Mastercard AN 5196 and Visa VIRP: What Adult Content Producers Need to Know

The Card Networks Are Now Watching Adult Content Producers

For years, 18 U.S.C. § 2257 was the compliance framework every adult content producer knew. Verify performer ages, maintain records, designate a Custodian of Records. Federal law, federal penalties.

Then the card networks got involved.

Mastercard's Amendment Notice 5196 (AN 5196) and Visa's Integrity Risk Program (VIRP) introduced a parallel compliance layer that most producers have never heard of — but that every producer who accepts card payments is subject to. The requirements go beyond 2257 in ways that catch producers off guard.

Here's what they actually require, why it flows to you as the producer, and how Easy2257 handles all three automatically.

What Are AN 5196 and VIRP?

In 2021, Mastercard and Visa came under pressure following reporting about non-consensual content on major adult platforms. Both networks responded by tightening requirements for "adult content merchants" — any business that accepts card payments for sexually explicit material.

Mastercard AN 5196 (Amendment Notice 5196 to the Mastercard SPME) added specific requirements for adult content merchants: written performer consent, a depicted-person removal portal, and monthly acquirer compliance reports.

Visa VIRP (Visa Integrity Risk Program) is Visa's risk classification framework for high-risk merchant categories. It mirrors AN 5196's requirements under VIRP §3.1 and SPME §9.4.1.

These are not laws. They're network rules. But violating them means losing the ability to accept Visa or Mastercard — which effectively means losing the ability to operate.

The Three Requirements

1. Written Performer Consent (Model Releases)

Both programs require written consent from every performer before content is published. Not verbal. Not "she agreed on camera." A signed, written model release covering the specific content being produced, before it goes live.

Under Mastercard AN 5196, this requirement is explicit: merchants must obtain and retain written consent for every performer depicted in content they sell or distribute, prior to publication.

This is where a lot of producers fall short. Filming with someone who verbally agrees, then publishing — that's not AN 5196 compliant. The signed release has to exist first.

What Easy2257 does: Every scene requires a performer-signed model release as part of the workflow. Talent signs digitally through the platform. A scene cannot be closed — and the producer cannot complete attestation — until all talent have signed. Model releases are stored in AWS S3, SHA-256 hashed, and included in full compliance archives.

For solo creators, the producer attestation on content log entries serves as the consent record for self-produced content.

2. Depicted-Person Removal Portal

AN 5196 and VIRP require merchants to operate a publicly accessible mechanism through which any depicted person can request removal of their image from content. This isn't just a DMCA takedown process — it's a proactive, unauthenticated intake portal tied to enforceable SLA deadlines.

The deadlines stack:

The TAKE IT DOWN Act, signed in 2025, made the 48-hour NCII deadline a federal criminal matter. Mastercard AN 5196 incorporates it by reference. Missing the 48-hour window isn't just a card network violation — it's potential federal criminal exposure.

What Easy2257 does: The removal portal at easy2257.com/report/removal is publicly accessible without login. Anyone depicted in content associated with a producer account can submit a request, specify the type, and receive acknowledgment. The producer dashboard shows all active requests with countdown timers. Email warnings go out as deadlines approach. Breached requests are automatically escalated to Easy2257 admin. CSAM requests are immediately redirected to NCMEC.

3. Monthly Acquirer Compliance Reports

This is the requirement most producers have never heard of — and the one most likely to put them in violation without knowing it.

Both AN 5196 and Visa VIRP require adult content merchants to submit monthly compliance reports to their payment acquirer. These reports summarize:

• Flagged content incidents for the period
• Removal requests received and actioned
• SLA compliance (requests that met or missed their deadline)
• Model releases collected
• Scenes and content logs finalized
• New ID verifications completed

The requirement doesn't disappear in quiet months. If nothing happened last month, you still submit a nil report confirming that. The monthly filing itself is the compliance act.

Most producers have no idea this requirement exists. Their payment acquirers do.

What Easy2257 does: On the 2nd of every month, Easy2257 auto-generates an acquirer report for every active producer covering the previous month's activity. Reports are stored as PDF and JSON, both SHA-256 hashed, emailed to the producer, and downloadable from the dashboard under Acquirer Reports. Months with no incidents produce a nil report — watermarked as such — so the filing obligation is always met.

Why This Flows to Producers, Not Just Platforms

The most common misconception: "This is a platform problem. OnlyFans or my payment processor handles it."

They don't.

AN 5196 and VIRP obligations flow through to individual merchants — producers and creators who accept card payments for content. Your payment processor operates under these network rules. You operate under your merchant agreement. The accountability chain runs all the way to you.

If a producer violates AN 5196 requirements and their processor flags it, the consequence isn't a warning — it's losing the ability to accept Visa and Mastercard. That means losing Stripe, PayPal, and effectively every payment method customers expect to use.

The Gap Most Producers Have Right Now

Before Easy2257 built these features, a typical producer compliance picture looked like this:

✗ Verbal consent only — no signed model release before publication

✗ No removal portal — "DM me to report an issue" is not AN 5196 compliant

✗ No monthly reports — acquirer has no record of compliance monitoring

All three requirements missing. All three now built into Easy2257.

Easy2257 Is the Only Platform That Covers All of This

2257 compliance alone is no longer enough. The card networks have added requirements that most compliance platforms haven't built.

Easy2257 now satisfies:

• Every requirement in 18 U.S.C. § 2257 and 28 CFR Part 75 — federal records law
• Mastercard AN 5196 — performer consent, removal portal, monthly reports
• Visa VIRP — same requirements under VIRP §3.1 and SPME §9.4.1
• TAKE IT DOWN Act (2025) — 48-hour NCII enforcement with automatic NCMEC referrals for CSAM

Not a checklist you manage manually. A system that runs automatically.

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