In March 2025, Utah was the first state to pass an App Store Accountability Act (ASAA), enacting SB 142. Since then, Texas, Louisiana, California (in modified form as the Digital Age Assurance Act), and Alabama have passed similar legislation, and several other states have active proposals.
The ASAAs have faced swift and comprehensive legal pushback. Texas' law, the first scheduled to take effect on January 1, 2026, was enjoined on First Amendment grounds. Utah's faces its own challenge: a trade group sued Utah in federal court to block SB 142, raising many of the same constitutional concerns that caused the Texas injunction.
In turn, legislators are now responding. On March 18, Utah Governor Spencer Cox signed HB 498 into law, amending his state's ASAA to account for constitutional claims against SB 142.
Key changes include:
- Pre-installed applications: The amendment adds a new definition of "pre-installed application," covering browsers, search engines, and messaging apps bundled onto devices at purchase, and extends age verification and parental consent obligations to now cover those applications.
- Significant change definition narrowed. The amendment removes "material changes to functionality or user experience" from the definition of “significant change.” The trigger for renewed consent is now limited only to data collection changes, age rating shifts, and new monetization features.
- Developer-specific controls. Developers may now affirmatively request that app stores block minor accounts from downloading or purchasing their apps — a new opt-in tool for developers who want to self-restrict access.
- Tightened data use restrictions. Age category data received through app store channels may now only be used by developers for three enumerated purposes: enforcing age-related restrictions, complying with law, or implementing safety features. Sharing that data with any third party is prohibited. This aligns with a February 2026 FTC policy statement declaring that narrow, purpose-limited age data collection is the expectation federally.
- Streamlined age verification. The amendment removes the prior provision allowing Utah's Division of Consumer Protection to establish alternative age verification methods through rulemaking and repeals the Division rulemaking section entirely. Instead, it requires commercially available methods that are "reasonably designed to ensure accuracy," with parental attestation required for minors.
These refinements aim to shore up the law against current and future First Amendment challenges, particularly by narrowing obligations and elements that could be considered to compel speech and tightening the scope of what triggers parental re-consent.
While several other states consider similar legislation, the ASAA amendment era has begun in earnest.
Key Takeaways For App Developers
- Developers will be able to ask app stores to block minors from their apps entirely. For apps not designed for minors, this is a clean safe harbor worth consideration.
- Age category data has exactly three permitted uses: age restrictions, legal compliance, and safety features. If you are using it for any other purpose, stop yesterday.
- Routine UX and feature updates no longer trigger renewed parental consent. Only changes to data collection, age ratings, or monetization clear that bar.
- Expect many more changes to this law and others. Trade groups are still bringing challenges, legislatures are proposing amendments, and app stores are developing policies, so the landscape shifts are sure to continue.
- Monitor the Utah litigation closely. How courts respond to a law expressly amended in response to constitutional concerns will set the tone for all ASAAs going forward.

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