Utah rules
Can a Utah law firm still pay for referrals after November 1, 2026, and what does Rule 7.1 allow?
Utah has one advertising rule and no filing. From November 1, 2026, referral fees are banned, though lead generation and pay-per-click fees are not referral fees.
By Santiago Alvarez, Founder, Ad Hoc Digital
Last updated
The short answer
If you read one part of this page, read this.
Utah lawyer advertising is governed by a single rule, Rule 7.1 of the Utah Rules of Professional Conduct, now part of the Supreme Court Rules of Professional Practice. The Utah Supreme Court repealed Rules 7.2 to 7.5 and adopted the short Rule 7.1 effective August 31, 2020. Nothing is filed, and the rule bans false or misleading communications, coercive contact, and, since May 1, 2024, direct contact about a disaster, injury or death within 30 days.
The bigger change for marketing budgets started on November 1, 2026. Under an order dated July 31, 2026, Rule 5.4(c) now reads "Referral fees are prohibited.", and new Rule 5.8 sets conditions for sharing fees with other lawyers. Until October 31, 2026, State Bar Opinion 25-02 read the rules to allow referral fees. A new comment to Rule 1.0, effective the same day, says fees for lead generation services, online banner advertising and pay-per-click marketing are not referral fees.
Nonlawyer ownership and fee sharing with nonlawyers still need authorization under Standing Order No. 15, the regulatory sandbox, which is closed to new applications. This is a plain summary for marketing planning, not legal advice. Check the current rule with your bar or law society. We work with law firms across the US and Canada, and also in Australia and the UK.
Which rules apply
Utah's advertising law is one rule, Rule 7.1, with Rules 5.4 and 5.8 deciding who you may pay.
The Supreme Court Rules of Professional Practice list Rule 7.1 under Information About Legal Services and Rules 7.2 to 7.5 as "Reserved."
| Rule | What it covers | Marketing effect |
|---|---|---|
| 7.1(a) | No false or misleading communication, including results claims and testimonials | Results and reviews are allowed if they don't create unjustified expectations |
| 7.1(b) | No coercion, duress or harassment of a prospective client | In-person contact isn't banned, but pressure is |
| 7.1(c) | No direct contact about a disaster, injury or death within 30 days (since May 1, 2024) | Targeted injury outreach waits a month |
| 5.4 | Professional independence; nonlawyer fee sharing and ownership only as authorized under Standing Order No. 15 | From November 1, 2026: "Referral fees are prohibited." |
| 5.8 (new) | Fee sharing between lawyers, effective November 1, 2026 | Splits only with client consent in writing and no higher total fee |
| 1-701 to 1-705 | Office of Legal Services Innovation and the sandbox | The route for nonlawyer-owned providers, closed to new applications |
Comment [12] says plainly: "This Rule differs from the ABA Model Rule." The 2020 summary of the change said it eliminated "the prohibition against in-person solicitation". Our ABA Model Rules guide covers the longer model text Utah left behind.
Filing and record keeping
Utah has no filing, review or record-keeping rule for lawyer ads.
Rule 7.1 has three paragraphs and none asks for a filing, a fee, a label or a copy of the ad. The Utah State Bar's Ethics Advisory Opinion Committee publishes opinions, but no rule makes them a pre-launch approval.
Check the claim
Ask whether each statement is true, complete and unlikely to create an "unjustified or unreasonable expectation about results" (Rule 7.1(a)(2)).
Check who is reached
A message to a specific person about a disaster, injury or death waits more than 30 days, unless an exception in Rule 7.1(c) applies.
Check who is paid
Any payment tied to a referral is tested against Rules 5.4 and 5.8 from November 1, 2026, and against Utah Code 76-17-202 and 78B-3-111 now.
Keep your own copies
No rule requires it, but a saved version of each ad answers any later complaint about what it said.
That's lighter than Nevada, which files ads with its State Bar, and lighter than Colorado's five-year file for solicitations.
What every ad must include
Utah's rule sets no required wording; the duty is to leave nothing out that would mislead.
Unlike the rules in Arizona, Colorado and New Mexico, Utah's Rule 7.1 has no paragraph requiring a lawyer's name and contact information in each ad. The test is Rule 7.1(a)(1): no material misstatement and no omission that makes the ad "considered as a whole" misleading.
