Per the announcement there's now a "18 U.S.C. §2257 Record-Keeping Requirements Compliance Statement" page with the following prohibition
"Civitai does not permit the upload of any content that contains real (non-AI) individuals, whether public or private figures."
As far as I can tell, there is no exception for the LoRA trainer. This is kinda a big problem for me since for my 100th (distinct) LoRA I was going to do something (not a person) with all public domain content and I would publish the training data. Now I have no idea what to do there.
Also I've got no idea who wrote the announcement, or the comment replies from accounts claiming to be staff, since that same thing starts with the line
"Civitai is not the producer (whether primary or secondary as defined in 18 U.S.C. §2257) of any content posted on the platform." so it clearly can't be real (and "We're producers except for when that makes it illegal"-esque reading that it only applies to "producer" under that statute is ridiculous, especially with the parenthesis ordering, not least of all because the statute defines "produces" rather than "producer")
I'd say I hope this be resolved soon, but from my past experiences of informing the staff their legal writing was (at best) overly ambiguous I can't be. I previously filed a suggestion (via official forum for those) they clean up the wording on the restriction on real people, because it has entirely different wording and details (and implications from those details!) between the three different places it's listed, none of which are actually part of the ToS (Come to think of it this 18 2257 thing or the prohibition itself isn't remotely referenced in the ToS either). The suggestion was marked private with no reply, indicating it was seen, but deliberately ignored. Civitai is too big to have such messy wording in critical rules.
Edit May 12 2025: I've used every venue I have to ask if this is actually how the text in that disclaimer is supposed to be read. In addition to this article, I've asked in the comments for the announcement that brought this. I've asked a moderator as a reply to a comment by that moderator clarifying another part of the new ToS changes. I've submitted a bug report about how the trainer's instructions act like training on real people is still allowed. I've even DMed the admin asking if that is how it's meant to be read. None of them have gotten a reply (even though the DM system has told me the admin DID open the message). I wasn't even asking for it to be altered, just asking if that's how the rule is supposed to be read.