Title 18 Section 2257 Record Worksheet

This model recordkeeping worksheet supports a producer's compliance program for content that depicts sexually explicit conduct. It organizes the individually identifiable information needed to demonstrate performers' names and ages for actual sexually explicit conduct and simulated sexually explicit conduct, including any lascivious exhibition of the genitals or pubic area. Built around the recordkeeping framework in 18 U.S.C. 2257 and 2257A and regulations promulgated under 28 CFR Part 75, it helps a commercial enterprise keep business records ready for inspection at all reasonable times and for commercial distribution in interstate or foreign commerce.

The worksheet captures the unique ID that matches the model release; performers' aliases, stage or professional names; and contact details. It documents the identification document used (for example, driver's license, passport, state ID, birth certificate, or green card), the recognized ID number, the exact name on the ID, and the birthdate. It also tracks how the ID was recorded-photocopy, photograph, digital image, or video-so records are maintained at business premises regularly and in the normal course of business.

Where a guardian signed a model release for a minor, it records the guardian's legal name, address, and phone number. The form ties records to the exact media where depictions appear-book, magazine, video, poster, or website page supporting labeling requirements such as a statement describing where the records may be located. A labeling statement and copy statement that disclose the location of records should be affixed to every copy and include an organization statement with the organization name, title, and business address of the organization's responsible individual.

Compliance context matters. Records are subject to inspection, and inspection refusal, false entry, or failure to comply can be unlawful acts, exposing an organization to civil and criminal liability, criminal penalties, and criminal prosecution by the attorney general, including criminal enforcement by the Criminal Division CEOS. Guidance appears in Order No.

2765-2005, Federal Register 70 FR 29619, 28 CFR Part 75 (e.g., CFR 75.9), the DOJ Justice Manual, and the Criminal Resource Manual. For entities covered by certification under 18 U.S.C. 2257A, the form supports certification of records, the content of certification, timely submission of certification, exemption certification, initial certification, and subsequent certification, and a certificate letter. Foreign producers should take reasonable steps that an ordinary person would conclude to verify age. Related regimes include 18 U.S.C. 1464, the Federal Communications Commission rules, and case law such as American Library Association v. Reno, Connection Distributing Co. v. Reno, and Sundance Associates Inc. v. Reno.

Use cases include studios, web publishers, distributors, photo or film processing vendors, and service providers involved in interstate commerce who must make records available for inspection and disclose the location of records with a clear records location statement and business records location.

Proposal Kit can streamline these business processes for certification and recordkeeping by providing document assembly, automated line-item quoting, an AI Writer to build supporting documents, and an extensive template library that makes preparing consistent, easy-to-use forms faster.

Beyond basic age and identity checks, an effective program defines who is accountable. A chief executive officer or a senior manager responsible should name the organization's responsible person for recordkeeping across sub-entities. The organization responsible for records should issue an organization statement and a statement of records location, and ensure the statement includes the name, title, and business address.

Records must be maintained at business premises, cross-referenced to the matter where each visual depiction appears, and organized for records inspection and inspection of records at all reasonable times. Refusing inspection can trigger an inspection refusal penalty and other consequences.

Certification disciplines the process. Many organizations prepare a form of certification and a statement certifying the collection and maintenance of the records required by Sections 2257 and 2257A. They track records subject to inspection, the content of certifications, and business processes for timely submission, including awareness that deadlines may align with dates like 16-Jun-09 or shift when a federal holiday due date applies.

If authorities provide a 2257A certification email or similar channel, the organization records proof of delivery. Inspection records should document how you maintain individually identifiable records and keep basic evidence justifying the basis for conclusions that performers are adults. Foreign producers' reasonable steps expectations can be met by retaining copies of identification documents and linking them to media uses.

Distribution chains extend risk. A commercial enterprise may work with internet access service, telecommunications service, or hosting providers. While roles vary, labeling statements and a clear records location statement help downstream partners understand who holds records available for inspection.

This aligns with recordkeeping regulations aimed at combating child pornography and visual depictions involving minors, and sits alongside other regimes such as criminal obscenity rules and sex offender registration laws. Coordinated compliance with federal and state tax labor laws and interstate commerce obligations helps reduce civil and criminal liability.

Use cases include a studio designating a senior manager to oversee certifications, a distributor consolidating records cross-referenced to matter IDs across sub-entities, or a platform documenting a labeling statement and business records location for all website page copy.

Proposal Kit can help teams operationalize these requirements by streamlining document assembly, building consistent organization statements and certification letters, generating automated line-item quoting for related services, and using its AI Writer and template library to produce supporting documents and procedures that are easy to use across teams.

To strengthen day-to-day compliance, set clear operating procedures for collecting, updating, and archiving age and identity data tied to each media use. Define how you record web locations consistently when content moves or is syndicated, following current recordkeeping regulations on domain versus per-URL capture. Use unique identifiers to link performer records to each project and media item, and maintain a change log when a performer adopts new aliases or when a work is re-edited. Limit access to individually identifiable information to designated staff and document a handoff process so an on-site custodian can present records maintained at business premises without delay during an inspection request.

Plan for continuity. Establish retention periods that cover the life of distribution plus audit windows, and run periodic spot checks against a sample of titles to verify that identification documents, releases, and the statement of records location remain accurate. Create an incident response playbook that outlines how you correct errors, reissue labels, and notify downstream partners if a labeling statement must be updated. In mergers or investor diligence, complete and current inspection records reduce risk and speed closing, while gaps can trigger escalations or pause distribution.

Proposal Kit can help formalize these workflows. Its document assembly and AI Writer can generate consistent organization statements, policies, and checklists; its extensive template library supports certification letters, cover statements, and cross-reference sheets; and automated line-item quoting helps scope compliance-related services. This makes it easier for teams to standardize how they prepare, review, and package compliance documents so that records subject to inspection are organized, current, and ready at the business location.

Writing the Title 18 Section 2257 Record Worksheet document - The Narrative

How to Build a Legal Contract with Proposal Kit

This video illustrates how to create a legal contract using the Proposal Pack Wizard software. It also shows how to create a proposal with an invoice and contract at the same time.