Utah’s governor recently signed the first law which puts age restrictions on app downloads. The law (the App Store Accountability Act, SB 142), was signed yesterday (Wednesday, April 26, 2025). We anticipate that the law may be challenged, similar to NetChoice’s challenge to the Utah Social Media Regulation Act and other similar state laws.
Once in effect, the law will apply to both app stores and app developers. There are various effective dates – May 7, 2025, May 6, 2026 and December 31, 2026— as outlined below. Among its requirements are the following:
- Age Verification: Under the new law, beginning May 6, 2026, app stores will need to verify the age of any user located in the state using “commercially reasonable” measures. Prior to that time, the Division of Consumer Protection will need to create rules that outline how age can be verified. Also starting May 2026, app developers will need to verify age categories “through the app store’s data sharing methods.” Age categories are children (users under age 13), younger teenagers (users between the ages of 13 and 15), older teenagers (users aged 16 or 17), and adults (users aged 18 and up).
- Parental Consent/Notification: Beginning May 6, 2026, app stores will need parental before a minor can download or purchase an app, or make in-app purchases. Consent is to be obtained through a parental account that links to the child’s account. At the same time, app developers will need to verify that app stores have parental consent for minors’ accounts. They also have to notify app stores of any significant changes to their apps. When this happens, the app stores will need to notify users and parents of these changes and get parents’ renewed consent. App stores will also need to notify developers any time parents revoke their consent.
- Contract Enforcement: Under the new law, beginning May 6, 2026, app stores will not be able to enforce contracts against minors unless they already have consent from the minors’ parents. This applies to app developers as well, unless they verify that the app store has consent from the minor’s parents.
- Safe Harbor: The new law contains safe harbor provisions for app developers. Developers won’t be responsible for violating this law if they rely in good faith on information provided by the app store. This includes age information as well as confirmation that parents provided consent for minors’ account. For the safe harbor to apply, developers also need to follow the other rules set out for them by the law (described above).
Putting it into Practice: While we anticipate that this law will be challenged, it signals that states are continuing their focus on laws relating to children in the digital space. This is the first law that is focused on app stores, but we expect to see more in the future.
James O’Reilly contributed to this post.