OHIO LEGISLATIVE SERVICE COMMISSION
Office of Research Legislative Budget
www.lsc.ohio.gov and Drafting Office
H.B. 476 Bill Analysis
135th General Assembly
Click here for H.B. 476’s Fiscal Note
Version: As Introduced
Primary Sponsors: Reps. Cutrona and Hillyer
Effective date:
Logan Briggs, Attorney
SUMMARY
 Creates the Universal Regulatory Sandbox Program.
 Establishes the Universal Regulatory Sandbox Program Advisory Committee and a
regulatory relief office to administer the sandbox program.
 Provides guidelines and required materials for the sandbox program application.
 Describes the evaluation process of applicants to the Universal Regulatory Sandbox
Program.
 Establishes guidelines on the limits of an approved participant’s demonstration and
offering.
 Requires participants in the sandbox program to make certain disclosures to consumers
before engaging in transactions.
 Establishes recordkeeping requirements for sandbox program participants.
 Permits a participant to request an extension of the demonstration period of up to
12 months.
 Implements reporting requirements for sandbox program participants, state agencies,
and the regulatory relief office.
 Requires the regulatory relief office to collect public suggestions to reform state laws
and regulations to reduce regulatory burdens.
TABLE OF CONTENTS
Universal Regulatory Sandbox Program ......................................................................................... 2
Regulatory relief office ................................................................................................................ 3
Universal Regulatory Sandbox Program Advisory Committee ................................................... 3
May 21, 2024
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Universal Regulatory Sandbox Program application ...................................................................... 4
Required materials ...................................................................................................................... 4
Fees.............................................................................................................................................. 5
Regulatory relief office review .................................................................................................... 6
Agency review ............................................................................................................................. 6
Preliminary application denial..................................................................................................... 6
Advisory Committee review ........................................................................................................ 7
Application denial........................................................................................................................ 8
Participation in the Universal Regulatory Sandbox Program ......................................................... 8
General ........................................................................................................................................ 8
Required disclosures ................................................................................................................... 9
Recordkeeping requirements ...................................................................................................... 9
Removal from the Universal Regulatory Sandbox Program ..................................................... 10
Demonstration period expiration and extensions ........................................................................ 10
Reporting requirements................................................................................................................ 11
Regulatory relief office .............................................................................................................. 11
Sandbox participants ................................................................................................................. 11
State agencies............................................................................................................................ 11
Public suggestions and recommendations................................................................................ 12
DETAILED ANALYSIS
Universal Regulatory Sandbox Program
The bill creates a Universal Regulatory Sandbox Program under the Department of
Commerce. Unlike the existing regulatory sandbox program found in Chapter 1355 of the
Revised Code, which only pertains to novel financial products or services, this universal
regulatory sandbox program (referred to, hereafter, as the “sandbox program”) applies to any
innovative product or service across all industries. Businesses may apply to offer a new product
or service through the sandbox program which would otherwise be prohibited by certain state
laws or regulations, or without the business needing to obtain a license or authorization that
might otherwise be required. If the application is approved, certain laws or regulations may be
temporarily waived or suspended with respect to that product or service, permitting the
business to demonstrate the value of relaxing certain statutory or regulatory restrictions on
businesses and industries.1
1 R.C. 1357.02(A); R.C. 1355.02, not in the bill.
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Regulatory relief office
The bill requires the Director of Commerce to establish a regulatory relief office within
the Department of Commerce, which is responsible for administering the sandbox program and
applications for participation. The regulatory relief office will also act as the liaison between
private businesses and state agencies to identify state laws or regulations that could be waived
or suspended under the sandbox program.2
The bill permits the regulatory relief office to do all of the following:
 Identify state laws and regulations which it believes unnecessarily inhibit the creation
and success of new companies or industries in Ohio;
 Make recommendations to the Governor and the General Assembly regarding modifying
those laws and regulations;
 Create a framework through which to analyze the risk to health, safety, and well-being
of consumers as a result of permanently removing or temporarily waiving state laws and
regulations that inhibit the creation or success of new and existing companies or
industries in Ohio;
 Propose reciprocity agreements between states that use, or are proposing to use,
similar regulatory sandbox programs to the sandbox program proposed by the bill, or to
the existing sandbox program under Chapter 1355 of the Revised Code.3
The regulatory relief office is permitted to adopt rules as necessary to administer the
sandbox program, including rules that establish application and reporting requirements, and
that allow for cooperation and consultation with the Superintendent of Financial Institutions to
ensure cooperation with the existing regulatory sandbox program under Chapter 1355 of the
Revised Code.4
Universal Regulatory Sandbox Program Advisory Committee
The bill creates the Universal Regulatory Sandbox Program Advisory Committee
(referred to, hereafter, as the “Advisory Committee”) within the Department of Commerce,
comprised of 11 members who will advise and make recommendations to the regulatory relief
office. The bill requires the Advisory Committee to review applications for participation in the
sandbox program and to make recommendations to the regulatory relief office as to whether
an application should be approved.5
The bill establishes the initial Advisory Committee members as follows:
2 R.C. 1357.02(B).
3 R.C. 1357.02(C).
4 R.C. 1357.02(C)(4).
5 R.C. 1357.04(A).
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 Three members, appointed by the Director of Commerce, representing business
interests from a variety of industry clusters, who will serve a term ending January 1,
2027;
 Three members, appointed by the Director of Commerce, representing business
interests from a variety of industry clusters, who will serve a term ending January 1,
2029;
 Two members, appointed by the Director of Commerce, representing state agencies
which regulate business, who will serve a term ending January 1, 2027;
 One member, appointed by the Director of Commerce, representing state agencies
which regulate business, who will serve a term ending January 1, 2029;
 One member of the Senate, appointed by the President of the Senate, who will serve a
term ending January 1, 2029;
 One member of the House of Representatives, appointed by the Speaker of the House
of Representatives, who will serve a term ending January 1, 2029.
