A Software Company in Utah That Reads the Court’s Standing Order Before the Backlog

Updated November 2026 · Written and maintained by the Progression Agency strategy team

A tenant in Provo types a question about a late rent notice into a chat window at midnight, and the product answers in plain words. Whether that answer is the practice of law, and who regulates the company behind it, is set by the Utah Supreme Court, which runs a legal regulatory sandbox under Standing Order No. 15 until August 2027. A software company in Utah building legal help reads that order as a requirements list before it writes the first ticket. Progression is based in New York, builds for Utah teams remotely, and offers on-site sessions on request.

A tenant’s question at midnight

The chat window below is hypothetical, and it shows no legal content on purpose. A tenant asks a question and the product replies. Everything the product team needs to learn before launch sits behind that reply.

The reply might be information, or it might be a service. The team needs to know which rules that reply sits under, because a product that delivers legal services through technology can fall inside a regulator’s reach. The regulator in this case is the Utah Supreme Court, working through an office it created.

Is a reply information or a service?

That is the question the Court’s order turns on, and it is not one for the product team to settle alone. The team’s job is to describe each reply clearly enough for counsel and the Office to answer it.

• Write down every type of question the product answers.
• Ask counsel which answers might count as legal services.
• Ask the Office of Legal Services Innovation about anything counsel is unsure of.

The Court’s sandbox, as a software company in Utah meets it

Utah Supreme Court Standing Order No. 15 establishes a pilot legal regulatory sandbox, an Office of Legal Services Innovation and the Legal Services Innovation Committee. The order says the Office works under the ultimate authority and control of the Court, with the Committee overseeing it, and that the pilot runs for seven years from the original effective date of August 14, 2020.

Under Section 4.3.2, an entity, for profit or nonprofit, that uses nonlawyer providers or technology platforms, tools or applications to provide legal services that constitute the practice of law falls within the Office’s scope. The order incorporates the definition of the practice of law in Utah Supreme Court Rule 14-802, so the rule is the starting point for any scope question. This page reaches no conclusion about any product.

Who is outside the Office’s scope?

Section 4.3.1 says partnerships, corporations and companies entirely owned and controlled by lawyers in good standing, individual lawyers with an active Utah Bar license and legal services nonprofits offering traditional services are outside the Office’s regulatory scope. A product built for a law firm to use is a different question from a product sold to consumers, and counsel can tell you which one you have.

Whether the order has been narrowed, extended or closed to new applications since its last amendment is not something a software vendor can settle from a page like this one. The Office holds the current answer.

Standing Order No. 15 as a requirements list

Read the order the way a product team reads a spec. Each section has a line for what it says, a line for what the software has to do about it and a line for who on the team owns that work.

Data the Office can ask for

Section 5.2 gives the Office authority to develop specific data reporting requirements, and to increase or decrease them as a provider’s performance and compliance warrant. Every regulated provider also has a proactive duty to report unforeseen risks or harms it learns of. The practical step is to design the product so the likely questions can be answered from its own records, without a rebuild.

• Keep a log of what users asked and what the product replied, within the product’s privacy rules.
• Store the version of each answer template that was live on a given date.
• Build an export a person can run without a developer.

A complaint button that reaches a person

Section 5.3 says the Office will build a way for consumers to complain to it directly, and that complaint information feeds its risk data. A provider that gives users its own path, to a named person who answers, is easier to supervise and easier to trust.

• Put the complaint path where the answer appears, not in a footer.
• Send each complaint to one person and record who handled it.
• Test the path every quarter with an internal message.

Ready for a secret shopper

The same section lists the tools the Office may use to watch the market: market surveys, expert audits, anonymous testing, product walkthroughs and secret shopper tests. A team that assumes every session could be one builds a product that behaves the same for everyone.

• Keep staging and production behavior identical for new users.
• Write replies for a stranger, since any user may be one.
• Keep a walkthrough video of the product current.

What building to the order costs

Most of the work in the table is ordinary product work: reporting fields, a complaint path and logs are features like any other. Published figures for comparable builds run from a typical low to a published high, as shown below. Hosting, licenses and security testing are extra.

