This is general information, not legal advice. Review every notice, ad and rental agreement clause with your attorney before you list a unit.
Yes, online storage auctions are legal in most states, but the conditions differ. Of 51 jurisdictions (50 states and DC), 37 name an online or website sale in the statute, 7 more allow it because the sale only has to be commercially reasonable, and the rest are limited or silent.
Advertising is a separate test. Some states let a website replace the newspaper ad, some accept any commercially reasonable manner, and 15 still require a newspaper ad even when the auction itself runs online. The table below lists the sale rule, the advertising rule and the statute section for every state, checked against statute text on October 21 and 22, 2026. Verified on 2026-10-23: the Nevada and Michigan rows, re-read on the official sites. To download every state in one file, see the lien law dataset.
Online storage auction laws by state: all 50 states and DC
Each state name links to our full lien timeline page for that state. Where we could not open the current compiled code, the note says which enacted act or compilation we read.
| State | Online sale allowed? | Online advertising allowed? | Notes | Statute |
|---|---|---|---|---|
| Alabama | Yes, if commercially reasonable | No, newspaper required | Sale may be at any time or place on any terms if commercially reasonable. The ad runs once in a county newspaper at least 7 days before; any commercially reasonable manner is allowed only if the county has no newspaper or the contents are worth $500 or less. | Ala. Code § 8-15-46(a), (b)(2) |
| Alaska | Statute silent | Statute silent | No self-storage act. The general storage lien law requires a public auction in the recording district and posting in three public places for 10 days. It does not mention online sales. | AS 34.35.175(b)-(d); AS 34.35.225(a) |
| Arizona | Statute silent | No ad rule in statute | Requires a public sale for cash at the place named in the notice. Five or more unrelated bidders attending makes the sale deemed commercially reasonable. | A.R.S. § 33-1704(A), (B)(2)(d), (I) |
| Arkansas | Limited: online bidding, sale held at the facility | Yes, any commercially reasonable manner | The sale must be held at the facility where the goods are stored, but a person who bids or views the sale online counts as an independent bidder. The ad runs once in a county newspaper or in a commercially reasonable manner, at least 7 days before the sale. Read from Act 363 of 2021; confirm subsection letters in the current code. | Ark. Code Ann. § 18-16-407(a)(1), (b)(2)(A), (d) |
| California | Yes | Yes, with one newspaper ad | A sale on a publicly accessible website that customarily conducts online auctions counts. The ad can be one newspaper ad plus one online ad kept up at least 7 days before the sale, or newspaper ads only. | Cal. Bus. & Prof. Code § 21707 |
| Colorado | Yes | Yes, any commercially reasonable manner | The sale may be held on an online auction website that customarily conducts public auctions. The ad may be a weekly periodical or another commercially reasonable manner. | C.R.S. § 38-21.5-103(1) |
| Connecticut | Yes | Yes | The sale may be held online. The ad may run in an online newspaper or on a publicly accessible independent website that regularly conducts online auctions, at least once in the 10 days before the sale. | Conn. Gen. Stat. § 42-163; § 42-164(a) |
| Delaware | Yes | Yes | A public sale includes a publicly accessible website that regularly conducts online auctions. The ad may run on such an independent website instead of a newspaper, weekly for 2 consecutive weeks. | 25 Del. C. § 4904(c), (e) |
| District of Columbia | Yes | Yes | The sale may be on a publicly accessible website that conducts property sales. The ad may be on a publicly accessible website that regularly advertises or conducts property sales, at least 3 days before. | D.C. Code § 40-404(b)(3), (d) |
| Florida | Yes | No, newspaper required | A lien sale may be held on a public website that customarily conducts personal property auctions. The ad must still run once a week for 2 weeks in a newspaper of general circulation. | Fla. Stat. § 83.806(4)(a), (5) |
| Georgia | Yes | No, newspaper required | A public sale includes a publicly accessible website that regularly conducts online auctions. The ad must run twice in the county legal organ. Read from the 2019 act that rewrote the section. | O.C.G.A. § 10-4-213 |
| Hawaii | Yes | Yes, any commercially reasonable manner | The sale may be on an online website that customarily conducts self-storage lien sales. The ad may skip the newspaper if at least three independent bidders participate. | Haw. Rev. Stat. § 507-66(a), (b) |
| Idaho | Yes | No ad rule in statute | The sale may be offered on a publicly accessible website that regularly offers personal property for auction or sale. The current section (last amended 2025) sets no advertising requirement; the sale must match the tenant notice. | Idaho Code § 55-2306(2), (4), (7) |
| Illinois | Yes | No, newspaper required | A sale on a publicly accessible online website is deemed held at the facility. The ad must still run once a week for two consecutive weeks in a newspaper, or be posted in 6 places if there is none. | 770 ILCS 95/4(E), (G) |
