The Complete Guide to 18 U.S.C. § 2257 Compliance

What Is 18 U.S.C. § 2257?

18 U.S.C. § 2257 is a federal law that requires producers of "actual sexually explicit conduct" to create and maintain records verifying that every performer is at least 18 years old at the time of production. The law was enacted to combat the exploitation of minors in pornography and applies to anyone who produces, manufactures, publishes, duplicates, reproduces, or reissues such content.

If you produce adult content involving more than one performer — whether you're a studio, an independent producer, or a creator on platforms like OnlyFans — this law applies to you.

Who Does 2257 Apply To?

The law applies to primary producers (those who actually film or photograph the content) and secondary producers (those who publish, duplicate, or distribute it). Key groups include:

• Independent producers shooting scenes with other performers
• Studios of any size producing explicit content
• Clip site sellers on platforms like ManyVids, Clips4Sale, and IWantClips
• OnlyFans creators who produce collaborative content (not solo content — 2257 applies when multiple performers are involved in sexually explicit conduct)
• Photographers shooting explicit still images
• Distributors and publishers who reissue content

Important: Solo content creators generally do not fall under 2257 unless they are producing content depicting "actual sexually explicit conduct" as defined by the statute. Consult an attorney for your specific situation.

The Five Core Requirements

1. Collect Government-Issued Photo ID

For every performer appearing in sexually explicit content, you must collect and inspect a valid government-issued photo identification document. This ID must contain:

• The performer's legal name
• Date of birth
• A photograph

Acceptable documents include driver's licenses, passports, and state-issued ID cards. You must verify that the performer is at least 18 years old before any production begins.

2. Maintain Detailed Records

You must create and maintain an index that cross-references:

• Each performer's legal name
• Any stage names, aliases, or maiden names used
• Date of birth
• The title, description, or identifier of each piece of content they appear in
• The date of production

These records must be organized so that an inspector can locate any performer's records by searching for any name the performer has used.

3. Designate a Custodian of Records (COR)

Every producer must designate a Custodian of Records — a person or entity responsible for maintaining the required records and making them available for inspection. The COR must:

• Maintain all required records in an organized, accessible manner
• Make records available for inspection during normal business hours at a designated physical location
• Produce records on demand when requested by authorized inspectors (typically the Attorney General's office)

4. Display the COR Statement

Every piece of content you produce must display a compliance statement including:

• The name of the Custodian of Records
• The physical address where records can be inspected

This statement must appear on the content itself or be readily accessible (e.g., on a website page for online content).

5. Retain Records for the Required Period

Records must be maintained for as long as the content is commercially available, plus five years after the content is removed from distribution. Given that digital content can remain available indefinitely, this effectively means permanent record retention for most producers.

The Custodian of Records Problem

The COR requirement is where most independent producers get stuck. The law requires records to be available at a physical location during business hours. For independent producers, this creates an impossible choice:

This is exactly the problem that COR services like Easy2257 solve. By designating a third-party service as your Custodian of Records, you fulfill the legal requirement without exposing your home address or renting office space.

Penalties for Non-Compliance

Failure to comply with 2257 carries serious penalties:

• First offense: Up to 5 years imprisonment
• Subsequent offenses: Up to 10 years imprisonment
• Forfeiture of content produced in violation

These are federal criminal penalties, not civil fines. The law is enforced by the Department of Justice, and inspections can occur with reasonable notice during business hours.

How to Comply: Step-by-Step

Step 1: Before Production

1. Collect a valid government-issued photo ID from every performer
2. Verify the performer is at least 18 years old
3. Record the performer's legal name, date of birth, and any aliases
4. Have the performer sign a model release that includes their legal name, stage name, and date of birth

Step 2: During/After Production

1. Document the title or identifier of the content produced
2. Record the date of production
3. Record all performers who appeared in the content
4. Cross-reference performer records with content identifiers

Step 3: Record Maintenance

1. Store all records in an organized, indexed system
2. Ensure records are searchable by performer name (including aliases)
3. Ensure records are searchable by content title/identifier
4. Maintain records at the designated COR location
5. Keep records for the duration the content is available + 5 years

Step 4: Display Requirements

1. Include the COR statement (name and address) on all content
2. For websites, include a dedicated 2257 compliance page
3. For physical media, include the statement on packaging

Digital vs. Paper Records

The original 2257 regulations were written for a paper-based world. Today, most producers maintain digital records. While the regulations don't explicitly require paper records, the physical location requirement for the COR creates ambiguity.

Best practice: Maintain digital records (for efficiency and backup) while ensuring your designated COR can produce physical copies on demand if required during an inspection. Modern compliance platforms handle this by storing all records digitally with the ability to generate printed reports.

Common Mistakes

1. Not collecting ID before production. The law requires age verification *before* production begins. Collecting IDs after the fact doesn't protect you.

1. Accepting photocopies or photos of IDs. While digital ID verification is increasingly accepted, you should use a verification system that authenticates the document, not just captures an image.

1. Incomplete cross-referencing. Your records must link performers to specific content. Having a folder of IDs without tying them to productions is not compliant.

1. Using your home address as the COR location. While technically compliant, this exposes your home address publicly. Use a COR service or registered agent.

1. Not updating records when content is redistributed. If you license content to a distributor, records still need to be maintained.

1. Forgetting the display requirement. Every piece of content needs the COR statement. This includes content on tube sites, clip sites, and social media platforms.

OnlyFans and 2257

OnlyFans and similar platforms have their own 2257 compliance processes for content uploaded to their platforms. However, as the primary producer, you are independently responsible for maintaining your own 2257 records regardless of what the platform does.

OnlyFans' compliance covers their obligations as a secondary producer/distributor. Your obligations as the primary producer are separate and non-transferable.

If you produce collaborative content on OnlyFans (content with other performers), you need your own 2257 record-keeping system.

Getting Started with Easy2257

Easy2257 handles the entire 2257 compliance workflow digitally:

1. Create a production and add scenes
2. Invite talent via secure links — they complete ID verification and sign documents on their own phone
3. ID verification uses bank-grade document authentication and facial comparison
4. Documents are signed electronically with legally-binding digital signatures
5. Records are stored securely with AES-256 encryption on AWS infrastructure
6. COR service is included with all paid plans — we become your designated Custodian of Records

Get started free or view pricing to learn more about our COR service.

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