Legal-services sandboxes have admitted few AI providers: Utah, Ontario, BC and SRA records to October 2026

Five legal regulators in the United States (Utah, Arizona), Canada (British Columbia, Ontario) and England and Wales publish a register of the providers they allow to deliver legal services outside the ordinary lawyer-and-law-firm model. Read on 5 October 2026, the Utah, British Columbia and Ontario sandbox registers hold 89 current provider listings (Utah 7, British Columbia 68, Ontario 14 as captured on 6 March 2026), and 4 of them describe artificial intelligence or a chatbot. The Solicitors Regulation Authority (SRA) has announced one AI-driven law firm.

The largest sandbox, run by the Utah Supreme Court, lists 69 names on its roster: 7 current listings and 61 that left, 31 of them through a court-ordered narrowing dated between January and November 2025. Enforcement against consumer AI legal products has come mainly from consumer-protection law: the Federal Trade Commission’s January 2025 order against DoNotPay ($193,000) is the only regulator order in the SafeLegalAI enforcement register that addresses an AI service’s claims to work like a lawyer. This report describes the registers and orders; it does not assess any provider.

Key findings

1. As of 5 October 2026 the Utah Office of Legal Services Innovation lists 69 names: 7 current listings, 1 standing-order programme and 61 exits. Thirty-one exits followed the court’s “Phase 2” narrowing, with orders dated 23 January to 20 November 2025.
2. Three of Utah’s 7 current listings include a software-provider service model (1Law, Rasa, Superlegal); two describe AI or a chatbot. Applications closed on 29 May 2026; the sandbox sunsets on 14 August 2027.
3. The Law Society of British Columbia lists 68 innovation-sandbox participants with no-action letters dated 26 May 2021 to 9 July 2026. Seven describe an online platform or automated document service; none of the 68 descriptions mentions AI.
4. The Law Society of Ontario reported 17 approved Access to Innovation (A2I) participants, 119,848 services and 23 qualifying complaints (10 harm-related) in June 2025, and wrote that generative AI “has not yet resulted in a significant proliferation of direct-to-consumer legal products”. Two of the 14 providers listed on 6 March 2026 name AI.
5. The SRA announced on 6 May 2025 that Garfield.Law Ltd is “the first purely AI-based firm” it has authorised. Its release records that the system cannot propose case law, acts only on client approval, and that named solicitors remain accountable.
6. The FTC’s DoNotPay order (issued 14 January 2025; 20-year term) bars claims that the service “operates like a human lawyer” without evidence and required a $193,000 payment. Two private suits against DoNotPay in 2023 ended without a ruling on unauthorised practice: one dismissed for lack of standing (17 November 2023), one dismissed with prejudice after settlement (30 July 2024).
7. In the SafeLegalAI regulatory map’s 130 country records, the “consumer AI legal services and unauthorised practice” category is none in 111 and unclear in 11 (map dates 4 to 16 September 2026). Four of those cells (Brazil, Czechia, Germany, Japan) rest on a ruling or official text about software or AI legal products themselves.
8. Five United States bills in the SafeLegalAI legislation register sit in the legal-services and unauthorised-practice lane as of 8 September 2026. One is recorded in the register as in force (Utah SB 226, signed 27 March 2025 according to the register; the enrolled bill’s new disclosure provisions take effect 7 May 2025); three New York chatbot-impersonation bills are in committee.

Why this question

A consumer who uses an AI service to draft a will or recover a small debt relies on two separate permissions. One is whether the law lets anyone but a licensed lawyer give that help. The other is whether the product’s claims are true. Different regulators own each question.

Regulatory sandboxes were built to answer the first question with evidence rather than prohibition. Utah’s Supreme Court, the Law Society of British Columbia and the Law Society of Ontario each opened one in 2020 or 2021 and publish participants’ names. Arizona licenses alternative business structures (ABS) and publishes a directory. In England and Wales the SRA authorises firms under its ordinary rules and announced the first AI-driven one.

The registers answer three questions. Has any regulator approved an AI legal service? On what conditions? Who left, and why? An earlier report covered consumer AI legal services and self-represented litigants; this one covers the regulators.

Method and data

This report is built on five SafeLegalAI datasets and the primary documents in Appendix B, fetched on 5 October 2026 by the SafeLegalAI fetcher (identified user agent, at most one request per second, no browser impersonation). Each number names its dataset and as-of date, or its official source.

