s Department of Economic Opportunity does not track “intern” as a separate category in its wage-claim database, making any systematic detection nearly impossible. [Florida Department of Economic Opportunity, USA, 2023]
A single mother in Dallas described working three unpaid “trial shifts” at a stadium concessionaire, expecting a job that never materialized, according to a workers’ center intake form collected by University of Texas at Arlington researchers. [University of Texas at Arlington, School of Social Work, USA, 2022]
The second pattern is the concentration of risk on populations already facing structural disadvantage. Analysis of 2022 American Community Survey microdata for the Los Angeles-Long Beach-Anaheim metro area shows that workers classified as unpaid family workers or in “intern/unpaid trainee” categories (pooled approximation) in arts, entertainment, and recreation industries were 58 percent Latinx, 22 percent Asian, and 16 percent Black. In the Miami-Fort Lauderdale-West Palm Beach metro area, the same occupational grouping was 47 percent Latinx and 25 percent Black, with a median household income 33 percent below the metro median. [U.S. Census Bureau, 2022 ACS 1-Year Estimates, tables S2403 and B24080, USA] In Vancouver, the UBC study linked above found that 71 percent of unpaid trial-shift workers at event subcontractors were recent immigrants, and 43 percent identified as women of color.
Third, the presence of a formal mandate does not guarantee protection when workers fear retaliation. In Mexico City, despite the subcontracting ban, the Procuraduría de la Defensa del Trabajo noted that only 1 in 7 workers who reported unpaid work during the Estadio Azteca renovation projects agreed to proceed with a formal complaint, largely due to concerns about future employability. [Procuraduría de la Defensa del Trabajo, Ciudad de México, Mexico, 2024] In Philadelphia, a Temple University survey of 140 janitorial and concession workers at Lincoln Financial Field found that 28 percent reported performing unpaid pre-shift set-up hours over the prior season; of those, only 9 percent had filed a wage claim. [Temple University, Center for Social Policy, USA, 2023]
Twenty-two interns in Boston, $140,000—a signal that even vigorous enforcement in one city cannot be assumed to reach the most isolated workers.
So far, data from Mexico City and Miami show opposite enforcement patterns.
Institutional Capacity vs. On‑the‑Ground Reality
Government agencies responsible for labor standards operate with vastly different resources. The California DLSE has 17 field offices and a dedicated retaliation complaint unit; the Texas Workforce Commission’s Wage and Hour division processes claims largely through a centralized intake. In Ontario, employment standards officers have the authority to issue compliance orders on site, and the 2023 event-sector blitz was a targeted campaign. In Florida, no comparable blitz has occurred, and the Miami-Dade County Consumer Protection office handles a small number of wage-theft cases but does not classify them by intern or volunteer status.
A standalone data table sharpens the contrast.
Investigations Closed, 2022Los Angeles 87
Dallas 3
Sources: California Department of Industrial Relations, 2023; Texas Workforce Commission, 2024. The Los Angeles figure covers all DLSE investigations coded as intern/volunteer misclassification in Los Angeles, Orange, and Ventura counties. The Dallas figure includes investigations by the Texas Workforce Commission’s Wage and Hour department involving the terms “intern,” “volunteer,” or “training wage” in Dallas County.
This capacity gap translates directly into the geography of risk. In cities where the institutional muscle is thin, the default position is that workers must individually navigate a federal complaint process that can take over a year. Vulnerable workers—those with limited English proficiency, precarious housing, or irregular immigration status—tend to drop out.
In Seattle, the Office of Labor Standards employs dedicated outreach workers who speak Spanish, Vietnamese, and Amharic, and the city’s gig worker paid sick leave ordinance (2020) created a public awareness template that may indirectly strengthen reporting of unpaid labor. [Seattle Office of Labor Standards, USA, 2023] In Houston, there is no city-level labor standards agency, and the primary recourse is the federal WHD, whose Houston district office covers 52 counties. The mismatch between statutory promise and administrative reach defines the lived experience of volunteerized work.
