Key takeaways
- Texas's App Store Accountability Act (S.B. 2420), signed May 27, 2025, was preliminarily enjoined on December 23, 2025 (Computer & Communications Industry Association v. Paxton, W.D. Tex.) before its January 1, 2026 effective date.
- On June 4, 2026, the Fifth Circuit granted Texas a stay pending appeal (following an administrative stay on May 28, 2026), allowing S.B. 2420 to take effect for new Texas accounts created on or after that date.
- The underlying First Amendment challenge remains pending before the Fifth Circuit; the law is in force while the appeal proceeds.
- Utah amended its parallel App Store Accountability Act (S.B. 142) through H.B. 498, delaying key compliance mandates to May 6, 2027 and removing the Attorney General's enforcement authority.
The Development
Texas's App Store Accountability Act (S.B. 2420) is now in effect after a year of legislative and judicial back-and-forth. Governor Greg Abbott signed S.B. 2420 on May 27, 2025, with a January 1, 2026 effective date. On December 23, 2025, however, U.S. District Judge Robert Pitman granted a preliminary injunction in Computer & Communications Industry Association v. Paxton (W.D. Tex.), finding the challengers likely to succeed on a First Amendment claim and barring enforcement — so the statute did not take effect on January 1, 2026.
Texas Attorney General Ken Paxton appealed. The U.S. Court of Appeals for the Fifth Circuit entered an administrative stay of the injunction on May 28, 2026, and then, on June 4, 2026, granted Texas a stay pending appeal. That order lifted the injunction and allowed S.B. 2420 to take effect, applying to new Texas app-store accounts created on or after June 4, 2026. The broader constitutional challenge remains pending before the Fifth Circuit.
Separately, Utah amended its own App Store Accountability Act (S.B. 142) through H.B. 498, delaying key operational requirements until May 6, 2027 and removing enforcement authority from the state's Attorney General.
Why It Matters
These developments create a fractured, fast-moving regulatory map for digital storefronts and app developers. App Store Accountability Act laws generally require app-store operators to verify users' ages at account creation and to obtain verifiable parental consent before minors download apps or make in-app purchases. With the Fifth Circuit's stay in place, Texas can enforce those requirements now — but only for new Texas accounts created on or after June 4, 2026, leaving pre-existing accounts untouched for the moment.
Because the law took effect through a stay pending appeal rather than a final merits ruling, its long-term status is uncertain. The Fifth Circuit could still affirm the injunction after full briefing, which would once again halt enforcement. Companies therefore face the difficult position of building compliance systems for a regime that is in force today but could be paused again depending on the appeal's outcome.
Utah's contrasting decision to delay its operational requirements until May 6, 2027 — and to strip its Attorney General of enforcement authority — suggests states are encountering real logistical and constitutional hurdles in implementing these frameworks. The divergence forces national platforms to track each state's posture separately rather than rely on a single national standard.
Who Should Care
For lawyers
Counsel advising technology companies, app-store operators, and developers must track divergent and shifting state timelines. In Texas, compliance is an active obligation as of June 4, 2026 for new accounts, but counsel should advise clients that the Fifth Circuit's eventual merits ruling could change that. Lawyers should evaluate clients' age-verification and parental-consent mechanisms against Texas's requirements now while preparing for the possibility that the appeal reinstates the injunction.
In Utah, the removal of the Attorney General's enforcement authority requires practitioners to reassess who may bring claims under the statute, and the delay to May 6, 2027 gives clients time to build compliant systems. Counsel should also monitor the parallel First Amendment litigation, because the Fifth Circuit's reasoning on the Texas law will shape the constitutional risk for every similar state statute.
For consumers and businesses
In Texas, people creating new app-store accounts on or after June 4, 2026 will encounter age-verification and parental-consent prompts. Businesses distributing apps to Texas users must deploy those systems now. In Utah, the full operational requirements will not bind until May 6, 2027, giving companies a longer runway to build and test the necessary infrastructure.