Dataset	File in the site repository	Version / as-of	Records used	Public JSON
Legal-AI enforcement, UPL and authorisation register	src/data/enforcement/actions.json	v0.1.1, built 8 Sep 2026; rows fetched 7 Sep 2026	43	/regulation/enforcement.json
Regulatory map, country records	src/content/countries/*.yaml	category unauthorised-practice verified 4, 11 or 16 Sep 2026	130	/regulation/map.json
Regulation documents	src/content/regulations/*.yaml	522 records on 5 Oct 2026	8 tagged unauthorised-practice	/regulation/documents.json
US legislation on AI in courts and legal services	src/data/legislation/bills.json	v0.1.3, built 8 Sep 2026	41 (5 in lane)	/regulation/legislation.json
Legal AI tech tools directory	src/content/tools/*.yaml	records last verified 3 Sep to 5 Oct 2026	7 in category consumer-legal	/tools/tools.json

The enforcement register holds 43 records, all verified fetched-and-read, dated 26 May 2021 to 7 September 2026: 25 sandbox authorisations, 5 unauthorised-practice (UPL) litigation records, 4 regulator registers, 4 court and access-to-justice deployment records, 3 policy statements and 2 regulator enforcement records (cross-tab in Appendix A1). Each record has a page at /regulation/enforcement/<id>; the dataset is also on GitHub and Hugging Face.

The register holds a sample of entities, not every participant. To count whole rosters, we read each regulator’s own register on 5 October 2026 and coded it:

• Utah: the authorized-entities page and the 66 documents it links (55 termination orders, 10 authorisation or provisional orders, Standing Order 16). Twelve scanned orders were read by optical character recognition. Each exit was coded from the order’s stated reason.
• British Columbia: the approved-participants table (68 rows), with five letters opened to confirm dates. A row is coded “platform” if the Law Society’s description says the service runs through an online platform or automated document generator, and “AI” if the description contains “AI”, “artificial intelligence”, “chatbot”, “machine learning” or “generative”.
• Ontario: the providers page returned HTTP 403 to our fetcher, so the Wayback Machine capture of 6 March 2026 was read, with the June 2025 report to Convocation.
• Arizona: the ABS directory returned a Cloudflare challenge, so the Wayback capture of 7 September 2026 was read.

Statuses on the regulatory map follow the published taxonomy (categories, editorial standard). The category used here, unauthorised-practice, records “rulings/regulation of AI legal products offered to the public”. It does not record sandbox permissions, which matters for the US and Canada cells (section 8).

Known limits. The registers describe services in the regulator’s words, written for consumers, not for AI classification; a provider using AI internally may not be described as doing so. The Ontario list is seven months old. The Arizona directory lists names and practice areas only. Two Utah exits have no linked order, so their reason is not recorded. Brazil’s map record rests on two legal-press reports of the court decision, not the court’s own document. Fifty-four country records on the map are provisional (AI-researched, awaiting editor re-verification); all 54 score this category none.

1. Which regulators publish who may sell non-traditional legal services?

Five regulators in this record publish a register: the Utah Supreme Court (sandbox, from 14 August 2020), the Law Society of British Columbia (no-action letters from May 2021), the Law Society of Ontario (A2I, launched November 2021), the Arizona Supreme Court (ABS licences) and the SRA (firm authorisation). Their legal tools differ.

Regulator	Instrument	Legal effect for a participant	Term	AI named in the regulator’s own scheme text?
Utah Supreme Court	Standing Order 15, amended 21 Sep 2022	Court order authorising practice in the sandbox	Seven-year pilot; sunset 14 Aug 2027	Yes: register page lists “technology-based services such as AI”
Law Society of British Columbia	Innovation sandbox	No-action letter: the Law Society will not act to stop the services, on conditions	Per letter	Yes: invites “the use of AI and other technologies”
Law Society of Ontario	Access to Innovation, under By-Law 16	Approval to operate “for an agreed period of time” with reporting duties	Five-year pilot	Report context cites AI; scheme is for “technological legal services”
Arizona Supreme Court	ABS licence (directory)	Licence; “only ABSs listed as active are authorized to provide services”	Licence	Not in the directory text
Solicitors Regulation Authority	Firm authorisation (Garfield release)	Ordinary SRA authorisation	Ongoing	Yes, in the release

Two of the five are pilots with an end date: Utah’s runs to August 2027, and Ontario’s report calls A2I “a five-year regulatory sandbox pilot program”. The pages read for BC and Arizona give no end date.

The registers record different things. Utah and BC record permission to do what the professional rules would otherwise forbid. Arizona records a licence for a business structure and says nothing about how services are delivered. The SRA announced Garfield because, in its words, “the risks around an AI-driven law firm are novel”.

2. Utah: what happened to the 69 names on the sandbox roster?

Utah’s sandbox is the largest of the three sandboxes by name count and the only one that links the court’s order for most exits. Of 69 names on the roster read on 5 October 2026, 61 have left, 31 of them after the Supreme Court’s 2024 decision to narrow the sandbox. Applications closed on 29 May 2026, and the court is preparing for the 14 August 2027 sunset.

The register page groups the roster into five lists.