| Indiana | Yes | Yes, any commercially reasonable manner | The sale may be held through a publicly accessible Internet web site. The default ad is one newspaper notice, but the owner may instead advertise in any other commercially reasonable manner likely to attract at least 3 independent bidders. | Ind. Code §§ 26-3-8-14(b), (c); 26-3-8-15(a) |
| Iowa | Yes | Yes, any commercially reasonable manner | A commercially reasonable sale includes a publicly accessible internet site that conducts sales or auctions. The ad runs at least 7 days before and is deemed reasonable if it likely draws three independent bidders in person or online. | Iowa Code § 578A.2 (commercially reasonable sale definition), § 578A.7 |
| Kansas | Yes | Yes, any commercially reasonable manner | The sale may be conducted online or in person. The ad may be a newspaper classified or another commercially reasonable manner, but with fewer than three independent bidders the sale is canceled and readvertised. | K.S.A. 58-817(a)(1), (a)(3) |
| Kentucky | Yes | Yes, any commercially reasonable manner | The sale may be held at the facility, the unit location or a publicly accessible website. The ad runs at least 3 days before and is deemed reasonable if at least three independent bidders participate or attend. | KRS 359.230(2)(c), (4) |
| Louisiana | Yes | Yes | The sale may be held on a publicly accessible website that conducts personal property auctions. The ad may run on a publicly accessible website that regularly advertises or conducts personal property auctions or sales instead of a newspaper (as amended by Acts 2026, No. 468). | La. R.S. 9:4759(5), (8) |
| Maine | Yes | No ad rule in statute | The sale may be held at the facility, the nearest suitable place or online. The text we read sets individual notice to the occupant but no public ad. | 10 M.R.S. § 1375 |
| Maryland | Yes | Yes | A sale on an online auction website is deemed held at the facility. The ad may be in a newspaper, by email or on an online website, at least 3 days before the sale. | Md. Code, Com. Law § 18-504 |
| Massachusetts | Statute silent | No, newspaper required | No self-storage act. The warehouse lien statute requires a newspaper ad and does not mention online sales or ads. | M.G.L. c. 106, § 7-210 |
| Michigan | Yes, if commercially reasonable | Yes | The ad may run in the print or electronic newspaper or on a publicly available website named in the rental agreement, weekly for 2 weeks. The act does not mention an online sale of the goods; the sale only has to conform to the notice and be commercially reasonable (MCL 570.525(8)). | MCL 570.525 |
| Minnesota | Yes | Only if no qualified newspaper | An online auction is a permitted sale method. The ad must be in a newspaper unless the area has no qualified one, then an independent public website is allowed. | Minn. Stat. § 514.973 |
| Mississippi | Yes | Yes, any commercially reasonable manner | The sale may be on a publicly accessible website that conducts lien sales or personal property sales (2020 amendment). The ad is deemed commercially reasonable if likely to attract at least 3 independent bidders to attend or view the sale in person or online. | Miss. Code Ann. §§ 85-7-121(j), 85-7-125(c) |
| Missouri | Yes | No, newspaper required | A public sale includes one conducted online at a publicly accessible website. The ad must still run in the classified section of a newspaper at least 7 days before. | Mo. Rev. Stat. §§ 415.405(10), 415.415 |
| Montana | Yes, if commercially reasonable | Yes, any commercially reasonable manner | A sale is commercially reasonable if attended or viewed by 3 persons in person or online. The ad may be in a county newspaper or another commercially reasonable manner, at least 7 days before. | Mont. Code Ann. § 70-6-607 |
| Nebraska | Statute silent | No, newspaper required | Sale is by public competitive bidding with no online mention. The ad runs in a county newspaper once a week for two weeks, with posting only if there is no newspaper. | Neb. Rev. Stat. § 69-2308 |
| Nevada | Yes, if commercially reasonable | Only if no newspaper | The statute never mentions an online sale of the goods. It requires only that the sale be commercially reasonable (NRS 108.477(5)). A website is named only for the ad, and only when no newspaper exists. | NRS 108.477(2), (4), (5) |
| New Hampshire | Yes | No ad rule in statute | A sale may be in person, online or through a publicly accessible internet website. The sections we read set no advertising requirement. | N.H. RSA 451-C:11; 451-C:8 |
| New Jersey | Yes | No, newspaper required | A publicly accessible online auction website is a suitable sale place. The ad must still run in a local newspaper, with posting in six places only if there is none. | N.J.S.A. 2A:44-191(e); 2A:44-191.1 |
| New Mexico | Yes | No, newspaper required | The sale may be held at the facility, the nearest suitable place or on a publicly accessible online web site. The ad runs in a county newspaper once a week for two weeks, and an online-only ad is not authorized. | NMSA § 48-11-7(E), (G) |
| New York | Yes, if commercially reasonable | Statute silent on method | The sale may be at any time or place on any commercially reasonable terms. The statute says the goods will be advertised but names no method. | N.Y. Lien Law § 182(7)(a), (8) |