Legal Background
State legislatures have increasingly targeted app stores to regulate how minors access online applications, with the "App Store Accountability Act" model adopted in varying forms by several states. These laws generally shift part of the burden of policing minors' digital access from parents to the platforms by requiring age verification at account creation and parental consent for minors' downloads and purchases.
Texas enacted its version, S.B. 2420, in 2025. Industry groups — led by the Computer & Communications Industry Association, whose members include major app-store operators — sued to block it, arguing it violates the First Amendment by conditioning access to protected expression on identity verification. Judge Pitman's December 23, 2025 preliminary injunction agreed the challengers were likely to succeed, pausing the law before it could take effect. Texas's appeal of that injunction produced the Fifth Circuit's 2026 stays.
What the Court and Legislature Did
In the Texas litigation, the Fifth Circuit stayed Judge Pitman's preliminary injunction — first administratively on May 28, 2026, then through a stay pending appeal on June 4, 2026. The stay did not resolve the merits; it allowed Texas to enforce S.B. 2420 (for new accounts) while the appeal proceeds, with the constitutionality of the law still to be decided.
In Utah, the legislature amended its App Store Accountability Act (S.B. 142) via H.B. 498. The amendments delayed the implementation deadline for specific operational requirements until May 6, 2027 and removed enforcement authority from the state's Attorney General — a legislative pullback that contrasts with the judicial green light Texas's law received.
How It May Be Applied
Because the Texas law is in effect for new accounts, national platforms must deploy age-verification and parental-consent systems for Texas users now, while preparing for the possibility that the Fifth Circuit later reinstates the injunction. Questions remain about exactly what technical standards will satisfy the statute and how Texas will measure compliance during the appeal.
In Utah, the delay until May 6, 2027 provides a runway to build compliant systems, though the removal of the Attorney General's enforcement authority raises questions about how the state will ensure compliance once the requirements bind. The contrast between the two states may push national platforms toward a state-by-state approach to onboarding and age verification rather than a uniform national one.
State Law Comparison
| Jurisdiction | Current Status | Key Dates | Enforcement Note |
|---|---|---|---|
| Texas (S.B. 2420) | In effect for new accounts (under appeal) | Signed May 27, 2025; enjoined Dec. 23, 2025; Fifth Circuit stay June 4, 2026 | First Amendment appeal pending before the Fifth Circuit |
| Utah (S.B. 142) | Mandates delayed | Compliance requirements delayed to May 6, 2027 (via H.B. 498) | Attorney General enforcement authority removed |
Plain-English Translation
State laws targeting app stores are moving at different speeds. A federal trial court blocked Texas's law in December 2025, but the federal appeals court (the Fifth Circuit) put that block on hold, so as of June 4, 2026 Texas can require age checks and parental approval for new app-store accounts — at least while the larger court fight over whether the law is constitutional continues. Utah, by contrast, hit the brakes: it pushed its technical deadlines out to 2027 and took away the state attorney general's power to enforce the law. So a new app-store account in Texas may ask for age verification today, while Utah's requirements won't fully bind for years.
This article is general legal information and commentary about legal developments. It is not legal advice, does not address your specific situation, and is not a substitute for advice from a licensed attorney. Reading this article and contacting us through this website do not create an attorney-client relationship.
Sources & authorities
- Tex. S.B. 2420, 89th Leg., R.S. (2025), "App Store Accountability Act" — signed May 27, 2025; took effect June 4, 2026 after Fifth Circuit stay — Texas Legislature
- Office of the Texas Attorney General — press release on the Fifth Circuit stay allowing enforcement (June 2026) — texasattorneygeneral.gov
- Utah S.B. 142 (2025), "App Store Accountability Act"; mandates delayed to May 6, 2027 by H.B. 498 (2026) — Utah Legislature
Further reading
Additional perspectives (a link is not an endorsement):