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Fiduciary CommonsA project of Michael G. Leahy, JD
State implementation

Utah: what is enacted, and what the acts add

Utah is the lead enacting state. Its statutes incorporate elements of VIDA and PDTA; they are not full enactments of the model acts.

The statutes

BillWhat it does
SB 260 (2025)Set the principles for state-endorsed digital identity: individual control of identity, protection against surveillance and tracking of credential use, selective disclosure, and the right to keep physical credentials. Directed study of how a state-endorsed digital identity would work.
SB 275 (2026)Passed unanimously by both chambers, signed March 25, 2026, effective May 6, 2026. Created the State-Endorsed Digital Identity (SEDI) program and a digital identity bill of rights, required selective disclosure and open standards, and codified the first statutory duty of loyalty for digital identity. Enforcement runs through the state's data privacy ombudsperson and Attorney General.

The premise is the same as the framework's: identity belongs to the person and precedes state recognition. Government's role is to endorse and verify, not to define or control.

What the model acts add

SEDI governs the identity verification layer. The framework adds two layers SEDI does not reach:

  • PDTA: an enforceable fiduciary relationship governing everything government does with personal information, not only identity transactions, with a private right of action and structural remedies.
  • GAAFA: authority limits, explanation and contestability for AI and automated decisions that use government-held information.

The relationship is successive, not competitive. A state that enacts SEDI-model legislation has built the foundation; PDTA and GAAFA complete it. Version 2.2 also includes provisions that let the acts operate independently of the SEDI Consortium for states adopting the framework on their own.

The consortium

Utah is in conversation with other states considering the SEDI Consortium. That addresses a central adoption problem: no state wants to be first without evidence that others will follow. Michael G. Leahy, JD, has worked with Utah on its digital identity legislation since 2023, including as a member of its legislative workgroup.

Sources: SpruceID on SB 275; CSG West on Utah's framework.