Again.....Since when are the legal requirements different for that?
There have been prosecutions on those who have taken close up photos of an underage girls snatch with panties pulled tightly against it. No nudity, and not sexually explicit.
Most "solo" sets feature the girl spread eagle and butt naked. Often with toys and or fingers inserted. That is sexually explicit and comes with the very same laws as anything that Max produces.
None of those laws happen to require a model release, 2 I.D.'s, or a pic of the model holding them next to her face.