| North Carolina | Yes | Yes, any commercially reasonable manner | An online sale on a publicly accessible auction website is permitted. The ad runs at least 5 days before and is deemed reasonable if at least 3 independent bidders attend. | N.C. Gen. Stat. § 44A-43 |
| North Dakota | Yes, if commercially reasonable | Yes, any commercially reasonable manner | The ad runs at least 7 days before and is deemed reasonable if at least 3 independent bidders attend in person or online. Online attendance is contemplated, but no website sale is named. | N.D. Cent. Code § 35-33-05(2) |
| Ohio | Yes | Yes, any commercially reasonable manner | The sale may be held on the internet if the address was stated in the notice. The ad may be a newspaper or another commercially reasonable manner, deemed so if 3 independent bidders register for, view or attend. | Ohio Rev. Code § 5322.03 |
| Oklahoma | Yes | No, newspaper required | The sale may be held online. The ad must still run once in a county newspaper; a website ad is not a substitute. | 42 O.S. § 197(F)-(I) |
| Oregon | Limited: list online, complete at facility | No, newspaper required | You may offer the goods on a publicly accessible auction website, but the sale must be completed at the facility or nearest suitable place. The ad runs twice in a newspaper; no ad is needed if the value is $1,000 or less. | ORS 87.691(2), (4) |
| Pennsylvania | Yes | Yes, with one newspaper ad | The sale may be held online. The ad may be newspaper twice, or newspaper once plus a publicly accessible website that regularly advertises or conducts online sales. | 12 Pa.C.S. §§ 5608, 5609 |
| Rhode Island | Yes | Yes | The sale may be held online. The ad runs once a week for two weeks on a publicly accessible website named in the rental agreement or a later notice, or once in a local newspaper instead. | R.I. Gen. Laws § 34-42-4 |
| South Carolina | Yes | No, newspaper required | The sale may be held online, run by a South Carolina licensed auctioneer. The ad runs weekly for two weeks in a local newspaper, with no website substitute. | S.C. Code § 39-20-45 |
| South Dakota | Yes | No, newspaper required | The sale may be held online. The ad runs once in a newspaper, with posting in six places only if there is none. | S.D. Codified Laws § 44-14-3(4), (5), (7) |
| Tennessee | Yes | Yes, any commercially reasonable manner | The sale must be held at the facility, online, or at the nearest suitable place. The ad must be commercially reasonable, which is met if at least 3 potential bidders take part. Read from Public Chapter 674 (2020). | Tenn. Code Ann. § 66-31-105(2)(E), (F) |
| Texas | Yes | No, newspaper required | A sale may be conducted through an Internet website accessible to the public, and the notice then gives the website address. The notice must run once in each of two consecutive weeks in a county newspaper, or be posted if there is none. Read from a code mirror because the official site would not load. | Tex. Prop. Code §§ 59.042, 59.044(b), 59.045(a) |
| Utah | Yes | Newspaper unless certified or confirmed email notice | The sale may be held at the facility, the nearest suitable place or online. The ad runs once in a county newspaper, but that is not required if the notice went by certified mail with proof, or by email with a response or return receipt. | Utah Code § 38-8-3(7), (9) |
| Vermont | Yes | Yes | The sale may be on a publicly accessible website and must be commercially reasonable. The ad may run in the electronic version of a newspaper or in any commercially reasonable manner. | 9 V.S.A. § 3905(3), (6) |
| Virginia | Yes | No ad rule in statute | A public auction may be held online. The section sets no newspaper or website advertising requirement, only notices to the occupant and lienholders. | Va. Code § 55.1-2902(A), (F) |
| Washington | Statute silent | No ad rule in statute | The sale must be commercially reasonable and public. The statute never mentions online sales and sets no advertising channel. | RCW 19.150.010(1); 19.150.060; 19.150.080(2) |
| West Virginia | Yes | Yes, if the occupant initialed | The sale may be held on an online auction website. The ad may go by email or online website instead of a newspaper only if the occupant initialed the rental agreement statement. | W. Va. Code § 38-14-5(b)(4), (e) |
| Wisconsin | Yes | No, newspaper required | A sale may be made in another commercially reasonable manner, including the Internet, at an Internet site expected to attract bidders. The ad must still be published once in a newspaper of general circulation. | Wis. Stat. § 704.90(6)(a)4., 7.c., 8. |
| Wyoming | Yes, if commercially reasonable | Only on the warehouse route | No self-storage act. The general lien statute allows a sale at a commercially reasonable time, place and terms after certified mail notice, with no ad. If you use the optional warehouse procedure instead, it requires a newspaper ad once a week for 2 weeks. | Wyo. Stat. §§ 29-7-101(b), 29-7-105(b), (h); 34.1-7-210(b)(v) |
How to read the table:
- Online sale allowed? "Yes" means the statute names an online, website or internet sale. "Yes, if commercially reasonable" means the text is silent on online sales, sets no place or method and only requires a commercially reasonable sale. We read that standard as allowing an online sale, but the statute does not say so, so confirm it with your attorney. "Statute silent" means the text says nothing either way.
