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UCPA: the Utah law explained for people with ads

Utah has one of the lightest state privacy laws in the United States and only reaches larger businesses. Even so, anyone covered must explain targeted advertising and offer a simple way to opt out. Here is when it applies to your site and what Google does with the signal.

  • ✓Based on the official text of the Utah Code
  • ✓Examples designed for sites with AdSense and Ad Manager
  • ✓Read-only scan, no changes to the site
$25Mminimum annual revenue for the law to apply, combined with a consumer threshold
100,000Utah consumers per year, the volume threshold for businesses that pass the revenue threshold
30 daystime to cure a violation after the attorney general's written notice
$7,500maximum fine per violation, in addition to actual damages to consumers

What it is

A lean law, designed not to burden small businesses

The Utah Consumer Privacy Act, or UCPA, is in Chapter 61 of Title 13 of the Utah Code. It was passed in 2022 and took effect on December 31, 2023.

The UCPA follows the structure of Virginia's law, but is lighter. It does not require data protection assessments, does not oblige the site to honor automatic browser signals and allows processing sensitive data with notice and an option to opt out, instead of prior consent.

It is also the only one of the laws in this group that requires minimum revenue. A business is only covered if it has annual revenue of at least $25 million and, in addition, a relevant volume of Utah consumers.

For those covered, the central rule does not change: the site must say that it does targeted advertising and offer a clear path for the visitor to opt out.

Checklist

What you need to meet

They only apply to businesses with annual revenue of US$ 25 million or more that also exceed one of the volume thresholds.

  1. Show clearly how to opt out

    Anyone who sells data or does targeted advertising must show clearly and visibly how the visitor opts out. The law does not define the link text.

    Example

    Footer: Do Not Sell or Share My Personal Information

  2. Publish a clear privacy notice

    The notice lists the categories of data, the purposes, how to exercise rights, the data shared with third parties and the types of third parties.

    Example

    We use browsing data to show ads. We share this data with ad networks. To opt out, use the link in the footer.

  3. Give notice before using sensitive data

    Before processing sensitive data, the site gives a clear notice and the chance to opt out. For a known child, the COPPA law applies.

  4. Respond within 45 days

    Requests get a response within 45 days. If it needs another 45, the site notifies the visitor and says how much longer it will take.

  5. Honor the correction request

    Since July 1, 2026, the visitor can also ask for incorrect data to be corrected.

  6. Use the US National section with Google

    Google does not accept the Utah section of the GPP string. For Utah, the CMP must send US National, or the site turns on RDP directly in the tag.

    // GPT: liga o processamento restrito de dados (RDP)
    // para quem recusou a venda ou a publicidade direcionada
    googletag.cmd.push(function () {
      googletag.pubads().setPrivacySettings({
        restrictDataProcessing: true
      });
    });
  7. Fix quickly if notified

    The attorney general notifies in writing and gives 30 days to fix it. If the failure continues, the fine reaches US$ 7,500 per violation.

In practice

Right and wrong

Official tools

Certified CMPs and official links

Google does not require a certified CMP for Utah. Google's US states message covers Utah and records the choice in the US National section. These are the official links.

Who it applies to

Revenue and volume, both at the same time

The law applies to anyone who does business in Utah or offers products and services to residents of the state and meets the revenue condition and one of the volume conditions.

$25 million in revenue

Annual revenue of $25 million or more. Without this condition, the law does not apply, however large the traffic.

100,000 consumers

Besides revenue, controlling or processing data of 100,000 or more Utah consumers in a calendar year.

Or 25,000 and data sales

Or processing data of 25,000 consumers and getting more than 50% of gross revenue from selling personal data.

Who is left out

Public agencies, nonprofits, higher education institutions and data covered by federal finance and health laws.

Definitions

The terms that matter for people who sell ads

Utah uses narrow definitions, similar to Virginia's.

Personal data

Information linked, or reasonably linkable, to an identified or identifiable person. De-identified and public data are left out.

Sensitive data

Racial or ethnic origin, religion, sexual orientation, immigration status, medical and health history, genetic and biometric data and precise location.

Sale

The exchange of personal data for money with a third party. As in Virginia, only payment in money counts.

Targeted advertising

An ad chosen based on data about the person's activities over time on other companies' sites and apps. Contextual ads do not count.

Rights

What a Utah visitor can ask for

The business has 45 days to respond, with the possibility of an extension. The list of rights is shorter than in other states.

Access

Confirm whether the business processes their data and get access to it.

Deletion and portability

Delete the data they themselves provided and receive a copy in a format they can take to another service.

Correction, from July 1, 2026

An amendment passed in 2025 added the right to ask for wrong data to be corrected, which the original law did not have.

Opt-out

Refuse the use of data for targeted advertising and the sale of personal data.

Site obligations

Privacy notice, opt-out and sensitive data

The business needs an accessible, clear privacy notice. It must list the categories of data processed, the purposes, how to exercise rights, the categories of data passed to third parties and the categories of those third parties.

If the site sells data or does targeted advertising, it must show clearly and visibly how the visitor can opt out. The law does not define the link text, but it must be easy to find, such as in the footer.

