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Summary
The US state of Utah recently passed the “Digital Choice Act”, which requires the operators of social media services to implement, by July 1, 2026, several substantial, novel features that have not previously been required by other legislation in Utah or elsewhere, including:
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The ability for a user to move their account and all their data from one social media service to another without avoidable loss of content or social connections (“data portability”);
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The ability for users on one social media service to socially interact with users on another social media service (“social media interoperability”); and:
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The ability for users to utilize more than one social media service at a time while keeping their content (including social graph and other personal data) synchronized between them (“personal data synchronization”).
Several other US states, including New York and Vermont, are currently considering similar laws.
In this paper, we analyze the impact on social media services, surface some key strategic decisions that need to be made by social media service providers and outline the main technical approaches which social media product teams could take to meet the requirements of the law. It is provided in the hope that it is useful for potential implementors, and for the legislative process in other states considering similar legislation.
We welcome discussion, please reach out.
This is our draft analysis, which we are continuing to refine. We cannot promise this analysis is complete or correct, so please refer to the legal text as the authoritative source. Ultimately, it will likely be the courts that establish a definitive interpretation. But hopefully, our analysis may be helpful in getting you started in thinking about what needs to be done and how it could be done.
If you disagree with any aspect of our analysis, or would like to discuss this further, please get in touch.