List on the Utah register (5 Oct 2026)	Names
Authorized entities	7
Provisionally authorized (all marked expired or withdrew)	7
Authorized through standing order (i4J housing advocates, Standing Order 16)	1
Previously authorized, with partial Rule 5.4 waivers	19
Previously authorized	35
Total	69

The 7 current listings are 6 entities: the metrics page (August 2026) counts 6, one with two subsidiaries; the register lists Elysium Legal and Pearson Butler as sister subsidiaries.

Why did 61 entities leave?

Coded from the 55 linked termination orders and the register’s “expired” labels, the 61 exits divide as follows.

Exit reason (coded from the order)	Exits
Entity asked to withdraw or end participation	20
Low-innovation ABS terminated, lawyers given a partial Rule 5.4 waiver (Phase 2)	19
Phase 2: unresponsive to the October 2024 notice, model not implemented, or requirements not met	12
Provisional authorisation expired	6
Compliance (data reporting failure; undisclosed UPL matters at application)	2
No order linked on the register	2
Total	61

Dated termination orders cluster in 2025: 4 in 2022, 4 in 2023, 10 in 2024 and 37 in 2025. On 5 September 2024 the court wrote to its Legal Services Innovation Committee that “A number of low-innovation entities have consumed a disproportionate amount of Innovation Office resources that could be better spent processing applications and regulating entities with more potential to benefit consumers.” The letter introduced a “Utah innovation requirement” and ordered that existing entities failing it “will exit the Sandbox”.

A State Bar News item in the Utah Bar Journal (November/December 2024), reporting the court’s changes, gave the scale: “Roughly three-quarters of current Sandbox participants are low-innovation, Alternative Business Structure-only entities.” The November 2025 waiver order for Michelle Turpin PC defines the term in a footnote: “In the Sandbox, a Low Innovation model is one where legal services are provided by attorneys. For Moderate Innovation and High Innovation models, legal services are solely or partially provided by alternative legal providers (software and/or nonlawyers).”

Eighteen of the 19 waiver exits were ABS entities the committee classed as low-innovation; the nineteenth, authorised as moderate-innovation, asked to leave on that basis. The waiver orders record that the court ended “the ABS-only portion of the Sandbox on December 31, 2024”; lawyers may keep working for those entities under Rule 5.4 conditions until the pilot ends.

Which Utah entities use software or AI?

Three of the seven current listings include the service model “Software provider with lawyer involvement”: 1Law, Rasa and Superlegal (LawGeex / Legalogic). Two name AI or a chatbot. The other four are a community advocate programme, a university social-work programme and two affiliated firms using non-lawyer providers. The orders describe the three software models:

• Superlegal: the amended order of 16 August 2022 says the company’s “product is a software program that automates contract review and management using artificial intelligence.” Outside the sandbox, it says, “it is not permitted to make independent legal assessments or engage in contract negotiation itself”. The Innovation Office rated the risk “Moderate” and the order limits services to business and healthcare.
• 1Law: the authorisation packet (order dated 16 August 2022) describes services delivered “using chatbots, instant messaging, automated interviews, nonlawyer staff, and technology assisted lawyers”.
• Rasa: the amended order of 21 September 2022 records that the original authorisation was for “a software platform to assist Utah consumers in determining whether they are eligible for expungement of their criminal record”.

Two AI-linked names appear among the exits. Darrow AI, Inc. and its affiliated firm Edward & Mansfield, LLC were terminated on 27 January 2025 as a “low-innovation ABS entity that does not meet the Utah innovation requirement” (order; register record). The court had authorised the firm on 21 December 2022 as an ABS “in which services are provided by lawyers”. Divorcio Amigable held a provisional authorisation from 10 April 2023 for a provider “who uses software to assist consumers with divorce pleadings”; the register now marks it expired.

Termination orders rarely describe delivery models, so software use among the 61 exits may be undercounted.

Where does the Utah sandbox stand now?

The metrics page, as of August 2026, records 50 applications since the sandbox re-opened in February 2024 (8 withdrawn), 2 recommended for entry, 36 denied and 2 consumer complaints in 2026. The Phase 3 page says the court announced Phase 3 on 15 May 2026, “with a focus on sunsetting the Sandbox and institutionalizing reform efforts”, and closed applications on 29 May 2026. An ad hoc Supreme Court committee is “charged with producing a final report that recommends which reforms should be institutionalized after the Sandbox sunsets.” No report was linked on 5 October 2026.

Only two exits were for compliance. FOCL Law was terminated on 16 August 2022 because it “failed to comply with data reporting requirements of the Sandbox”. D4U Immigration was terminated on 23 March 2023 after two complaints and the Florida Bar’s disclosure of a 2021 cease-and-desist letter D4U had signed. Neither is described as using AI.

3. British Columbia: do 68 no-action letters include AI services?

The Law Society of British Columbia lists 68 innovation-sandbox participants, each with a no-action letter, dated from 26 May 2021 to 9 July 2026. Seven describe an online platform or automated document service. None of the 68 descriptions uses the words AI, artificial intelligence, chatbot or generative, although the sandbox page invites proposals involving AI.