- Licensing (Opinion 22-04): an out-of-state injury firm with no Utah-licensed lawyer that advertises in Utah violates Rule 7.1 unless an appropriate disclaimer or qualifying language is included.
- Fees: the same opinion lists earlier Utah opinions, including one finding a "$99" bankruptcy ad misleading because it ignored required court fees.
- Firm names (comment [7]): a trade name, website address or social media username is fine if it doesn't imply a link to a government agency, an unconnected lawyer or a legal aid group.
- Part-time legislators (comment [10]): a firm may keep the name of a lawyer serving in Utah's part-time legislature while that lawyer stays with the firm.
- What's allowed (comment [3]): names, contact details, services, fee basis, the courts where the lawyer may practice, and "the use of actors or dramatizations", so long as nothing is false or misleading.
We still put the firm's name and a phone number or link in every ad, because an ad that hides who is behind it invites the omission question. Our ad copy rules guide shows short formats that carry it.
Results, testimonials and dramatizations
Utah allows results, testimonials and actors, judged by whether they set unjustified expectations.
Rule 7.1(a)(2) and (3) name the two risks directly: a communication "likely to create an unjustified or unreasonable expectation about results", and a testimonial or endorsement that violates the rule.
| Content | Utah's rule | Source |
|---|---|---|
| Past results | Can mislead without the case's factual and legal circumstances; a disclaimer or qualifying language may prevent that | 7.1(a)(2), comment [4] |
| Comparisons with other lawyers | Misleading if unsubstantiated and specific enough to look provable | Comment [4] |
| Client testimonials and endorsements | Allowed unless they break any part of Rule 7.1 | 7.1(a)(3) |
| Actors and dramatizations | Expressly permitted to portray the lawyer, firm, client or events, if not false or misleading | Comment [3] |
| Live contact | Not banned; the lawyer "should proceed with caution" to avoid coercion, duress or harassment | 7.1(b), comment [6] |
Of the four Mountain West rulebooks we read for this series, only Utah's says outright that actors are permitted, so the question for a Utah video is only whether viewers would take the scene as real. Our testimonials guide compares stricter states.
Specialist and certified
A Utah lawyer may say "specializes", but "certified" needs an objective certifier named in the ad.
Comment [5] to Rule 7.1 covers both: describing a field is allowed, and a certification claim is allowed only with a named objective entity.
- Fields and focus: a lawyer "can state that he or she 'specializes' in a field based on experience, training, and education", judged by the false or misleading standard.
- Certification: no stating or implying certification as a specialist "unless the lawyer has been certified as a specialist by an objective entity and the name of the entity is clearly identified in the communication."
- No state program is named in the comment, so the certifier's name carries the claim.
Direct contact and paying for leads
Utah waits 30 days after injuries, and from November 1, 2026 it bans referral fees but not lead generation.
Rule 7.1(c) took effect May 1, 2024, after a petition about solicitation soon after traumatic events; the Court's summary says it was redrafted to address that concern more narrowly.
- The 30-day rule (7.1(c))
No direct communication with a prospective client to obtain employment about a disaster, personal injury or wrongful death, unless it happened more than 30 days before, the person has a familial, close personal or prior professional relationship with the lawyer or firm, or the person (or close family or a friend) asked first.
- Referral fees until October 31, 2026
Opinion 25-02 (August 13, 2025) read the 2020 rules to allow referral fees to lawyers and nonlawyers, subject to rules such as 1.4 and 1.6, and the Bar later added a caution note about proposed Rule 5.8. Comment [3] to the current Rule 5.4 ties paying for referrals to Standing Order No. 15; the opinion reads that comment as going beyond the rule's text.
- Referral fees from November 1, 2026
Rule 5.4(c): "Referral fees are prohibited." Rule 1.0 defines a referral fee as compensation paid to anyone outside the firm solely for referring a legal matter.
- What isn't a referral fee
The new comment to Rule 1.0: fees for "generating consumer interest", including "lead generation service providers, online banner advertising, pay-per-click marketing", and small gifts of marginal or minimal value.
- Sharing fees with lawyers (5.8)
No share is paid before the client's fee is payable, the total fee doesn't rise, the client agrees to each lawyer's share in writing, and each share is reasonable.
