Verified Circulation Guide

For the Audit

All circulation data claimed on ABC Publisher’s Statements must comply with all ABC bylaws, rules, guidelines and policies and be supported by auditable documentation.

Bylaw 2.8 Publisher Duty to Install and Maintain Records states that it is the responsibility of the publisher (ABC applicant or member) to maintain all records necessary for audit, ensure that the records are accurate, and provide those records to the ABC auditors in a timely manner. This bylaw also states:

“Publisher members may sell copies in quantities through agents, distributors and wholesalers, independent contractors or other third parties, however, the publisher shall remain responsible for the accuracy, completeness and accessibility of the records maintained by such organizations…”

For verified circulation, the records made available to the auditor must support the five primary elements of the transaction:

1. The copies claimed as verified were actually distributed to recipients.
2. The recipient (individual or public place) was served at least two consecutive issues.
3. Opt-out requirements were met for:
   • Public Place – Waiting room
   • Individual Use – List-type sources
4. Opt-in requirements were met for:
   • Public Place – Airline and Hotels (written agreements)
   • Individual Use – Individually Requested (request from recipient)
5. Circulation was properly classified in the Publisher’s Statements.
   • In general
   • By distribution location or source (Pars. 6A and 6B classifications)

The ABC auditor must be granted access to all documentation supporting the five primary elements of verified transactions. During the audit, however, the ABC auditor may also determine additional information or documentation is necessary to complete their validation of this circulation.

The records necessary for the ABC audit of verified circulation include, but are not limited to:

• Proof that copies were printed—may include print orders, print invoices and proof of payment to printer.
• Source of names—through third-party verification of list sources.
• Proof that opt-out notices were mailed—including mailing or distribution records (via the USPS) and responses of opt-outs received.
• Copies of written agreements for all hotel and airline programs.
• Original orders—for all individually requested copies (direct mail forms, telemarketing scripts, online orders, etc.).
• Proof that magazine copies were mailed—either via the USPS or alternative delivery source such as Federal Express, UPS, etc.
• Proof that a minimum of two consecutive issues were served to each individual and public place recipient.

If a magazine chooses to disclose in the explanatory paragraph that payments were received from a sponsor for verified circulation, documentation must be provided to confirm the payment was reported net of all considerations.

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