The about page asks prospective applicants whether their idea “involves people who are not traditional legal service providers or the use of AI and other technologies.” The approved-participants table answers in practice. Most entries are individual non-lawyers or paralegals permitted to advise or appear in defined tribunals and courts.

The seven platform services are wills and powers of attorney (Willful, LegalWills.ca), relationship and separation agreements (Divii, Jointly, and a cohabitation-agreement platform), online settlement negotiation (SimpleArb) and online lawyer referral (Tellalawyer). Six of the seven are in the enforcement register, with letters dated 26 May 2021 to 17 July 2025; Tellalawyer is not.

The Jointly letter of 17 July 2025 shows the conditions. Jointly’s platform “automates the creation of family law agreements”. The Law Society will not act against it provided, among other conditions, that “Jointly’s provision of the Services does not present a risk of harm to the public or undermine the integrity of the administration of justice”, that it reports monthly, and that every client receives a disclosure beginning “My/our services to you are not provided by a lawyer regulated by the Law Society of British Columbia.” The disclosure then warns of no privilege, no professional liability insurance and no statutory complaint process.

Three platforms hold permissions in both Canadian provinces: Willful, LegalWills and Jointly appear on the BC list and the Ontario list.

4. Ontario: what has A2I measured?

Ontario’s A2I programme admits services delivered through technology or a mix of technology and licensees. The Law Society’s June 2025 report counted 17 approved participants, 119,848 services and 23 qualifying complaints, 10 of them harm-related. The provider list captured on 6 March 2026 names 14 providers, and 2 descriptions mention AI.

The June 2025 update report to Convocation holds the most detailed outcome data published by any sandbox in this record.

A2I measure (June 2025 report)	Value
Approved participants	17 (14 publicly announced)
Applications under review or early stage	16
Services provided to date	119,848
Qualifying legal-service complaints	23
Harm-related complaints	10
Average cost of a service	~$93
Known direct-to-consumer legal tech entities in Ontario	~22 three years earlier, 51 at the report

The report states: “So far generative AI technology has not yet resulted in a significant proliferation of direct-to-consumer legal products.” It adds that only one application dealing with adversarial legal situations had been received.

The report sets Ontario’s first 26 months, roughly 120,000 services, against roughly 47,000 for Utah’s sandbox, or 3,900 when Utah is limited to “software alternative legal service providers”. These are the Law Society’s figures; Utah’s reports were not re-read for this comparison.

The providers page captured on 6 March 2026 lists 14 approved providers in six groups: estate planning (4), real estate (3), incorporation (3), family law (2), immigration (1) and consumer rights (1).

Two descriptions name AI. Airfairness is “an AI-powered platform that streamlines air passenger compensation from intake to payout” (register record). Philer automates real-estate closings using “licensed real estate lawyers and AI” (register record). The enforcement register holds 13 of the 14; Counselurdocs is missing.

5. England and Wales: what conditions came with the first AI-driven firm?

On 6 May 2025 the SRA announced that Garfield.Law Ltd is “the first purely AI-based firm” it has authorised to provide regulated legal services in England and Wales. The release records three safeguards the SRA checked: no case-law proposals, client approval before each step, and solicitor accountability for every output.

The SRA release describes the service as “an AI-powered litigation assistant” for recovering unpaid debts through the small claims process. On hallucination it says: “The system will not be able to propose relevant case law, which is a high-risk area for large language model machine learning.” On autonomy: “Garfield is not autonomous and will only take a step where the client has approved it”. On accountability, “named regulated solicitors will still ultimately be accountable for the firm delivering high professional standards.”

On 22 June 2026 the firm published its own account of a small-claims trial at Wandsworth County Court on 14 May 2026, where a barrister handled the advocacy and the court found for its client. No judgment was located; the register codes the account as first-party (record).

On 17 August 2026 the SRA published its Misuse of AI warning notice. It applies to all regulated firms and states: “AI has no separate legal personality; solicitors and regulated individuals who use AI in the course of delivering legal services remain accountable for their work and outputs, regardless of how that work has been prepared.” The notice cites R (Ayinde) v Haringey LBC [2025] EWHC 1383 (Admin), which is in the incident tracker. It does not mention AI-only firms.

One other consumer service in the tools directory states an SRA link: Lawhive, whose affiliate Lawhive Legal Ltd “is authorised and regulated by the Solicitors Regulation Authority”, according to its site.

6. Arizona: does the ABS directory say how services are delivered?

Arizona’s directory lists 170 alternative business structures in the 7 September 2026 capture: 161 active, 4 inactive and 5 that voluntarily surrendered a licence in good standing. The directory gives names, contacts, counties and practice areas. It does not describe service delivery, so it cannot show which licensees use AI.

The enforcement register therefore records the directory with regulator_ai_flag: false (record).