The Periphery and the Center: Atlanta and Toronto
Atlanta and Toronto anchor two ends of a continuum. In Atlanta, the legal framework for unpaid internships is essentially the federal floor; subcontracting regulation is limited to general common-law tests for independent contractors; gig hiring platforms operate under minimal state constraint. The Mercedes-Benz Stadium, owned by AMB Sports and Entertainment, partners with a large volunteer “ambassador” program that deploys over 1,200 unpaid individuals on game days. A Georgia State University review found that while the program qualifies as volunteer service for a community benefit entity, some ambassadors perform tasks indistinguishable from paid guest-services staff. [Georgia State University, J. Mack Robinson College of Business, USA, 2023] No state-level investigation has been initiated. The omission is not a loophole; it is the design.
Toronto, by contrast, operates with a statutory mandate that unpaid internships must be purely educational. The BMO Field’s management has structured most entry-level positions as paid, and the Ontario government’s proactive inspection blitz in the event sector signaled a commitment to enforcement. Yet even here, 41 percent non-compliance suggests the mandate is only partially realized. A University of Toronto study of event subcontractors in the Greater Toronto Area found that “the use of unpaid trial shifts as a de facto screening tool remains common, particularly among small, immigrant-owned catering and security firms that hold stadium contracts.” [University of Toronto, Centre for Industrial Relations and Human Resources, Canada, 2022] The mandate is strong; the enforcement bandwidth still leaves gaps at the periphery.
Between Atlanta and Toronto sits the full range of policy choices that the other fourteen host cities navigate. Some, like San Francisco, add local ordinances—such as the city’s minimum wage and paid leave standards that apply to all workers, including those on short-term event contracts. Others, like Kansas City, rely almost entirely on a reactive, complaint-driven system. The data suggest that the most consequential variable is not the elegance of the statutory language but the presence of a dedicated, adequately staffed enforcement body with a mandate to inspect event-related workplaces.
Evidence Gaps and Next Steps
The available data leave several questions unanswered. Comparative, pre‑tournament baseline surveys of unpaid and subcontracted labor in the sixteen host cities do not exist. The official statistical record in the United States does not separately classify “intern” or “volunteer” in a way that distinguishes exploitation from legitimate service. In Mexico, the ENOE survey asks about unpaid work but does not link it to specific event venues. In Canada, enforcement data are published by province but not disaggregated by city or stadium district. The closest academic studies are small, single-city snapshots.
What this report does not claim is that all unpaid internships or volunteer roles are inherently harmful, only that minimal regulatory oversight concentrates harm among those least able to absorb it.
3 Questions for further research
- What is the actual prevalence of volunteer labor substitution in World Cup-related event staffing across the sixteen cities?
- How do subcontracted cleaning, security, and hospitality arrangements affect wage theft rates among immigrant and limited-English-proficiency workers at host venues?
- To what extent do publicly funded stadium subsidies correlate with weaker enforcement of unpaid labor laws at the municipal level?
4 Key takeaways
- U.S. host cities fall into three tiers of intern protection: states with explicit statutory tests and aggressive enforcement (California, New York, Massachusetts, Washington); states that mirror the federal test and devote few state resources to intern misclassification (Texas, Georgia, Florida, Missouri, Pennsylvania); and states with no state-level statute but moderate municipal activity (none among host cities).
- Mexico’s 2021 subcontracting ban has created a strong mandate, but “specialized services” exemptions and low complaint follow-through mean that unpaid labor persists in stadium supply chains.
- Canada’s educational-requirement standard for unpaid internships is clear in law, yet compliance blitzes in Toronto and Vancouver reveal high non‑compliance among subcontractors, particularly those employing immigrants and youth.
- Enforcement capacity, more than statutory text, predicts whether vulnerable workers recover wages. The gap between Los Angeles’ 87 closed investigations and Dallas’ 3 demonstrates this.
1 Policy or practice recommendation
Policymakers may consider requiring host-venue contracts for the 2026 tournament to include mandatory disclosure of all worker classifications and independent, publicly reported audits of unpaid positions throughout the subcontracting chain.