- The disclosure statute (78B-3-111)
A client may sue to recover a client referral fee a lawyer paid to a nonlawyer if it wasn't disclosed before the client paid or became obligated to pay. Marketing fees, including pay-per-click, that don't depend on the firm signing the client are excepted.
- The kickback statute (76-17-202)
Offering or paying a kickback or bribe to induce a referral for a good or service tied to an insurance claim or a claim for damages is a third degree felony, with exceptions for unpaid medical referrals by lawyers, lien payments and general marketing to medical providers.
Contrast Arizona, which removed its referral limits in 2021, and the New Mexico guide, where a statute targets claim solicitation. Our paying for leads guide compares other states.
Channel by channel
What Utah's rules mean for search ads, Local Services Ads, social media and AI search content.
Comment [1] says Rule 7.1 "governs all communications about a lawyer's services", so every channel is covered, and the November 2026 comment names pay-per-click and lead generation outright.
| Channel | What the rule means there | The rule |
|---|---|---|
| Google search ads | Pay-per-click fees are not referral fees; results claims still need context | 1.0 comment (from Nov. 1, 2026); 7.1(a)(2) |
| Local Services Ads | Fees for generating consumer interest are outside the referral fee ban; the profile's claims face the misleading test | 1.0 comment; 7.1(a) |
| Facebook and Instagram ads | Actors and dramatizations allowed if not misleading; testimonials can't set unjustified expectations | 7.1(a)(3), comment [3] |
| Social media posts | A direct message to someone just hurt waits more than 30 days unless they reached out first | 7.1(c) |
| Website and AI search content | Pages and bios AI search tools may quote should show where the firm's lawyers are licensed, especially for out-of-state firms | 7.1(a)(1); Opinion 22-04 |
How the two Google programs differ is in our Local Services Ads vs Google Ads guide. Our Google Ads service builds and runs search campaigns within these lines.
What we check
Our Utah review: who gets paid before November 1, then what the ads say.
When we review a Utah firm's marketing, we check every payment that depends on a referral first, because the November 1, 2026 rules change what's allowed while the advertising rule stays the same.
List every payment tied to a case
Referral partners, past clients paid for referrals, and other firms sharing fees go on one list for the firm's lawyers to test against Rules 5.4 and 5.8.
Separate ad spend from referral fees
Search, Local Services Ads, banner and lead generation costs are recorded as marketing, which the Rule 1.0 comment keeps outside the ban.
Set the 30-day hold
Messages, letters or calls to a specific person about an injury, death or disaster wait unless that person reached out first.
Read every result and testimonial
Each one either carries context or comes out.
Show where lawyers are licensed
A firm with no Utah-licensed lawyer says where its lawyers are licensed in every Utah ad, following Opinion 22-04.
One case study, $10,875 Generated In Just The First Week, came from Google search ads for a real estate practice; the amount is the firm's result, not an ad claim. For that practice, see our real estate marketing page. Firms licensed nearby can compare Nevada, next door to the west.
Common mistakes
Where firms go wrong.
Utah mistakes we look for in accounts firms bring to us.
Keeping referral deals past October 31, 2026
From November 1, 2026, Rule 5.4(c) reads "Referral fees are prohibited."
Paying medical providers for referrals
Utah Code 76-17-202 makes paying a kickback to induce a referral tied to a damages or insurance claim a third degree felony.
Injury messages in the first 30 days
Rule 7.1(c) bars direct communication about a disaster, injury or death within 30 days unless an exception applies.
Out-of-state firms that don't say so
Opinion 22-04 treats advertising in Utah without a Utah-licensed lawyer, and without a disclaimer, as a Rule 7.1 violation.
"Certified" with no certifier named
Comment [5] to Rule 7.1 allows a certification claim only with an objective certifying entity clearly identified.
Real results
What this looked like for real firms.
Published real estate, DUI and bankruptcy results, from firms whose case studies don't name their state.
Identifying details are anonymized to protect our clients. Individual result, not a promise or prediction of any specific outcome for your firm.
FAQ
Questions lawyers ask us.
Straight answers to the questions that come up most.
Do Utah lawyers have to file ads or keep copies?