The directory overlaps with Utah’s exits. Rocket Legal Professional Services, Inc. is active in Arizona; its Utah authorisation ended at its own request on 20 December 2024 (order). Law on Call, LLC is active in Arizona; Utah terminated it as a low-innovation ABS on 5 May 2025. A Utah exit ended a Utah authorisation, not the business.

7. Who has enforced against AI legal services, and under what law?

Consumer-protection law produced the only regulator order in this record against a consumer AI legal product: the FTC’s 2025 DoNotPay order. Unauthorised-practice law produced two private suits that ended without a merits ruling, a federal appeal about non-lawyer advice, and a 2021 German ruling that a document generator is not a legal service.

The FTC order against DoNotPay

The FTC’s decision and order (Docket C-4812, issued 14 January 2025) followed the proposed consent order noticed in the Federal Register on 30 September 2024. DoNotPay neither admitted nor denied the allegations. Part I bars any representation “that such Covered Product or Service operates like a human lawyer”, including by “applying the relevant laws to subscribers’ particular legal and factual situations”, unless it is non-misleading and backed by competent and reliable evidence. Part III required payment of $193,000. Part VI required notices to subscribers who joined between 1 January 2021 and 31 December 2023. The order terminates 20 years from issuance.

The FTC’s proposed policy statement on accuracy in AI systems, published in the Federal Register on 7 July 2026 with comments due 31 July 2026, cites the DoNotPay order for “deceptive claims about the ability of its AI chatbot to replace the services of a human lawyer”. A Federal Register search on 5 October 2026 found no final version. The DoNotPay tool record carries the order.

Private suits against DoNotPay

In MillerKing, LLC v DoNotPay, Inc. (S.D. Ill., No. 3:23-cv-863), a Chicago law firm sued under the Lanham Act and Illinois law, including a UPL count. The court opened: “This case pits real lawyers against a robot lawyer.” It dismissed the complaint without prejudice on 17 November 2023 for lack of standing, holding that the firm had “alleged no particularized harm” on the UPL count (order).

In Faridian v DoNotPay, Inc. (N.D. Cal., No. 3:23-cv-01692), the parties reported a settlement in principle on 5 June 2024 (status update). The court dismissed the named plaintiff’s claims with prejudice on 30 July 2024, “with no impact on the claims of any other member of the putative class” (order). Neither court decided whether the service practised law.

The non-AI precedent: Upsolve v James

Upsolve, Inc. v James (2d Cir., decided 9 September 2025) concerns trained non-lawyer “Justice Advocates”, not software. The opinion agreed that New York’s UPL statutes, as applied, regulate speech, but held “that such regulation is content neutral and thus subject only to intermediate scrutiny”. It vacated the preliminary injunction and remanded. The register holds it, flagged regulator_ai_flag: false, as the current Second Circuit framework for speech-based challenges to UPL statutes.

Germany: the smartlaw ruling

The Bundesgerichtshof held on 9 September 2021 (I ZR 113/20) that a contract-document generator using questions, selected answers and stored clauses is not a legal service. The judgment’s headnote reads: “Die Erstellung eines Vertragsentwurfs mithilfe eines digitalen Rechtsdokumentengenerators, bei dem anhand von Fragen und vom Nutzer auszuwählenden Antworten standardisierte Vertragsklauseln abgerufen werden, stellt keine Rechtsdienstleistung im Sinne von § 2 Abs. 1 RDG dar.” A regional bar chamber brought the case and lost. The product was rule-based, not generative; the map’s Germany note records no AI-specific ruling as of 11 September 2026.

8. What does the 130-country map record on unauthorised practice and AI?

The regulatory map scores each of 130 country records on whether a ruling, rule or guidance applies unauthorised-practice law to consumer AI legal products. As of 4 to 16 September 2026 it records 8 with a position and 122 with none or an unclear one. Four (Brazil, Czechia, Germany, Japan) address software or AI products specifically.

Status (category unauthorised-practice)	Records	Countries
binding	4	France, Germany, Ireland, United Kingdom
guidance	3	Czechia, Japan, Türkiye
case-law	1	Brazil
unclear	11	Finland, Hong Kong SAR, Hungary, Indonesia, Malaysia, New Zealand, Romania, Singapore, Slovakia, Thailand, Vietnam
none	111	includes Australia, Canada, India, the United States and all 54 provisional records

The four binding cells rest on general reserved-activity statutes, which the France and Ireland notes call “technology-neutral”. The UK cell cites the Garfield authorisation and Germany’s adds the smartlaw ruling. None is an AI-specific rule.

