Updated November 2026 · Written and maintained by the Progression Agency strategy team
A date of birth entered on a sign-up screen says fifteen, and from May 6, 2027 that is not the number your app is supposed to act on. App developers in Utah now read a different field: the age category the app store returns under the App Store Accountability Act, as amended by H.B. 498 in 2026. This page lays out the four categories in a grid, one row for each behavior your app controls, then what the work costs. Progression is based in New York, works with Utah product teams remotely, and offers on-site sessions on request.
On this page · 11 sections
- Fifteen on a sign-up screen
- What app developers in Utah have to change before May 6, 2027
- The grid: four categories, one row per behavior
- Significant changes that restart the conversation
- Parental consent, read through the store
- Where the safe harbor stops
- Who can bring a claim
- Apps already on the phone
- What does building the grid into an app cost?
- A release brief for your product lead
- Related services and guides
Outside the niche A Provo company whose app has no minors in its market still has a significant-change rule to think about each time it adds ads or in-app purchases; our app development page covers the rest of the build.
The sign-up card and the grid settings are illustrative examples: the Act does not prescribe what an app does for each category, and every setting in the grid is a choice a product team makes. The Act is stated as amended by H.B. 498 in 2026, as of November 2026. Ask counsel how it applies to your app and whether the law has changed. Nothing here says that any app complies.
Fifteen on a sign-up screen
A user types a birth year that makes her fifteen. The app store, which has verified her account, returns a different story: the account is a minor account with a parent attached, and consent has been recorded. The product manager looks at the two numbers and has to decide which one the app believes.
The card shows a small screen with a large question under it. Under the Act, the store’s category is the field the developer verifies against, and the typed date is a signal that the store may not share. In the rows of the grid that matter, the store’s category wins.
What app developers in Utah have to change before May 6, 2027
The App Store Accountability Act is Utah Code Chapter 13-76. It was enacted as S.B. 142 in 2025 and amended by H.B. 498 in 2026. The amendment sets four age categories: child, under 13; younger teenager, at least 13 and under 16; older teenager, at least 16 and under 18; and adult, 18 and over.
Beginning May 6, 2027, a developer must verify through the app store’s data sharing methods the age category data of account holders located in Utah, and for a minor account whether verifiable parental consent has been obtained. The developer must also notify app stores of a significant change to the app. The text of the section is at Utah Code 13-76-202.
The duties fall on the developer, which the Act defines as a person who owns or controls an app made available through an app store in the state. Whether your company fits that definition, and what the Act means for your app, is a question for counsel.
- Verify age category data through the store, not through a field the user types.
- For a minor account, verify whether verifiable parental consent has been obtained.
- Tell the store about every significant change.
- Use the category data only for the purposes the Act lists.
- Do not share age category data with any person.
The grid: four categories, one row per behavior
The Act sets the categories and the developer’s duties. It does not say what an app should do for each category. What your app does is a design choice, and each choice below is a developer-created restriction or default that the Act allows the app to implement with the category data.
| Behavior | Child (under 13) | Younger teenager (13 to under 16) | Older teenager (16 to under 18) | Adult (18 and over) |
|---|---|---|---|---|
| Messaging | Off, or with approved contacts only | Approved contacts by default | Open, with blocking tools on by default | Open |
| In-app purchases | Off; the store requires parental consent for a minor’s purchases | Off until consent is on record | Off until consent is on record | On |
| Data collected | The least the app needs to work | The least the app needs to work | The least the app needs to work | As the privacy policy describes |
| Data shared | None with outside parties | None with outside parties by default | None with outside parties by default | As the privacy policy describes |
| Defaults at first launch | The most protective set | The most protective set | A protective set the parent may change | The standard set |
| When to request consent status | Download, purchase and each significant change | Download, purchase and each significant change | Download, purchase and each significant change | Not applicable |
| Your build | A written scope that fills in the grid for your app | Quoted after a written scope; typical published bands are in the price section | Each row priced as its own line | Each row priced as its own line |
Lowest category wins, at first implementation
When a developer first implements a safety-related feature or default of its own, the Act says to use the lowest age category indicated by the app store’s data or by age data the developer collected itself. If the store says older teenager and your own sign-up says child, the default follows child. A parent may customize restrictions and content settings for a user in a minor account after those defaults are set.
Asking for the category again
A developer may request age category data no more than once during each 12-month period, to check its accuracy or continued account use within the verified category. The Act also lists reasonable suspicion of account transfer or misuse, and the creation of a new account with the developer, as occasions to ask.
- Store the date of each request and the reason.
- Count requests per account so the 12-month limit is visible.
- Do not poll the store on every launch.
- Treat the answer as data to use for the purposes the Act lists, and nothing else.
Who does what, store or developer?
The Act splits the work. The store verifies the account holder’s age category, collects consent and shares the result. The developer reads the result and acts on it.
| Step | App store provider | Developer |
|---|---|---|
| Age category | Requests it and verifies it with commercially available methods | Verifies it through the store’s data sharing methods |
| Minor accounts | Affiliates the account with a parent account and obtains verifiable parental consent | Verifies whether consent has been obtained |
| Significant change | Notifies the account holder and, for a minor account, the parent, and obtains renewed consent | Notifies the store |
| Sharing data | Shares only as the chapter requires or as the law requires | May not share age category data with any person |
What should a team do first?
Map every place the app asks a user’s age, then decide which of those moments should read the store’s category instead.
- List every sign-up, settings and purchase screen that touches age.
