The Short Answer
Yes — if you produce content with other performers that depicts "actual sexually explicit conduct" as defined by 18 U.S.C. § 2257, you are a primary producer and must maintain age verification records for every performer.
OnlyFans' own compliance program covers their obligations as a distributor/platform. It does not replace your obligations as the producer.
What Counts as "Actual Sexually Explicit Conduct"?
The statute defines this as:
- Sexual intercourse (including genital-genital, oral-genital, and anal-genital)
- Bestiality
- Masturbation
- Sadistic or masochistic abuse
- Lascivious exhibition of the genitals or pubic area
Solo content (featuring only yourself) generally doesn't trigger 2257 obligations because the law's record-keeping requirements focus on verifying the age of performers — and you presumably know your own age.
Collaborative content involving two or more performers in sexually explicit conduct requires full 2257 compliance by the producer.
What OnlyFans Does (and Doesn't Do)
OnlyFans requires ID verification for all creators as part of their platform onboarding. This covers their obligations as a secondary producer/distributor. However:
- OnlyFans does not maintain records on your behalf as a primary producer
- Their verification covers the account holder, not necessarily every performer in collaborative content
- Your independent obligation to maintain 2257 records exists regardless of the platform's policies
What You Need to Do
If you shoot collaborative content:
- Verify the identity of every performer before shooting
- Collect government-issued photo ID from each performer
- Maintain an index cross-referencing performers to content
- Designate a Custodian of Records (COR) responsible for your records
- Include a 2257 compliance statement on or near your content
The COR Problem for Creators
Most OnlyFans creators work from home. Designating yourself as the COR means publishing your home address as the location where records can be inspected. This is a significant safety concern.
A COR service like Easy2257 solves this: we become your designated Custodian of Records, your talent completes verification through our platform, and our address goes on your content — not yours.
The Bottom Line
If you're an OnlyFans creator producing content with other performers, 2257 compliance isn't optional — it's federal law. The penalties for non-compliance (up to 5 years imprisonment) make it worth getting right.
Get compliant today — our Producer plan starts at $39.95/scene and includes full COR service.
This article is for informational purposes only and does not constitute legal advice.