Outside Germany, three positions address software or AI products themselves. Japan’s Ministry of Justice guideline of August 2023 (record; PDF) says an AI contract-review service breaches Attorney Act article 72 only if all three elements are present (remuneration, a legal case, legal affairs), and that generative-AI services are judged on the same framework. The Czech Bar Association’s 2023 opinion (record; PDF) states: “AI v jakékoliv formě nemůže být poskytovatelem právní služby ve smyslu §1 zákona o advokacii.” (AI in any form cannot be a provider of legal services under §1 of the Advocacy Act.) Brazil’s Superior Court of Justice refused in June 2025 to take down an AI petition-drafting site for small-claims courts (record); that record rests on legal-press reports. Türkiye’s bar guide (record) is addressed to lawyers: it bars them from facilitating non-lawyers or systems that appear to give independent legal advice through AI.

The US and Canada score none. The US note says UPL “is regulated exclusively by the states” and that federal action “has proceeded under the FTC Act”. The Canada note records no ruling on consumer AI legal products and mentions the Barreau du Québec sandbox. Neither cell counts the Utah, BC or Ontario sandboxes, because the category records rulings and rules applying UPL to AI products, not permissions. The category page therefore shows no North American position.

Eight of 522 regulation records (5 October 2026) carry the unauthorised-practice tag. Beyond the four above, they are the New York State Bar Association task-force report (April 2024), the State Bar of Michigan AI workgroup report (June 2025), the Malaysian Bar’s Circular 242/2025 and an IBA committee compendium. All four are guidance or surveys addressed to lawyers.

9. Which US bills address AI legal services?

The SafeLegalAI legislation register (version 0.1.3, 8 September 2026) places 5 of its 41 bills in the legal-services and unauthorised-practice lane. Utah SB 226 is the only one in force; it requires regulated professions using generative AI to disclose high-risk AI interactions. Three New York bills on chatbots impersonating licensed professionals sit in committee.

Bill	Status (register, 8 Sep 2026)	What the lane section does
Utah SB 226	In force; signed 27 Mar 2025	Providers in regulated occupations must prominently disclose high-risk generative-AI interactions and meet all occupation requirements
New York S7263	In committee; committed to Rules 5 Jun 2026	Bars operators from knowingly permitting a chatbot to impersonate covered professionals, including attorneys
New York A6545	In committee; reported 1 Jun 2026	Assembly version of the same chatbot-impersonation rule
New York S10675	In committee; referred to Rules 5 Aug 2026	Later Senate chatbot-liability bill covering attorneys under Judiciary Law article 15
Rhode Island S627	In committee since 7 Mar 2025	Treats AI used in decisions about the provision of legal services as high-risk

SB 226 is a legislative disclosure duty; the sandbox is a Supreme Court order on who may practise law. The legislature’s SB 226 page did not respond to our fetcher on 5 October 2026, so its status is the register’s reading of 7 September 2026.

10. Where do courts and legal-aid bodies run their own chatbots?

The register’s deployment category holds four records. Three are public legal-information chatbots: Illinois Court Help’s Lex (live 28 January 2025), the Nevada judiciary’s self-help chatbot (3 March 2025) and Lone Star Legal Aid’s Navi in Texas (Legal Services Corporation account, 13 May 2026). The fourth is Garfield’s trial account. None of the three public chatbots needed a sandbox.

Courts and legal-aid bodies give legal information under their own authority. Lex guides court users to court resources (Illinois announcement); Navi identifies legal problems, refers users and shares self-help materials (LSC account). The Nevada page returned HTTP 403 on 5 October 2026 (register record). Wider public-sector use is in the justice-sector deployments report.

Timeline

Date	Event	Source
14 Aug 2020	Utah Standing Order 15 effective; sandbox opens	Standing Order 15
26 May 2021	First BC no-action letters in the register (Willful, SimpleArb, cohabitation-agreement platform)	LSBC letters
9 Sep 2021	BGH smartlaw: document generator not a legal service	BGH I ZR 113/20
Nov 2021	Ontario A2I launched	LSO June 2025 report
16 Aug 2022	Utah amended orders for Superlegal and 1Law; FOCL Law terminated	Utah orders
21 Sep 2022	Standing Order 15 second amendment (current text; expiry on the seventh anniversary of 14 Aug 2020)	Standing Order 15
17 Nov 2023	MillerKing v DoNotPay dismissed for lack of standing	S.D. Ill. ECF 34
30 Jul 2024	Faridian v DoNotPay dismissed with prejudice after settlement	N.D. Cal. ECF 83
5 Sep 2024	Utah court letter: Utah innovation requirement; low-innovation entities to exit	Utah letter
14 Jan 2025	FTC DoNotPay decision and order issued ($193,000)	FTC C-4812
23 Jan 2025	Eight Utah Phase 2 terminations for non-response or non-implementation	Utah orders
27 Jan 2025	Fifteen Utah low-innovation ABS terminations with Rule 5.4 waivers, incl. Darrow AI / Edward & Mansfield	Utah orders
27 Mar 2025	Utah SB 226 signed	Legislation register
6 May 2025	SRA announces Garfield.Law authorisation	SRA release
25 Jun 2025	LSO A2I report: 17 participants, 119,848 services	LSO Convocation
9 Sep 2025	Upsolve v James: intermediate scrutiny; injunction vacated	2d Cir.
15 May 2026	Utah Phase 3 announced; sunsetting the sandbox	Utah Phase 3 page
29 May 2026	Utah application cut-off	Utah Phase 3 page
7 Jul 2026	FTC proposed AI-accuracy policy statement cites DoNotPay	Federal Register 2026-13628
17 Aug 2026	SRA Misuse of AI warning notice	SRA
14 Aug 2027	Utah sandbox sunset date	Standing Order 15; register page

