Utah’s Sandbox: Interim Reports and the Case for Evaluation

In 2020, the Utah Supreme Court launched the nation’s first legal regulatory sandbox. The Sandbox was designed to open the door to new kinds of legal service providers and business structures, including entities with nonlawyer ownership and nonlawyer practitioners, who could offer legal services under close regulatory oversight. The core question driving this initiative was straightforward but profound: Can we regulate legal service delivery in ways that expand access to legal services while still protecting consumers?

The Sandbox was not created in a vacuum. For decades, people have been pointing to the widening gap in access to affordable legal help. At the same time, traditional rules of professional conduct have tightly constrained who can deliver legal services and how they can be delivered. The central goals of these rules are to ensure quality and protect the public, but historically they have also made it nearly impossible to test innovative approaches to providing legal services. Utah decided to try something different: loosen those restrictions in a controlled environment while setting clear guardrails for consumer protection.

IAALS’ Evaluation of Utah’s Sandbox

IAALS has served as an independent evaluator of the Sandbox since it was first implemented. We have now completed our interim evaluation, with findings published across a four-part report series detailing our approach and findings for each component of our evaluation over the first five years of Sandbox operations. We are releasing these reports on a rolling basis, with the first two reports launching today.

• Part 1: Sandbox Background and Evaluation Design Overview – Provides context for the Sandbox and outlines our evaluation framework.
• Part 2: Process Evaluation – Examines how the Sandbox has been designed and implemented, including a detailed look at its structures, activities, and policy changes.

Our third and fourth reports will be published in November 2025 and January 2026, respectively.

• Part 3: Outcomes Evaluation – Analyzes the results the Sandbox has produced to date, such as the entities authorized, the services provided, the quality of those services, and how entity goals align with the Sandbox’s objectives.
• Part 4: Social Return on Investment (SROI) Analysis – Estimates the social and economic value the Sandbox has generated relative to the investments made.

These interim reports provide formative findings. They capture how the Sandbox has evolved, what early outcomes are beginning to take shape, and where challenges remain. They also reflect the rigor of IAALS’ approach, which draws on multiple data sources: monthly activity reports, surveys of Sandbox entities, structured discussions with Sandbox leadership, and archival records. This diversity of evidence allows us to triangulate findings and offer a more reliable picture of what is happening in practice.

At the conclusion of the pilot in 2027, IAALS will publish a final evaluation that will synthesize data across the entire seven-year pilot period, offering a comprehensive assessment of the Sandbox’s overall impact.

The Critical Nature of Evaluation

For a reform of this magnitude, evidence is essential. Evaluation provides a structured way to understand what is happening inside the Sandbox: how it is functioning, what results are emerging, and where adjustments may be needed. It is not about declaring the Sandbox a success or a failure. Rather, it is about learning—gathering the data and insights necessary to ensure that the Sandbox is meeting its goals of expanding access to legal services while protecting consumers. Just as importantly, evaluation creates transparency for the public, the profession, and policymakers who need reliable evidence about the risks and benefits of trying something new.

There are different kinds of evaluation, and each can add considerable value in understanding how a program is functioning. Process evaluation, outcomes evaluation, and social return on investment (SROI) are the three types most relevant to our interim evaluation of the Sandbox.

Process evaluation looks at structures, activities, and decision-making processes, helping us understand whether a program is functioning as intended and why certain successes or challenges emerge. This kind of evaluation is especially valuable in identifying lessons learned and opportunities for improvement.

Outcomes evaluation asks whether the program is producing the results it set out to achieve. It connects the program’s activities to its intended goals, providing evidence of what difference the program is making for the people and systems it touches. For the Sandbox, outcomes evaluation tells us whether new models of legal service delivery are actually expanding access to justice while protecting consumers.

Finally, SROI analysis estimates the economic and social value generated by a program relative to the resources invested. SROI translates impacts into broadly understandable terms—such as cost savings for consumers and community benefits—that provide evidence-based estimates of the overall value of the reform.

Each of these approaches can be valuable on its own, but together they provide a far more complete picture. This integrated approach gives policymakers, courts, and the public the best possible evidence for making decisions about the future of regulatory reform.

This evidence matters because the stakes are high. Millions of people every year face legal problems—divorce, eviction, debt collection, employment disputes—without affordable help. For too long, our regulatory system has left them with few options: go it alone, pay more than they can afford, or forego their rights entirely. The Sandbox is one attempt to test whether new models can fill that gap. Evaluation can tell us whether that attempt is working, where it is falling short, and what adjustments might be necessary.

Utah’s Sandbox is a bold experiment in addressing some of the legal profession’s most entrenched problems. But boldness alone is not enough. Evidence must guide the way. That is what IAALS’ evaluation is about: shining a light on what is happening, sharing lessons learned, and helping courts and policymakers in Utah and across the country make informed choices about the future.