Progression quotes after a written scope. Pricing depends on scope and is confirmed in a written proposal, and published prices are subject to change.

Where legal information may turn into legal service

Rule 14-802 defines the practice of law, and the order incorporates it. A software development company in Utah that takes on a legal help product starts here. The line between giving information and giving a service is the one a product team has to map, answer type by answer type, with counsel in the room.

• Explaining what a term on a form means.
• Choosing among options for a particular user’s facts.
• Preparing a document for a user to file.
• Recommending what the user should do next.

These are examples of answer types to bring to counsel, and this page does not say where any of them falls. The product team’s job is to list them, one by one, so counsel has something concrete to assess.

How should a team keep the map current?

Treat the list of answer types as a product artifact. Any change to a reply, a template or a model that produces replies updates the list, and counsel sees the change before it ships.

Owners, investors and the cap table

Section 4.3.3 says disbarred lawyers may not gain or hold an ownership interest of more than 10 percent in an entity authorized under the order. An applicant discloses any material relationship or business partnership with a disbarred lawyer, and whether a disbarred lawyer works in the entity in a managerial role in the direct provision of legal services to consumers.

The section also asks for disclosures about felony criminal history: of anyone holding more than 10 percent, of material business partners, and of people in managerial roles who directly provide legal services. A founder’s data room and the application should tell the same story, so keep one record and use it for both. Questions about what applies to a given person go to counsel.

What belongs in the ownership record?

Names, percentages, roles and dates, kept current as the cap table changes, with a note on who last reviewed it. The point is that no one has to reconstruct the history under a deadline.

What the public can see once you apply

Section 5.6 says the identities of applicants and the applications themselves are presumed to be public information. Applicants may designate specific information as confidential business information under the Government Records and Access Management Act, citing Utah Code 63G-2-305.

What should stay confidential?

Only specific business information the applicant can explain, such as pricing logic or a vendor contract, marked item by item. Counsel decides what qualifies.

• Draft the application so confidential parts sit in their own sections.
• Designate specific items, not whole documents.
• Assume the rest will be read by competitors, customers and reporters.

The order also says data reported to the Office as part of an entity’s regulatory requirements is presumed not to be confidential business information, so the reporting design in the table above should assume the data will not be private.

August 2027 on the roadmap

The pilot lasts seven years from August 14, 2020. Section 8 says the Court will decide at the end whether and in what form the Office continues, and that authorized participants in good standing, with little apparent risk of consumer harm, may continue under the Office or another appropriate body at the Court’s discretion.

A roadmap that runs past August 2027 needs a branch for each outcome. Confirm the current status with the Office before planning, since this page reports the order as amended in 2022.

What should the roadmap branch on?

On the Court’s decision, and on nothing the team has to guess. Each branch lists the features, the reporting and the staffing that change, so the team can switch plans in a week and not a quarter.

• Branch one: the program continues in the same form.
• Branch two: it continues in a changed form.
• Branch three: it ends and the product needs another home.

Who on the team owns each line

A requirement without an owner is a wish. The roles below are the ones a small product team already has, and each takes the lines in the table that fit its work.

Our software development company page covers how a build like this is run, and our SaaS development company page covers subscription products.

Before the application goes in

Six items cover the work that falls to the product team. A team that finishes them has answers ready for the questions the order is likely to raise.

A team in Utah comparing options can also see our app development company in Utah page for the mobile side of a product, and our AEO for law firms page for firms that publish legal content.

Questions to bring to counsel and the Office

The list below is for the first meeting. It contains questions and no answers, because the answers depend on the product.

• Do any of our answer types count as the practice of law under Rule 14-802?
• Are we within the Office’s scope, or outside it?
• Is the sandbox accepting applications today, and in what form?
• Which reporting fields would the Office expect from a product like ours?
• How should we mark the confidential parts of an application?
• What happens to participants after August 2027?

Related services and guides

Pages that sit beside this requirements list:

• Software development company
• SaaS development company
• AEO for law firms

Frequently asked questions