Results indicated that special needs sexual offenders could be reliably categorized into the offense pathways identified by the self-regulation model. Moreover, no significant differences emerged in the representation of offense pathways between the mainstream and special needs sexual offenders. The largest group of special needs sexual offenders was placed in the approach-automatic group, followed by the approach-explicit group. The findings suggest that sexual offenders with special needs are capable of self-regulation as well as explicit offense planning. A responsive treatment approach should be adopted for special needs offender groups, which focuses on improving self-regulatory behaviors such as problem solving and coping skills. Participants were 16 special needs offenders who were matched to 48 mainstream offenders on the basis of risk level and offense type. All offenders were in residential custodial-based treatment programs for moderate and high risk sexual offenders in Australia. A file review was conducted using a self-regulation checklist that categorized offenders into specific offense pathways. Variables under examination included criminal and social history and offense characteristics. Differences between the two groups were measured using Cohen’s kappa statistic and chi-square analyses. Future research should examine the effectiveness of a responsive treatment approach for special needs sexual offenders. Tables, references