- Mark which fields come from the user and which come from the store.
- Replace typed ages with the category where the Act’s duties apply.
- Review the list with counsel before changing the screens.
Significant changes that restart the conversation
The Act defines a significant change as a material modification to an app’s terms of service or privacy policy that changes the categories of data collected, stored or shared, alters the age rating or content descriptions, introduces in-app purchases where there were none, or introduces advertisements where there were none.
A developer must notify app stores of a significant change, and may request age category data or parental consent when implementing one. A release checklist that asks four questions is cheap to build and easy to run.
| Question | If yes |
|---|---|
| Does this release change what data the app collects, stores or shares? | Tell the store, and ask counsel about the policy change |
| Does it change the app’s age rating or content descriptions? | Tell the store before release |
| Does it add in-app purchases to an app that had none? | Tell the store and plan for renewed consent on minor accounts |
| Does it add advertisements to an app that had none? | Tell the store and review the ad settings by category |
Does every release count?
No. The definition is about a material modification to terms of service or a privacy policy of the kinds listed. A bug fix that changes none of them is not on the list. Ask counsel about borderline releases.
Parental consent, read through the store
For a minor account, the developer verifies through the store’s data sharing methods whether verifiable parental consent has been obtained. The store collects it: the Act has the store give a parent a disclosure about the app and obtain an affirmative choice before a minor downloads or buys an app or makes an in-app purchase.
Do not rebuild consent inside the app. Read the status the store returns, act on it and record when you read it. A developer also may not enforce a contract or terms of service against a minor unless it has verified through the store’s methods that consent was obtained.
- Read consent status from the store at each point the Act allows you to ask.
- Keep the status with the account record, with the time it was returned.
- Handle revocation: the store notifies the developer when a parent revokes consent.
- Show a clear message when an action is blocked pending consent.
Shipping an app into Utah next year?Send us your sign-up flow and your data map. You get a free proposal from app developers in Utah with the grid filled in for your app.
Where the safe harbor stops
Section 13-76-402 says a developer is not liable for a violation of the chapter if the developer demonstrates that it relied in good faith on age category data received through the store’s data sharing methods and on the store’s notification that verifiable parental consent was obtained, and complied with Section 13-76-202.
The same section says the safe harbor applies only to actions brought under the chapter and does not limit a developer’s liability under any other applicable law. Whether your practices meet the terms is for counsel.
Does good faith reliance need a record?
It helps to have one. Keep the data the store returned, the time you read it and the action you took.
- Log each category and consent status you receive.
- Log what the app did as a result.
- Keep logs in a place counsel can reach.
- Do not store more than the Act’s purposes need.
What does the developer have to show?
That it relied in good faith on the store’s data and that it followed the developer requirements. Keep logs that show both.
Who can bring a claim
Beginning May 6, 2027, only a minor, or the parent of that minor, who has been harmed by a violation of the developer provisions on contracts, the parental consent disclosure and sharing age category data may bring a civil action against a developer. A court shall award a prevailing parent the greater of actual damages or $1,000 for each violation, reasonable attorney fees and litigation costs.
We make no prediction about whether such claims will be brought. Questions about the law’s status, including any court challenge, go to counsel.
Apps already on the phone
The Act does not require an app store provider or developer to block access to an app an account holder installed before the day the obligations take effect, except where a parent revokes consent or the app makes a significant change. The Act also adds requirements for pre-installed applications.
- List which installed users have accounts created before the date.
- Plan what the app does for them after the next significant change.
- Check whether any of your apps ship pre-installed on devices.
- Ask counsel about a pre-installed build.
What does building the grid into an app cost?
The cost depends on how many of the grid’s rows your app already controls, how many stores you ship in and how much of the account system needs rework. A small app with a few settings is a modest project. An app with payments, messaging and an admin panel is a larger one. Progression quotes after a written scope.
| What is quoted | Published US band | Fits |
|---|---|---|
| Simple app or MVP | $15,000 to $80,000 | An app with a few screens and one sign-up flow |
| Mid-complexity app | $60,000 to $150,000 | Payments, integrations and an admin panel with age-based settings |
| Complex or compliance-heavy app | $150,000 to $500,000 | Several stores, messaging, purchases and detailed data handling |
We list no Utah premium and no price per age category.
A release brief for your product lead
Copy this card into your release template and fill it in before the next planning meeting. Mobile app developers in Utah who start from a completed card can brief a build in an afternoon.
Send the finished card with your sign-up flow. Our app development page describes the build that follows. For the marketing side of a Utah business, see marketing agency in Utah.
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Frequently asked questions
What must app developers in Utah do under the App Store Accountability Act?
Do mobile app developers in Utah have to build their own age check?
Does app development in Utah change if my users are all adults?
Which four age bands does the Act set?
On what date do the developer duties begin?
How often can I ask for a user’s age category?
What counts as a significant change?
What is the safe harbor?
Who may file a claim against a developer?
What does building the grid into an app cost?
Would a team member come to our office in Lehi?
What if my typed date of birth disagrees with the store’s category?
What default should a new safety feature use?
Can I share the age category data with an analytics vendor?
What can I use the category data for?
Does the Act cover apps already installed?
Can a developer ask the store to stop minors downloading its app?
Is the law being challenged in court?
Can your team tell us if our app complies?
Which files help most in the first week?
Shipping an app into Utah next year?Send us your sign-up flow and your data map. You get a free proposal from app developers in Utah with the grid filled in for your app.
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