Adult Content Compliance Checklist for Payment Processor Audits
Free template. Not legal advice. This document is a starting point only. Laws differ by state and country, and platform and payment processor rules change often. Have a licensed attorney in your jurisdiction review it before you use it. Using this template does not create an attorney-client relationship with anyone. Released under CC0 1.0 (public domain): copy, change and share it freely, no credit needed.
How to use this checklist: Payment processors, acquiring banks and card networks (including Visa and Mastercard rules for adult content merchants) expect adult websites and creators to show how they verify ages, collect consent, review content and handle complaints. Use this checklist to prepare for a merchant review, onboarding or annual audit. Replace every item in [BRACKETS] and keep evidence for each line.
Business details
| Legal business name | [PRODUCER LEGAL NAME] |
| Business address (street, no P.O. box) | [PRODUCER ADDRESS] |
| Websites covered | [PLATFORMS] |
| Person responsible for compliance | [COMPLIANCE CONTACT NAME AND TITLE] |
| Date of this review | [REVIEW DATE] |
1. Written policies (signed and dated)
| # | Policy | Have it | Evidence |
|---|---|---|---|
| 1 | Content moderation policy and procedure (who reviews, how much, before publishing) | [ ] | [FILE NAME] |
| 2 | Performer age, ID verification and consent procedure | [ ] | [FILE NAME] |
| 3 | Complaint and content removal policy, with timeframes and appeals | [ ] | [FILE NAME] |
| 4 | Procedure for suspected child sexual abuse material, non-consensual or illegal content | [ ] | [FILE NAME] |
| 5 | Law enforcement contact procedure | [ ] | [FILE NAME] |
| 6 | Anti-human-trafficking statement | [ ] | [FILE NAME] |
| 7 | Consumer age verification policy (how visitors prove they are adults, where required by law) | [ ] | [FILE NAME] |
| 8 | Refund, cancellation and billing support policy | [ ] | [FILE NAME] |
| 9 | Privacy policy and terms of service | [ ] | [URL] |
2. Every performer, every production
| # | Check | Done |
|---|---|---|
| 10 | Government photo ID checked in person and copy kept | [ ] |
| 11 | Photo of performer holding ID | [ ] |
| 12 | Signed release with explicit consent to be recorded, to distribution and to download | [ ] |
| 13 | Release dated on or before the production date | [ ] |
| 14 | On-camera consent clip for each production | [ ] |
| 15 | 2257 record indexed by legal name, stage name and title | [ ] |
| 16 | No missing records for anyone visible in published content | [ ] |
3. Content review before publishing
| # | Check | Done |
|---|---|---|
| 17 | 100% of content reviewed by a person before it goes live | [ ] |
| 18 | Content that depicts or suggests minors, non-consent, incest, intoxication, sleep or unconsciousness, violence, bestiality or trafficking is never published, including as role-play | [ ] |
| 19 | Titles, descriptions, tags, thumbnails and ads screened against a prohibited terms list | [ ] |
| 20 | Prohibited terms list kept and updated: [FILE NAME] | [ ] |
| 21 | Records of review decisions kept | [ ] |
4. Website pages (linked from the footer of every page)
| # | Page | Live | URL |
|---|---|---|---|
| 22 | 2257 custodian of records statement | [ ] | [URL] |
| 23 | Contact page with business name and street address | [ ] | [URL] |
| 24 | File a complaint or content removal request | [ ] | [URL] |
| 25 | Copyright and DMCA notice page | [ ] | [URL] |
| 26 | Age verification policy | [ ] | [URL] |
| 27 | Terms of service and privacy policy | [ ] | [URL] |
| 28 | Refund and cancellation policy | [ ] | [URL] |
| 29 | Clear billing descriptor and support contact shown at checkout | [ ] | [URL] |
5. Complaints and removals
| # | Check | Done |
|---|---|---|
| 30 | Every complaint logged the day it arrives | [ ] |
| 31 | Acknowledgement within [1] business day | [ ] |
| 32 | Resolution within [5] business days (check your processor's current maximum) | [ ] |
| 33 | Any person shown in content can request removal, and consent-related content stays down during review | [ ] |
| 34 | Appeals process, with an independent neutral third party for unresolved consent disputes | [ ] |
| 35 | Suspected child sexual abuse material reported to the NCMEC CyberTipline and law enforcement | [ ] |
| 36 | Monthly content violation or zero-incident report filed if your processor requires it | [ ] |
6. Features that raise risk (confirm or disable)
| # | Feature | Status |
|---|---|---|
| 37 | User uploads | [NONE / MODERATED BEFORE PUBLISHING] |
| 38 | Live streaming | [NONE / MODERATED IN REAL TIME] |
| 39 | Messaging between users | [NONE / MONITORED] |
| 40 | Tips, tokens or bidding | [NONE / DESCRIBE] |
| 41 | Escort or classified ads | [NONE] |
| 42 | AI-generated or synthetic sexual content | [NONE / LABELED AND CONSENTED] |
| 43 | Affiliate marketing (affiliates follow your prohibited terms list) | [NONE / DESCRIBE] |
7. Records retention
| # | Check | Done |
|---|---|---|
| 44 | Performer records kept at least 7 years from creation or last update | [ ] |
| 45 | Complaint records kept at least [7] years | [ ] |
| 46 | Records stored securely, with access limited | [ ] |
| 47 | Records can be produced promptly when a processor, bank or authority asks | [ ] |
Reviewed by: [COMPLIANCE CONTACT NAME] Signature: ______________________ Date: ______________