How alcohol compliance checks and minor decoy stings work

How a compliance check runs

A compliance check, also called a minor decoy operation or sting, tests whether staff sell or serve alcohol to someone under 21. In California, local police and the state's Department of Alcoholic Beverage Control (ABC) both use decoys, and in Oregon and Washington the state agency uses its own.

Illinois's model policy for police describes the visit. The decoy enters alone and should not look as if they are with adults or officers, while an officer watches from inside or from where the sale can be seen. In a bar, the observing officer smells the drink served to confirm it is alcohol, and the decoy does not drink it.

What follows a sale is covered in after a failed alcohol compliance check, and federal tobacco checks in what happens in an FDA tobacco compliance check.

California ABC: Minor Decoy ProgramOregon Liquor and Cannabis Commission: Minor Decoy OperationsWashington State Liquor and Cannabis Board: Retail enforcementIllinois Law Enforcement Training and Standards Board, Model policy and guidelines for alcohol and tobacco compliance checks, revised 2006 (PDF)

Who the decoy is and what ID they carry

Oregon's rule also has licensees and their staff return an ID the decoy presented immediately when police or an OLCC representative ask for it.

California's regulation sets the appearance test this way:

The decoy shall display the appearance which could generally be expected of a person under 21 years of age, under the actual circumstances presented to the seller of alcoholic beverages at the time of the alleged offense.

In a January 2026 appeal, a liquor store argued that the decoy wore a baseball cap the photos in evidence did not show. The Appeals Board upheld the decision against it.

Colorado's guidelines differ: a decoy who shows a valid ID may still claim to be older, for this reason:

This demonstrates whether the seller is relying upon the valid ID presented or a verbal representation of age.

California ABC Appeals Board, AB-10026, issued January 21, 2026 (PDF)

Which venues get checked

Some states limit how venues are selected. Oregon's statute and OLCC's rule require decoy operations in cities of 20,000 or more to be random or targeted. Random checks give every licensee as equal a chance as possible, and a targeted check needs a documented compliance problem at that venue. Utah's law allows random attempts to buy alcohol at one location no more than four times in 12 months, unless the supervising officer writes down a reasonable suspicion that the venue sold to someone under 21.

Colorado's guidelines describe checks after a complaint or at random, and recommend not rechecking a venue that passed at unreasonably short intervals.

ORS 471.346, Uniform standards for minor decoy operationsOAR 845-009-0200, Uniform standards for minor decoy operations (Oregon Secretary of State)Utah Code 77-39-101, Investigation of sales to underage individualsColorado Liquor & Tobacco Enforcement Division, Model guidelines concerning compliance checks for underage alcohol sales, 2013 (PDF)

What the venue is told, before and after

Some programs announce themselves in general terms. California's ABC strongly encourages police to notify all licensees by letter "of the results of a pending Decoy Program" and to consider telling the local media. Illinois's model policy suggests news releases and letters to merchants, including congratulatory ones after a refused sale.

1. 1

   California

   After a sale, and no later than any citation, the officer directing the decoy makes a reasonable attempt to bring the decoy back in to identify the seller face to face. ABC says the decoy and the seller should then be photographed together.

2. 2

   Utah

   Right after any attempt (sale or not) or as soon as practical, the officer tells the cashier and the owner or manager that the buyer was under age. Any citation has to be issued within seven days, and the officer writes a report with a photo of how the decoy looked.

3. 3

   Colorado

   The guidelines have the seller told the same day, a criminal summons served within three days and the licensee told within 14 days if administrative action will follow.

4. 4

   Illinois

   State law requires that a venue found to have complied be told within 30 days that no violation was found. The model policy has the officer explain any violation to the manager on site.

California ABC: Minor Decoy ProgramCal. Code Regs. tit. 4, § 141, Minor decoy requirements (LII)Utah Code 77-39-101, Investigation of sales to underage individualsColorado Liquor & Tobacco Enforcement Division, Model guidelines concerning compliance checks for underage alcohol sales, 2013 (PDF)235 ILCS 5/6-16.1, Enforcement actionsIllinois Law Enforcement Training and Standards Board, Model policy and guidelines for alcohol and tobacco compliance checks, revised 2006 (PDF)

When a check does not follow the rules

California's regulation says that failure to comply with it is a defense to any action brought under the state's law on sales to minors. Oregon's law takes a different line: a departure from the state's standards is not grounds to challenge a complaint, citation or conviction, but the commission may not consider a sale from such an operation when imposing a civil penalty, deciding on the renewal, suspension or cancellation of the license or otherwise sanctioning the licensee.

Cal. Code Regs. tit. 4, § 141, Minor decoy requirements (LII)California ABC Appeals Board, AB-10026, issued January 21, 2026 (PDF)ORS 471.346, Uniform standards for minor decoy operations

Can a venue run its own decoy checks?

In some states, yes, with conditions. Washington allows in-house programs with the board's prior written approval of a written plan. The buyers are at least 18, use no fraudulent ID and should not look deceptively mature, and the venue takes two photos of each on the day. A first failure cannot be the only reason an employee is fired, and results cannot be used for criminal or administrative prosecution.

Oregon's rule has a licensee testing its own staff use a decoy who meets the state's standards and give OLCC and the local police at least 24 hours' notice, with the decoy's name, date of birth and a current photo. Illinois lets a licensee run a sting on its own staff after giving written notice at least 14 days ahead to the police, the local liquor control commissioner or both. Michigan exempts the underage buyer in an employer-sponsored check that the local prosecutor's office approved in advance.

RCW 66.44.290WAC 314-21-015WAC 314-21-025OAR 845-009-0200, Uniform standards for minor decoy operations (Oregon Secretary of State)235 ILCS 5/6-16.1, Enforcement actionsMCL 436.1703

Where a scan fits

Where the rules above address the decoy's ID, it shows their true age. If staff ask for the ID and scan it, the app works out the age from the date of birth and checks it against the venue's minimum age, which is 21 unless the owner changes it. Staff have no override for an underage result. The underage flag only goes away if the owner switches on Allow Underage Entry for that venue, which is off by default.

A decoy who carries no ID never reaches the scanner, so the check still depends on staff asking every time, as in how to check IDs at the door. Every scan creates a visit record of who scanned, when, the document type, the result and what staff decided, as how a scan works shows.