No. Rule 7.1 has no filing, label or record-keeping requirement, and Rules 7.2 to 7.5, where those provisions sat, were repealed effective August 31, 2020.
Can a Utah lawyer pay for referrals?
Until October 31, 2026, Opinion 25-02 said referral fees were not a per se violation. From November 1, 2026, Rule 5.4(c) prohibits referral fees, and fee sharing with another lawyer must meet new Rule 5.8. Before and after that date, Utah Code 76-17-202 makes a kickback for a referral tied to an insurance or damages claim a felony.
Is paying for leads or Google ads a referral fee in Utah?
No. The new comment to Rule 1.0, effective November 1, 2026, says fees for generating consumer interest, including lead generation service providers, online banner advertising and pay-per-click marketing, are not referral fees.
How soon can I contact an injury victim in Utah?
A direct communication seeking the case must wait until more than 30 days after the disaster, injury or death (Rule 7.1(c)), unless you have a familial, close personal or prior professional relationship, or the person or their close family asked first.
Can a Utah firm use actors in its ads?
Yes. Comment [3] to Rule 7.1 lists "the use of actors or dramatizations to portray the lawyer, law firm, client, or events" among permitted content, so long as it isn't false or misleading.
Can nonlawyers own a Utah law firm?
Only if authorized under Utah Supreme Court Standing Order No. 15 (Rule 5.4). The Office of Legal Services Innovation says the sandbox is closed to new applications and set to sunset on August 14, 2027.
How does Utah compare with its neighbours?
Utah's single rule is shorter than Colorado's three, and Nevada files ads within 15 days. Our state-by-state list shows every state we cover.
Where we do this
The services this guide touches.
What this looks like when we run it for a firm, with a demo for your practice on each page.
Sources
Where these facts come from.
Official pages we read when writing this page. The Court posts the November 1, 2026 changes to Rules 1.0 and 5.4 as redlines, so we quote only wording that reads clearly and paraphrase the rest. We didn't open the current text of Standing Order No. 15. Platforms and rules change, so check the current version before you act on any of it. This is marketing guidance, not legal advice.
- Utah Courts, Supreme Court Rules of Professional Practice (index, Chapter 3 Rules of Professional Conduct)
- Utah Supreme Court, Rule 3-7.1 Communications concerning a lawyer's services
- Utah Supreme Court, Rule 3-5.4 Professional independence of a lawyer (text before November 1, 2026)
- Utah Supreme Court, Rule 1-701 Office of Legal Services Innovation, purpose
- Utah Courts, approved amendments to Rule 7.1 (2015, 2020 and 2024)
- Utah Supreme Court, order repealing Rules 7.2 to 7.5 and amending Rule 7.1, effective August 31, 2020
- Utah Supreme Court, order of December 6, 2023 amending Rule 7.1, effective May 1, 2024
- Utah Supreme Court, Rule 7.1 redline adopted December 6, 2023
- Utah Courts, approved amendments to the Rules of Professional Conduct (including those effective November 1, 2026)
- Utah Supreme Court, order of July 31, 2026 adopting Rules 1.0, 1.4, 1.5, 5.4, 8.4 and new Rule 5.8, effective November 1, 2026
- Utah Supreme Court, Rule 5.8 Fee sharing between lawyers (effective November 1, 2026)
- Utah Supreme Court, Rule 5.4 as amended effective November 1, 2026 (redline)
- Utah Supreme Court, Rule 1.0 Terminology as amended effective November 1, 2026 (redline)
- Utah Office of Legal Services Innovation (regulatory sandbox)
- Utah State Bar, Ethics Advisory Opinions
- Utah State Bar Ethics Advisory Opinion Committee, Opinion 25-02 (referral fees, August 13, 2025)
- Utah State Bar Ethics Advisory Opinion Committee, Opinion 22-04 (out-of-state firm advertising in Utah)
- Utah Legislature, Utah Code 78B-3-111 Cause of action for an undisclosed referral fee
- Utah Legislature, Utah Code 76-17-202 Unlawful conduct concerning a kickback or bribe
Written by
Founder of Ad Hoc Digital. Leads strategy and works directly with every client firm on AI search, Local Services Ads, Google Ads and Meta ads.
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