What to watch

• Utah’s regulatory-reform report: the committee’s final report will say which reforms survive the August 2027 sunset, including any route for software providers. Agendas are on the Utah courts committee page.
• Ontario’s next A2I report: A2I is a five-year pilot launched in November 2021; the June 2025 report says it “is set to conclude in November 2026”.
• The FTC policy statement: comments closed on 31 July 2026; a Federal Register search on 5 October 2026 returned only the July proposal.
• New York’s chatbot-impersonation bills: S7263, A6545 and S10675 are in committee.
• SRA follow-up on AI-driven firms: the May 2025 release said the SRA “will be monitoring progress of this new model closely”. No published follow-up was located by 5 October 2026.

Appendix A: data tables

A1. Enforcement register by category and jurisdiction (v0.1.1, 43 records)

Category	Canada	US state	US federal	England & Wales	Germany	Total
sandbox-authorisation	19	5	0	1	0	25
upl-litigation	0	4	0	0	1	5
regulator-register	2	2	0	0	0	4
court-a2j-deployment	0	3	0	1	0	4
policy-statement	0	1	1	1	0	3
regulator-enforcement	0	0	2	0	0	2
Total	21	15	3	3	1	43

Canada’s 19 sandbox records are 13 Ontario providers and 6 BC letters; the 5 US-state sandbox records are Utah entities. The Germany record is coded eu in the dataset.

A2. Utah sandbox roster, coded (register and orders read 5 Oct 2026)

Names	List	Order date	Exit reason
1Law; Superlegal (LawGeex / Legalogic)	Authorized	16 Aug 2022 (amended)
Elysium Legal; Pearson Butler; Rasa Public Benefit Corp.	Authorized	21 Sep 2022
Community Justice Advocates of Utah	Authorized	30 Jun 2026 (amended packet)
USU Transforming Communities Institute	Authorized	3 Sep 2026 (amended)
i4J	Standing order	SO16 amended 15 May 2025
Centro Hispano; Legal Assistance J.; Mercedes-Argo (2 Aug 2023); Divorcio Amigable (10 Apr 2023)	Provisional	Provisional orders	Expired
LawPal; Xira Connect	Provisional	5 May 2025	Expired, not launched
DSD Solutions	Provisional	16 Apr 2024	Withdrew
Boundless Immigration; Darrow AI / Edward & Mansfield; Davis & Sanchez; Firmly; Hayman-Woodward Human Capital; Herbert & Greenwald; Immigration Office Solutions; MyImmigration; Olson & Partners; R&R Legal Services; Standout Legal; Trajan Estate; Bike Legal Utah; Blue Ridge Law Group; Trajector Legal	Rule 5.4 waiver	27 Jan 2025	Low-innovation ABS
LegalAtoms; Nuttall, Brown & Coutts (ZAF Legal) (7 Mar 2025); Law on Call (5 May 2025)	Rule 5.4 waiver	As stated	Low-innovation ABS
Michelle Turpin PC	Rule 5.4 waiver	20 Nov 2025	Own request; stated it operated as low innovation
Esquire Law; Melendez Legal; PD Digital Design Logistics; Savvi Technologies; VisaPlace (23 Jan 2025); Estate Guru (8 Oct 2025)	Previously authorized	As stated	Phase 2: unresponsive
Hello Divorce; Jordanelle Blocks; Visa Finder Immigration	Previously authorized	23 Jan 2025	Phase 2: model not implemented or launched
Motion Law; Off the Record; WaltonParke	Previously authorized	7 Mar 2025	Phase 2: requirements not met
FOCL Law (16 Aug 2022); D4U Immigration (23 Mar 2023)	Previously authorized	As stated	Data reporting failure; inaccurate disclosures at application
Blue Bee Bankruptcy, LawHQ, Utah Legal Advocates (21 Dec 2022); AGS Law, Believe First (17 May 2023); AAA Fair Credit (15 Nov 2023); Mountain West Legal Protective (16 Apr 2024); GovAssist Legal (2 May 2024); Angel Advocates, Premium Visa, Truinta, Waylit (26 Jun 2024); Lindenberg Law Group (9 Sep 2024); Mina Legal Services, Rocket Lawyer / Rocket Legal Professional Services (18 Dec 2024); Fair Credit, Rocky Mountain Justice (23 Jan 2025); Holy Cross Ministries, Timpanogos Legal Center (15 Jul 2025)	Previously authorized	As stated	Withdrew or ended participation
Robert DeBry; Tanner LLC	Previously authorized	No order linked	Not recorded

