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Actively Compliant Secondary Producer

Record-Keeping
Statement.

In compliance with 18 U.S.C. § 2257 and 28 C.F.R. Part 75, Scroll maintains this statement as a secondary producer. All content on this platform was created by third-party primary producers who bear full record-keeping responsibility.

Legal basis: As defined under 28 C.F.R. § 75.1(c)(2), a secondary producer is any person who produces, assembles, manufactures, publishes, duplicates, reproduces, or reissues a book, magazine, periodical, film, videotape, digitally- or computer-manipulated image, picture, or other matter that contains a visual depiction of actual sexually explicit conduct but who is not the primary producer of the visual depiction. Scroll qualifies strictly as a secondary producer.
§ 2257
Fully Compliant
Secondary
Producer Classification
18+
Verified Performers Only
Governed by U.S. Federal Law Effective Immediately Inspectable Upon Request
28 C.F.R. § 75.1(c)(2)

Our Producer Classification

Scroll operates exclusively as a secondary producer. We do not create, direct, produce, or commission any sexually explicit content. All such content displayed on this platform originates from third-party primary producers.

What Scroll Does Not Do

  • Hire, contract with, or manage performers
  • Direct, produce, or film any explicit content
  • Pay performers for sexual performances
  • Own or operate any production studio or facility
  • Create original sexually explicit visual depictions

What Scroll Does Do

  • Display content uploaded by verified third-party primary producers
  • Require primary producers to confirm 2257 compliance upon upload
  • Accept content removal requests related to compliance
  • Cooperate fully with lawful inspection requests
Exemption under 28 C.F.R. § 75.6: Secondary producers who did not hire, contract with, or otherwise manage the performers depicted in the visual content are exempt from maintaining the full performer identity records required of primary producers, provided the statement required by 28 C.F.R. § 75.8 is displayed and the secondary producer is not otherwise a primary producer of any visual depiction on the site.
28 C.F.R. § 75.5

Records & Inspection

Records verifying performer ages are maintained by the primary producers of each visual depiction. As a secondary producer, Scroll maintains records of its secondary producer status and the identity of primary producers whose content appears on the platform.

What Records Exist

Records maintained include: the secondary producer status declaration, a register of third-party primary producers whose content appears on the platform, and the location of primary producer custodian information.

Where Records Are Kept

All records relating to Scroll's compliance as a secondary producer are maintained at our registered compliance address listed in the Custodian section above. Records are available for inspection upon lawful written request.

Requesting Inspection

Inspections may be requested during business hours (Mon–Fri, 9AM–5PM EST). Requests must be submitted in writing to the designated custodian. We will respond and schedule access within a commercially reasonable timeframe.

Primary producer records: Records verifying the age and identity of performers depicted in visual content on this platform are maintained by the primary producers of each such depiction — not by Scroll. To access performer identity records, contact the primary producer listed in the content's attribution or metadata. Primary producers are required by law to make these records available under 28 C.F.R. § 75.5.
Compliance Process

How We Stay Compliant

Our compliance process runs at every stage — from onboarding content producers to ongoing monitoring and enforcement. Here's what that looks like in practice.

01
Producer Verification
Every content producer who uploads material to Scroll must affirm, at the point of upload, that they are a compliant primary producer who maintains all required 2257 records. Unverified accounts cannot upload explicit content.
02
Compliance Affirmation at Upload
Each upload triggers a mandatory declaration: the uploader confirms they are the primary producer, that all performers were 18+ at time of production, and that records are maintained and available for inspection.
03
Custodian Referral Chain
We maintain a reference to each primary producer's custodian of records. If an inspection is requested for content hosted on our platform, we can direct inspectors to the appropriate primary producer.
04
Removal Upon Non-Compliance
Any content found to be in violation of 2257 requirements — including content where the primary producer cannot produce required records — is removed immediately upon discovery or notification.

Age Verification

All performers depicted in content on Scroll must have been 18 years of age or older at the time of the production of the visual depiction, as verified and recorded by the primary producer.

Record Accessibility

Primary producers are contractually obligated to retain and make available all performer records required by 28 C.F.R. Part 75 for the duration required by law (no less than 7 years).

Zero Tolerance Policy

Scroll maintains a strict zero-tolerance policy for content depicting minors in any sexual context. Such content is permanently banned, immediately reported to the National Center for Missing & Exploited Children (NCMEC), and subject to law enforcement referral.

Content Reporting

Report Non-Compliant Content

If you believe any content on Scroll violates 18 U.S.C. § 2257, depicts a minor, or was produced without proper age verification, please report it immediately. We take every report seriously and investigate promptly.

Flag on Platform

Use the report button on any content page to flag a post for compliance review. Reports are reviewed by our moderation team within 24 hours.

Email Compliance

Send detailed reports including content URLs, reason for concern, and any supporting information to 2257@scrollto.com.

Report to NCMEC

If you believe content depicts a minor, report directly to the NCMEC CyberTipline at CyberTipline.org in addition to contacting us.

Response commitment: All 2257 compliance reports are triaged within 4 business hours. Content under review may be immediately suspended pending investigation. Confirmed violations result in permanent removal, account termination, and where legally required, referral to law enforcement.
Common Questions

Frequently Asked Questions

18 U.S.C. § 2257 is a United States federal law that requires producers of sexually explicit content to verify the age of every performer depicted and to maintain records of that verification. The law is implemented by 28 C.F.R. Part 75, which sets out the specific requirements for what records must be kept, where they must be maintained, and how they must be made available for inspection.
A primary producer is the entity that actually creates, films, or produces the sexually explicit visual depiction — they hire and work directly with performers. A secondary producer is an entity that publishes, distributes, or displays content produced by others without being involved in its original creation. The law places the record-keeping burden primarily on primary producers, while secondary producers must display compliant labelling and maintain certain reference records.
Age verification records are maintained by the primary producer of each piece of content — not by Scroll. Each piece of content on the platform that falls under § 2257 includes labelling that identifies the primary producer or their custodian of records. You can contact that primary producer directly to request inspection of their records during their stated business hours.
Every content producer who uploads material to Scroll must affirm at the point of upload that all performers depicted were 18 or older at the time of production, and that the required age verification records are maintained and available. Accounts found to have violated this affirmation are permanently banned and reported to appropriate authorities. Scroll also maintains a zero-tolerance policy for content depicting minors in any sexual context.
Submit a written inspection request to our Custodian of Records at 2257@scrollto.com or via the mailing address listed in the Custodian section of this page. Include your name, contact information, the nature of your request, and any specific content or records you wish to inspect. We will respond within a commercially reasonable timeframe and schedule access during business hours (Monday–Friday, 9AM–5PM EST).
This statement applies to any visual depictions of actual sexually explicit conduct as defined in 18 U.S.C. § 2256(2)(A) that appear on the platform. Content that does not meet the statutory definition of sexually explicit conduct under federal law is not subject to 2257 record-keeping requirements, though all content on Scroll must comply with our Terms of Service regardless.