US state App Store Accountability Acts: Texas (SB 2420), Utah (SB 142 as amended by HB 498), Louisiana (Act 185 of 2026) and Alabama (Act 2026-59)

What it requires

In each state, when an individual creates an account, the app store must verify the user's age category (under 13, 13 to 15, 16 to 17, or adult), link a minor's account to a verified parent account and obtain the parent's consent before the minor downloads or buys an app or makes an in-app purchase; Louisiana ties consent to enabling in-app purchases, and Texas requires consent for each individual download or purchase (Tex. Bus. & Com. Code § 121.022). Utah and Alabama define an in-app purchase as a charge for user conduct within an app billed by an app store for virtual currency, digital goods, digital services or other apps. Texas developers must assign an age rating to each app and to each purchase that can be made through it (§ 121.052) and notify app stores before significant changes, including new opportunities to make a purchase or new advertisements (§ 121.053). In Utah, since HB 498, a change to an app's terms of service or privacy policy that first introduces in-app purchases or advertising is a significant change requiring renewed parental consent. In Texas a violation is a deceptive trade practice. In Utah, from 6 May 2027, enforcement is by private action only: a minor or parent harmed when an app store or developer enforces terms against a minor without parental consent, misrepresents the consent disclosure or shares age data may sue, and a prevailing parent receives the greater of actual damages or $1,000 per violation (§ 13-76-401). In Louisiana the attorney general may seek civil fines of up to $10,000 per violation after a 45-day notice-and-cure period. In Alabama knowing or reckless violations are deceptive trade practices, and the attorney general, who has exclusive jurisdiction, may collect up to $7,500 per violation; accounts existing on 2 October 2026 must be verified before 1 October 2027.

Why it bears on this field

Coin bundles, passes and episode unlocks bought through an app store's billing system are in-app purchases under the Utah and Alabama definitions, so for a user identified as a minor they fall within the parental-consent requirement; Texas requires consent for each individual purchase, and Louisiana ties consent to enabling the purchase function. The statutes reach users under 18, not only under 13. In Texas each purchasable item needs its own age rating, and a change that adds new opportunities to make a purchase is a significant change; in Utah only a change that first introduces in-app purchases or advertising is. Louisiana's act also reaches app stores that distribute apps to computers, gaming consoles and virtual reality devices. The obligations attach to users located in the enacting state, and the Utah and Alabama definitions cover only charges billed by an app store.

Open questions

• Will the Fifth Circuit, which heard argument on 4 August 2026, uphold the Texas act on the merits after finding at the stay stage that Texas had made a strong showing of likely success, and will the Utah, Louisiana and Alabama acts face fresh challenges before they take effect?
• Does the Texas consent requirement for a purchase made in or using a software application extend to purchases billed outside the app store, such as web checkouts reached from an app, given that the Utah and Alabama definitions are limited to charges billed by an app store?

Timeline

• 2025-05-07Utah's SB 142, the App Store Accountability Act, takes effect, with app-store and developer duties set for 6 May 2026 and its enforcement section for 31 December 2026. Source (opens in a new tab)
• 2025-05-27Texas's SB 2420 is signed, with an effective date of 1 January 2026. Source (opens in a new tab)
• 2025-12-23In CCIA v. Paxton (W.D. Tex., No. 1:25-cv-01660), Judge Robert Pitman preliminarily enjoins the Texas Attorney General from taking any action to implement, enact or enforce SB 2420. Source (opens in a new tab)
• 2026-02-17Alabama's HB 161 is enacted as Act 2026-59, effective 1 January 2027. Source (opens in a new tab)
• 2026-03-18Utah's HB 498 is signed, moving the app-store and developer duties and the private right of action to 6 May 2027 and narrowing what counts as a significant change. Source (opens in a new tab)
• 2026-04-21The two federal suits against Utah's act, by CCIA and by a group of minors, are dismissed by stipulation; the parties agree that the act as amended by HB 498 authorises no government enforcement and creates only a private cause of action. Source (opens in a new tab)
• 2026-05-15Louisiana's HB 977 is signed as Act 185. It provides that the 2025 act, Act 481, shall not become effective and replaces it with a revised scheme whose main provisions take effect on 1 July 2027. Source (opens in a new tab)
• 2026-05-28The Fifth Circuit temporarily and administratively stays the Texas preliminary injunctions pending a ruling on the motion for a stay. Source (opens in a new tab)
• 2026-06-04In a published order, the Fifth Circuit grants a stay of the universal preliminary injunctions pending appeal, finding that Texas has made a strong showing that it is likely to succeed on the merits. Source (opens in a new tab)
• 2026-07-06The Supreme Court denies the applications by CCIA (No. 25A1390) and by Students Engaged in Advancing Texas (No. 25A1389) to vacate the Fifth Circuit's stay. Source (opens in a new tab)
• 2026-08-04The Fifth Circuit hears oral argument in the consolidated Texas appeals (Nos. 25-51073 and 26-50001). Source (opens in a new tab)