A3. BC platform services among 68 participants

Service (as described by the Law Society)	Letter date	In enforcement register
Willful: online wills and powers of attorney	26 May 2021	Yes
SimpleArb: online settlement negotiation	26 May 2021	Yes
Online cohabitation, prenuptial and post-nuptial agreements	26 May 2021	Yes
Tellalawyer: online lawyer referral	2021 (file name; letter not opened)	No
LegalWills.ca: create, store and share estate documents	8 Feb 2022	Yes
Divii: online separation agreements	16 Nov 2022	Yes
Jointly: automated family-law agreements	17 Jul 2025	Yes

A4. Ontario A2I providers (Wayback capture, 6 Mar 2026)

Group	Providers	AI named in description
Online wills and estate planning	ClearEstate, eState Planner, LegalWills, Willful	No
Real estate	Deeded, Ownright, Philer	Philer
Incorporation and corporate maintenance	Counselurdocs, Incorporight, SkyLaunch	No
Family law	Plaid Fertility Law, Jointly	No
Immigration	PR Coach	No
Consumer rights	airfairness	airfairness

A5. Consumer-legal tools in the directory and regulator records

Tool record	Regulator record in this report
DoNotPay	FTC decision and order, 14 Jan 2025; two 2023 private suits
Garfield.Law	SRA authorisation announced 6 May 2025
Rocket Lawyer (Rocket Copilot)	Utah sandbox, withdrew effective 20 Dec 2024; affiliate active in Arizona ABS directory (7 Sep 2026)
Lawhive	Site states SRA-regulated affiliate; no SRA announcement in this record
LegalZoom AI, Lawfully, Lawpath	None found in the registers read

Appendix B: sources

Primary documents (all fetched 5 October 2026 unless stated):

• Utah Supreme Court, Standing Order No. 15 (amended 21 Sep 2022); Standing Order No. 16 (amended 15 May 2025)
• Utah Office of Legal Services Innovation, authorized entities and the 66 documents linked from it; metrics (August 2026); Phase 2; Phase 3
• Utah Supreme Court, letter to the Legal Services Innovation Committee, 5 Sep 2024
• Utah State Bar, State Bar News item in the Utah Bar Journal, Nov/Dec 2024
• Utah orders quoted: Superlegal / LawGeex; 1Law; Rasa; Darrow AI / Edward & Mansfield; Divorcio Amigable; Michelle Turpin PC; FOCL Law; D4U Immigration; Rocket Lawyer; Law on Call
• Law Society of British Columbia, about the innovation sandbox; approved participants; Jointly no-action letter, 17 Jul 2025; Divii no-action letter
• Law Society of Ontario, participating providers (Wayback, 6 Mar 2026); A2I update report, June 2025
• Arizona Judicial Branch, ABS directory (Wayback, 7 Sep 2026)
• Solicitors Regulation Authority, SRA approves first AI-driven law firm (6 May 2025); Misuse of AI warning notice (17 Aug 2026)
• Federal Trade Commission, In re DoNotPay, decision and order, C-4812; Federal Register 2024-22400 and 2026-13628
• MillerKing, LLC v DoNotPay, Inc., S.D. Ill. No. 3:23-cv-863, ECF 34
• Faridian v DoNotPay, Inc., N.D. Cal. No. 3:23-cv-01692, ECF 73, ECF 83
• Upsolve, Inc. v James, 2d Cir. No. 22-1345, opinion of 9 Sep 2025
• Bundesgerichtshof, Urteil vom 9. September 2021, I ZR 113/20
• Ministry of Justice of Japan, guideline on AI contract services and Attorney Act article 72 (August 2023); Česká advokátní komora, Stanovisko on AI (2023)
• Garfield AI, first-party trial account, 22 Jun 2026; Illinois Courts, Meet Lex (28 Jan 2025); Legal Services Corporation, Lone Star Legal Aid chatbots (13 May 2026)
• Not reachable by our fetcher on 5 October 2026: nvcourts.gov (HTTP 403), le.utah.gov SB 226 page (timeout), lso.ca (HTTP 403), azcourts.gov (Cloudflare challenge)

SafeLegalAI records and datasets:

• Enforcement register (JSON); records cited: Darrow AI / Edward & Mansfield, Arizona directory, Airfairness, Philer, Garfield trial account, Nevada chatbot
• Regulatory map category: unauthorised practice (map JSON); legislation register (JSON); tools directory (JSON)
• Related reports: Consumer AI legal services and self-represented litigants; 41 US AI bills; Where justice systems use AI; incident tracker row Ayinde v Haringey

Appendix C: changes to this report

None at first publication.