Sensitive data can only be processed after clear notice and the chance to opt out. For known children's data, the federal COPPA law applies, with parental consent.

Utah does not require the site to honor the Global Privacy Control or other automatic browser signals, and does not require data protection assessments. That does not stop the business from honoring the GPC by choice, which simplifies operations across several states.

Timeline

Utah law dates

The UCPA has changed little since it took effect.

  1. 2022

    Law passed

    Utah passes its broad consumer privacy law, SB 227.

  2. December 31, 2023

    Entry into force

    The rights, the privacy notice and the opt-out of targeted advertising and sale take effect.

  3. 2025

    Amendment passed

    The Utah Legislature passes the addition of the right to correct.

  4. July 1, 2026

    Right to correct now in effect

    Visitors can now ask to correct wrong data.

Enforcement and fines

Attorney general, consumer protection division and 30-day period

The Utah attorney general has exclusive authority to enforce the law. The state's Division of Consumer Protection receives complaints, investigates and can refer the case to the attorney general. Individuals cannot sue a company under the UCPA.

Before filing a lawsuit, the attorney general must send a written notice at least 30 days in advance, pointing out each failure. If the company fixes the problem within that period and sends a written statement that it did so and will not repeat it, there is no lawsuit. This cure period has no end date.

If the failure continues or happens again, the attorney general can seek the consumers' actual damages and a fine of up to $7,500 per violation.

In practice, the 30-day period gives a second chance, but only to those who read the notice and fix things quickly. Having the notice and the opt-out working from the start avoids the problem.

AdSense and Ad Manager

How Google treats visitors from Utah

The IAB Tech Lab created a dedicated Utah section in the GPP string, but Google does not accept it. The AdSense support page lists the Utah section among the unsupported strings.

For Utah, Google reads the US National section. When it signals an opt-out of sale, sharing or targeted advertising, Google turns on restricted data processing, or RDP, and shows only non-personalized ads.

The Privacy message for US states, in AdSense and Ad Manager, includes Utah and saves the choice in the US National section. If you use another CMP, check that it sends US National for Utah visitors, and not only the state section.

Another option is to turn on RDP directly in the ad tag, for example with restrictDataProcessing in GPT, for visitors who opted out. Remember to pass the opt-out on to header bidding partners, video and pixels as well.

In practice

What is and is not allowed in Utah

Examples for a site with ads that is above the law's thresholds.

Allowed

  • Showing personalized ads without asking permission first, with a visible opt-out link
  • Saving the opt-out of Utah visitors in the US National section of the GPP
  • Honoring GPC by choice, even without an obligation
  • Processing sensitive data after a clear notice and an option to opt out
  • Show contextual ads to people who opted out

Not allowed

  • Sending only the Utah section and assuming Google will read it
  • Hiding the opt-out in the middle of the privacy policy
  • Processing health data or precise location without notice and without a chance to opt out
  • Ignoring a notice from the attorney general and missing the 30-day deadline
  • Refusing to correct wrong data after July 2026

Common errors

Where sites usually go wrong with Utah

The law is simple, but the technical part often fails.

Wrong GPP section

The CMP sends only the Utah section, which Google does not accept, and the ad request goes out without RDP.

Policy without ads

The policy talks about cookies, but does not say there is targeted advertising or how to opt out.

Thinking Utah does not matter

The company goes over $25 million in revenue and 100,000 Utah visitors and offers no opt-out at all.

Outdated rights

The policy does not mention the right to correct that has applied since July 1, 2026.

In ConsentMode

What the audit checks about the UCPA

  • Opens the site as a Utah visitor and looks for the targeted advertising opt-out link in a visible place.
  • Reads the GPP string in ad requests and shows whether it includes the US National section, which is the one Google reads for Utah.
  • Identifies the CMP and checks whether the opt-out changes the string before ad and header bidding requests.
  • Records whether the site honors GPC, which is not required in Utah, but is in other states.
  • Reads the privacy policy and points out whether purposes, third parties, rights and how to opt out are missing.

Frequently asked questions about the Utah law

My site earns less than $25 million. Does the UCPA apply?

No. The law only applies to those with annual revenue of at least $25 million that also exceed one of the consumer thresholds. Even so, ad partners may ask for the opt-out signals.

Do I need to honor GPC in Utah?

It is not required by the UCPA. Many sites honor it anyway, because states such as California, Colorado, Connecticut and Oregon require it.

Do I need consent for sensitive data?

Utah requires a clear notice and a chance to opt out before processing, and not prior consent. For children, the federal COPPA law applies.

Which GPP section should I send for Utah?

For Google, US National. AdSense states that it does not accept the Utah section.

Does ConsentMode set up my CMP?

No. ConsentMode is not a CMP and does not change your site. It shows which section is being sent and what to adjust.

Library

Official sources

This guide was written from these official pages. Read them directly at the source:

Find out whether Google is reading your opt-out

The audit opens the site as a Utah visitor and shows the string sent to ads, without changing anything.

Start the audit