2257 Compliance Checklist for Adult Content Producers

Why You Need a 2257 Compliance Checklist

If you produce adult content involving more than one performer, 18 U.S.C. § 2257 requires you to maintain age verification records. The penalties for non-compliance — up to 5 years imprisonment for a first offense — make it critical to get every step right.

This checklist covers every requirement so you can verify your compliance at each stage of production. Bookmark this page or download the checklist as a reference.

Pre-Production Checklist

Before any filming or photography begins, complete every item below for each performer who will appear in sexually explicit content.

Identity Verification

• [ ] Collect a valid, unexpired government-issued photo ID from each performer
• [ ] Acceptable IDs: driver's license, passport, state-issued ID card, military ID
• [ ] Verify the ID contains: legal name, date of birth, and photograph
• [ ] Confirm the performer is at least 18 years old at the time of production
• [ ] Compare the photo on the ID to the person standing in front of you
• [ ] If using a digital verification service (like Easy2257), ensure the automated check completes successfully before proceeding

Record Collection

• [ ] Record each performer's legal name exactly as it appears on their ID
• [ ] Record their date of birth
• [ ] Record all stage names, aliases, maiden names, or nicknames the performer uses or has used
• [ ] Have each performer sign a model release or Performer Information Worksheet (PIW) that includes their legal name, stage name, and date of birth
• [ ] Retain a copy or record of the ID (digital scan, photograph, or detailed notation)

Performer Consent

• [ ] Obtain written consent for the specific content being produced
• [ ] Ensure consent documents reference the performer's legal name and the production title
• [ ] If required by your workflow, record pre-shoot video consent

Production Checklist

During and immediately after production, document the following.

Content Documentation

• [ ] Assign a unique title, identifier, or scene number to each piece of content produced
• [ ] Record the date of production for each scene or content piece
• [ ] Record the names of all performers appearing in each scene (legal names and stage names)
• [ ] If applicable, record the location of production

Cross-Referencing

• [ ] Create an index entry that links each performer to every piece of content they appear in
• [ ] Ensure the index is searchable by any name a performer has used (legal name, stage names, aliases)
• [ ] Ensure the index is searchable by content title or identifier

Post-Production Checklist

After production is complete, before content is published or distributed.

Record Organization

• [ ] All performer records are organized and indexed in a systematic manner
• [ ] Records can be produced for any performer within a reasonable timeframe
• [ ] Records can be produced for any piece of content within a reasonable timeframe
• [ ] All records are stored in a secure location with appropriate access controls

Custodian of Records (COR)

• [ ] A Custodian of Records has been designated for your productions
• [ ] The COR's name and address are documented in your records
• [ ] The COR can make records available for inspection during normal business hours
• [ ] If you are your own COR: your designated address is a location where records can be physically inspected (not just stored digitally)
• [ ] If using a COR service (like Easy2257): your subscription is active and all records have been uploaded

Content Labeling

• [ ] Every piece of content includes a 2257 compliance statement that identifies:

- The name of the Custodian of Records

- The physical address where records can be inspected

• [ ] For websites: a dedicated 2257 compliance page is accessible from the content
• [ ] For distributed content: the statement appears on or near the content itself
• [ ] Statement format example: *"18 U.S.C. § 2257 Record-Keeping Requirements Compliance Statement: Records required by 18 U.S.C. § 2257 are kept by [COR Name], [COR Address]."*

Ongoing Compliance Checklist

Compliance isn't a one-time event — it's ongoing for as long as your content is available.

Record Retention

• [ ] Records are maintained for as long as content is commercially available
• [ ] After content is removed from distribution, records are retained for an additional 5 years
• [ ] Backups exist to protect against data loss
• [ ] If a performer's name changes, records are updated to reflect the new name while retaining the old name as an alias

Periodic Review

• [ ] Review records quarterly to ensure completeness
• [ ] Verify that all published content has an associated COR statement
• [ ] Confirm your COR designation is current and active
• [ ] Update records for any content that has been redistributed, licensed, or reissued

Inspection Readiness

• [ ] Records can be produced on demand during business hours
• [ ] The COR (you or your service) is prepared to respond to an inspection request
• [ ] You understand the inspection process: administrative inspections authorized by the statute, conducted during reasonable hours

Common Mistakes to Avoid

1. Collecting IDs after production — The law requires verification *before* production begins
2. Accepting expired IDs — The ID must be valid at the time of verification
3. Incomplete cross-referencing — A folder of IDs without links to specific content is not compliant
4. Missing the display requirement — Every piece of published content needs the COR statement
5. Using your home address as COR — While technically compliant, this exposes your home address publicly. A COR service solves this for $39.95/scene.
6. Assuming the platform handles it — OnlyFans, ManyVids, and other platforms handle their own obligations. Yours are separate.
7. Not updating records when content is re-released — Redistributed content needs maintained records

How Easy2257 Handles This Entire Checklist

Every item on this checklist is built into the Easy2257 workflow:

• Identity verification — Bank-grade automated ID scanning and face matching via Veriff
• Record collection — Performers complete their own information via secure invite links
• Cross-referencing — Automatic linking of performers to productions and scenes
• COR service — We serve as your designated Custodian of Records (included in all paid plans)
• Content labeling — We provide your COR statement text to display on content
• Record retention — Secure encrypted cloud storage with redundant backups
• Inspection readiness — Generate audit-ready reports with one click

Get started free and let Easy2257 handle compliance so you can focus on production.

This checklist is for informational purposes only and does not constitute legal advice. Consult an attorney for guidance specific to your situation.