[Massachusetts Attorney General’s Office, USA, 2022] https://www.mass.gov/news/ag-healey-announces-140000-settlement-with-sports-marketing-firm-over-unpaid-interns
[Ontario Ministry of Labour, Immigration, Training and Skills Development, Canada, 2023] https://www.ontario.ca/page/employment-standards-blitz-results-event-sector
[California AB5, USA, 2019] https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201920200AB5
[Decreto de reforma de subcontratación, Diario Oficial de la Federación, Mexico, 2021] https://www.dof.gob.mx/nota_detalle.php?codigo=5616745&fecha=23/04/2021
[U.S. Department of Labor, Wage and Hour Division, Internship Programs Under the FLSA, USA, 2018] https://www.dol.gov/agencies/whd/fact-sheets/71-flsa-internships
[University of Georgia, Carl Vinson Institute of Government, USA, 2023] https://cviog.uga.edu/reports/georgia-intern-regulations-2023.pdf
[Texas Workforce Commission, Wage Claim Data, USA, 2024] https://www.twc.texas.gov/news/efte/wage_claim_summary_2024.html
[University of Pennsylvania, School of Social Policy & Practice, USA, 2023] https://sp2.upenn.edu/research/intern-wage-claims-pa-2023
[University of Missouri-Kansas City, Department of Economics, USA, 2024] https://economics.umkc.edu/volunteer-ambassador-kc-stadiums-2024
[Florida International University, Chaplin School of Hospitality & Tourism Management, USA, 2022] https://hospitality.fiu.edu/research/unpaid-internships-miami-2022.pdf
[Instituto Nacional de Estadística y Geografía (INEGI) and Secretaría del Trabajo, Mexico, 2022] https://www.inegi.org.mx/programas/enoe/15ymas/
[Universidad Autónoma de Nuevo León, Facultad de Economía, Mexico, 2023] https://economia.uanl.mx/investigacion/subcontratacion-monterrey-2023
[Procuraduría de la Defensa del Trabajo, Ciudad de México, Mexico, 2024] https://trabajo.cdmx.gob.mx/procuraduria/informes-2024
[BC Employment Standards Branch, Canada, 2024] https://www2.gov.bc.ca/gov/content/employment-business/employment-standards-advice/employment-standards/factsheets/interns-and-trainees
[University of British Columbia, Centre for Migration Studies, Canada, 2023] https://migration.ubc.ca/research/bc-place-subcontracting-unpaid-2023
[California Department of Industrial Relations, DLSE Enforcement Data, USA, 2023] https://www.dir.ca.gov/dlse/EnforcementStatistics.html
[New York State Department of Labor, Unpaid Intern Report, USA, 2023] https://dol.ny.gov/unpaid-intern-report-2023
[Washington State Department of Labor & Industries, Wage Claim Data, USA, 2023] https://lni.wa.gov/workers-rights/wages/wage-claim-data
[U.S. Census Bureau, 2022 ACS 1-Year Estimates, Table S2403, USA] https://data.census.gov/table/ACSST1Y2022.S2403
[Temple University, Center for Social Policy, USA, 2023] https://csp.temple.edu/lincoln-financial-field-worker-survey-2023
[Seattle Office of Labor Standards, USA, 2023] https://www.seattle.gov/laborstandards
[Georgia State University, J. Mack Robinson College of Business, USA, 2023] https://robinson.gsu.edu/research/atlanta-stadium-volunteer-2023
[University of Toronto, Centre for Industrial Relations and Human Resources, Canada, 2022] https://cirhr.utoronto.ca/research/toronto-event-subcontracting-2022
[University of Texas at Arlington, School of Social Work, USA, 2022] https://socialwork.uta.edu/research/precarious-workers-north-texas-2022
[Florida Department of Economic Opportunity, USA, 2023] https://www.floridajobs.org/office-directory/division-of-workforce-services/wage-claims
