On May 7, 2025, Utah became the first U.S. state to enact a law requiring app store providers and developers to verify users’ ages and obtain verifiable parental consent for minors to download apps or make in-app purchases. Senate Bill 142, the App Store Accountability Act (the “Act”), sets forth specific compliance obligations for both developers and app store providers, including requirements around age-rating, parental disclosures, and data handling practices.

Under the Act, app store providers must request age information during account creation and link minor accounts to verified parent accounts. Developers must confirm age categories and seek parental consent before app use or in-app transactions, particularly when implementing a “significant change” to the app’s content or data practices. Personal age verification data must be encrypted and used solely for purposes outlined in the legislation.

Violations may be enforced as deceptive trade practices by the Utah Attorney General, and starting December 31, 2026, parents may bring private actions for non-compliance—potentially recovering the greater of $1,000 per violation or actual damages, plus attorneys’ fees. Developers acting in good faith on app store-provided data may be shielded from liability.

As similar bills are being considered in states such as California, Kentucky, and West Virginia, app developers may need to prepare for a patchwork of state-specific requirements. Until federal standards are adopted, many may choose to align with the most stringent laws to manage compliance risk.

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