The Committee members, who serve without compensation, must be appointed within
30 days after the bill’s effective date, and any subsequent vacancies on the Advisory Committee
must be filled in the same manner by the same appointing authority. After the initial term for
each member appointed by the Director of Commerce, each subsequent member will serve a
term lasting four years. Committee members appointed from the Senate or the House of
Representatives will serve a term of two years or for the remainder of their legislative term,
whichever is less.6
The Director of Commerce will select a chairperson for the Advisory Committee each
year, and the Committee will meet at the call of the chairperson. The initial meeting must occur
within 30 days after the last member’s appointment. A majority of members constitutes a
quorum for the Advisory Committee to conduct business. If needed, the regulatory relief office
will provide technical and administrative support to the Committee. The Advisory Committee is
not a public body required to conduct public meetings.7
Universal Regulatory Sandbox Program application
Required materials
The bill requires any person seeking to participate in the sandbox program to submit an
application to the regulatory relief office. If requested, the office must assist a person
interested in participating in the sandbox program with preparing an application. The form and
manner of the application are set by the regulatory relief office, but the bill requires it to
include, at a minimum, all of the following:
6 R.C. 1357.03(B), (C), and (D).
7 R.C. 1357.03(E), (F), and (G).
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 Confirmation that the applicant is subject to the jurisdiction of the Department of
Commerce;
 Confirmation that the applicant has established a physical or virtual location in the state,
from which it will demonstrate an innovative offering and where all required records,
documents, and data will be maintained;
 The applicant’s relevant personal and contact information, including legal names,
addresses, telephone numbers, email addresses, website addresses, and other
information required by the regulatory relief office;
 Disclosure of any criminal convictions of the applicant or other participating individuals;
 A list of the state agencies that regulate the applicant’s business;
 Other information required by the regulatory relief office.8
The application must also include a description of the applicant’s innovative offering.
The applicant must describe how the offering is subject to licensing, legal prohibition, or other
authorization requirements outside of the sandbox, and each law or regulation which the
applicant seeks to waive or suspend while participating. Alongside this, the applicant must
describe the proposed demonstration plan, including its estimated duration and how the
regulatory sandbox would enable the applicant to successfully demonstrate the offering. Lastly,
the application must describe each of the following:
 The offering’s benefits to consumers;
 How the offering differs from others available in Ohio;
 The risks that may exist for consumers who use or purchase the offering;
 How the applicant will end the demonstration and protect consumers if the offering
fails;
 Acknowledgement that the applicant is subject to all laws and regulations regarding the
offering after the demonstration concludes.9
If an applicant seeks to demonstrate more than one offering through the sandbox
program, the applicant must file a separate application for each offering.10
Fees
The Director of Commerce may impose an application fee to offset the costs of the
regulatory relief office and the costs of administering the sandbox program. The bill creates the
Universal Regulatory Sandbox Program Fund within the state treasury, into which the
8 R.C. 1357.06(A) and (B).
9 R.C. 1357.06(A)(5).
10 R.C. 1357.06(D).
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regulatory relief office will deposit the fees. Money in the fund will be used for the purposes of
the bill.11
Regulatory relief office review
The bill requires the regulatory relief office to process and review applications for
participation in the sandbox program. The office must consult with applicable government
agencies which regulate the applicant’s business and, if more information is required from the
applicant, must seek out that information. The contents of each application and any related
information provided by the applicant are considered confidential, and the application is not a
public record.12
The regulatory relief office must review an application and refer it to the appropriate
agency within five business days after receipt. In addition, it must provide the applicant with
acknowledgement of receipt as well as the name and contact information for each state agency
reviewing the application.13
Agency review
Within 30 days after receiving a complete application, the bill requires a state agency to
review the application and provide a report to the regulatory relief office which recommends
that the applicant be admitted, or denied entrance, into the sandbox program. The report must
describe any identifiable, likely, and significant harm addressed by the law or regulation the
application seeks or waive or suspend. The bill permits an agency to extend the general, 30-day
deadline by five business days by providing written notice to the regulatory relief office. Only
one extension is allowed for each application. If an agency fails to deliver a report by the
deadline, the regulatory relief office is required to proceed as though the agency does not
object to temporarily waiving or suspending the relevant laws or regulations.14
Preliminary application denial
If an agency recommends that an applicant be denied entrance into the sandbox
program, the report submitted to the regulatory relief office must include the reasons for
recommending the denial. The reasons must include the agency’s reasoning why a temporary
waiver or suspension of the relevant laws or regulations would potentially cause significant
harm to the health, safety, or financial well-being of consumers or the public, why it may create
unreasonable expenses for the state’s taxpayers, and the likelihood of the harm or expenses. If
the agency determines that consumers or the public can be protected through less restrictive
11 R.C. 1357.06(C).
12 R.C. 1357.06(E) and (G).
13 R.C. 1357.06(F).
14 R.C. 1357.07(A)(1), (2), and (5).
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means than existing laws or regulation, the bill requires the agency to recommend how that
may be achieved.15
Under the bill, the regulatory relief office must reject an application under the following
circumstances:
 An applicable state agency