Update, May 11, 2026: Utah has agreed to not enforce the VPN law until Sept. 3, 2026 after Aylo, the parent company of Pornhub.com, challenged the law in court.

For the last couple of years, we’ve watched the same predictable cycle play out across the globe: a state (or country) passes a clunky age-verification mandate, and, without fail, Virtual Private Network (VPN) usage surges as residents scramble to maintain their privacy and anonymity. We've seen this everywhere—from states like Florida, Missouri, Texas, and Utah, to countries like the United Kingdom, Australia, and Indonesia. 

Instead of realizing that mass surveillance and age gates aren't exactly crowd favorites, Utah lawmakers have decided that VPNs themselves are the real issue.

On May 6, 2026, Utah will become, to EFF’s knowledge, the first state in the nation to target the use of VPNs to avoid legally mandated age-verification gates. While advocates in states like Wisconsin successfully forced the removal of similar provisions due to constitutional and technical concerns, Utah is proceeding with a mandate that threatens to significantly undermine digital privacy rights. 

What the Bill Does

Formally known as the “Online Age Verification Amendments,” Senate Bill 73 (SB 73) was signed by Governor Spencer Cox on March 19, 2026. While the majority of the bill consists of provisions related to a 2% tax on revenues from online adult content that is set to take effect in October, one of the more immediate concerns for EFF is the section regulating VPN access, which goes into effect this coming Wednesday.

The VPN Provisions

The new law explicitly addresses VPN use in Section 14, which amends Section 78B-3-1002 of existing Utah statutes in two primary ways:

1. Regulation based on physical location: Under the law, an individual is considered to be accessing a website from Utah if they are physically located there, regardless of whether they use a VPN, proxy server, or other means to disguise their geographic location.
2. Ban on sharing VPN instructions: Commercial entities that host "a substantial portion of material harmful to minors" are now prohibited from facilitating or encouraging the use of a VPN to bypass age checks. This includes providing instructions on how to use a VPN or providing the means to circumvent geofencing.

By holding companies liable for verifying the age of anyone physically in Utah, even those using a VPN, the law creates a massive "liability trap." Just like we argued in the case of the Wisconsin bill, if a website cannot reliably detect a VPN user's true location and the law requires it to do so for all users in a particular state, then the legal risk could push the site to either ban all known VPN IPs, or to mandate age verification for every visitor globally. This would subject millions of users to invasive identity checks or blocks to their VPN use, regardless of where they actually live. 

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"Don't Ask, Don't Tell"

In practice, SB 73 is different from the Wisconsin proposal in that it stops short of a total VPN ban. Instead, it discourages using VPNs by imposing the liability described above and by muzzling the websites themselves from sharing information about VPNs. This raises significant First Amendment concerns, as it prevents platforms from providing basic, truthful information about a lawful privacy tool to their users. 

Unlike previous drafts seen in other states, SB 73 doesn't explicitly ban the use of a VPN. Under a "don't ask, don't tell" style of enforcement, websites likely only have an obligation to ask for proof of age if they actually learn that a user is physically in Utah and using a VPN. If a site doesn’t know a user is in Utah, their broader obligation to police VPNs remains murky. So, while SB 73 isn’t as extreme as the discarded Wisconsin proposal, it remains a dangerous precedent.

Technical Feasibility

Then there is also the question of technical feasibility: Blocking all known VPN and proxy IP addresses is a technical whack-a-mole that likely no company can win. Providers add new IP addresses constantly, and no comprehensive blocklist exists. Complying with Utah’s requirements would require impossible technical feats.

The internet is built to, and will always, route around censorship. If Utah successfully hampers commercial VPN providers, motivated users will transition to non-commercial proxies, private tunnels through cloud services like AWS, or residential proxies that are virtually indistinguishable from standard home traffic. These workarounds will emerge within hours of the law taking effect. Meanwhile, the collateral damage will fall on businesses, journalists, and survivors of abuse who rely on commercial VPNs for essential data security.

These provisions won't stop a tech-savvy teenager, but they certainly will impact the privacy of every regular Utah resident who just wants to keep their data out of the hands of brokers or malicious actors.

Uncharted Territory

Lawmakers have watched age-verification mandates fail and, instead of reconsidering the approach, have decided to wage war on privacy itself. As the Cato Institute states: 

“The point is that when an internet policy can be avoided by a relatively common technology that often provides significant privacy and security benefits, maybe the policy is the problem. Age verification regimes do plenty of damage to online speech and privacy, but attacking VPNs to try to keep them from being circumvented is doubling down on this damaging approach."

Attacks on VPNs are, at their core, attacks on the tools that enable digital privacy. Utah is setting a precedent that prioritizes government control over the fundamental architecture of a private and secure internet, and it won’t stop at the state’s borders. Regulators in countries outside the U.S. are still eyeing VPN restrictions, with the UK Children’s Commissioner calling VPNs a “loophole that needs closing” and the French Minister Delegate for Artificial Intelligence and Digital Affairs saying VPNs are “the next topic on my list” after the country enacted a ban on social media for kids under 15.

As this law goes into effect, we are entering uncharted territory. Lawmakers who can’t distinguish between a security tool and a "loophole" are now writing the rules for one of the most complex infrastructures on Earth. And we can assure that the result won't be a safer internet, only an increasingly less private one.

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