- Online advertising allowed? "Yes" means a website, email or online newspaper ad is named as an option. "Yes, any commercially reasonable manner" means the statute does not tie the ad to a newspaper. "No, newspaper required" means a website ad does not replace it.
- Check date: every row was checked on 2026-10-21, and Arkansas, Idaho, Tennessee, Wisconsin and Wyoming again on 2026-10-22. The Indiana row was re-read from the official 2025 Indiana Code on 2026-10-23, and the Mississippi row from the official enrolled text of HB 1138 (2020) on 2026-10-25. The Alaska, Louisiana, Massachusetts, Nebraska and New Mexico rows were read from the official statute text on 2026-10-25. Where an official site would not load, we read the enacted act or a code mirror instead, and the note says so for the rows where it matters most. Re-check the current section before you rely on it.
What counts as an online storage auction
An online storage auction is a lien sale where bidding happens on a website instead of, or alongside, a crowd at the facility. The goods are still sold under the same lien process: default, notice to the tenant, a waiting period, an ad where the state requires one, then a public sale.
The legal questions are different at each step. Is a website sale a valid public sale? Is a website listing a valid ad? Does the sale count as held at the facility? Most statutes answer the first question and many leave the second to a separate section. See the advertising requirements guide for the ad side in more detail.
States that spell out online sales
37 jurisdictions name an online, website or internet sale in the statute. Examples from the table:
- California, Colorado, Delaware, Georgia, Hawaii: the site must customarily or regularly conduct online auctions or sales.
- Illinois and Maryland: a sale on an online auction website is deemed held at the facility.
- Ohio and Texas: the notice must give the internet or website address of the sale.
- South Carolina: the sale may be online, but it is run by a South Carolina licensed auctioneer.
- Minnesota: online auction or an in-person public sale are the two permitted methods, and online bidders must register and agree to the sale rules.
Another 7 states (Alabama, Michigan, Montana, Nevada, New York, North Dakota and Wyoming) do not name a website sale but only require a commercially reasonable sale. That supports an online sale, though the reading is less direct, so ask your attorney.
States that only allow online advertising, or limit it
Allowing an online sale does not mean you can drop the newspaper. Florida, Georgia, Illinois, Missouri, New Jersey, Oklahoma, South Carolina, South Dakota, Texas and Wisconsin all allow online sales and still require a newspaper ad. The full group of 15 newspaper-required states is in the table.
Nine states name a website, email or online newspaper ad: Connecticut, the District of Columbia, Delaware, Louisiana, Maryland, Michigan, Rhode Island, Vermont and West Virginia. West Virginia adds a condition: the occupant must have initialed the rental agreement statement. California and Pennsylvania allow a website ad for one of two required ads, and Minnesota and Nevada allow a website only when no qualifying newspaper exists.
Thirteen states accept any commercially reasonable manner, and most tie that to bidder turnout, such as at least three independent bidders. Kansas is stricter: with fewer than three independent bidders attending or viewing online, the sale is canceled, rescheduled and readvertised. For how long each state makes you wait before the sale, see how long before a storage unit is auctioned.
Checklist before you list a unit online
- Open your state row and write down the sale rule, the ad rule and the section number. If it says Statute silent or No ad rule in statute, ask your attorney what is enough.
- Confirm the lien notice period has ended. Count from the day the notice was delivered, not the rent due date. The lien timeline calculator shows the earliest date.
- Check military status and bankruptcy. Under 50 U.S.C. 3958 you may not enforce a storage lien against a servicemember during service and for 90 days after without a court order.
- Choose a site the statute accepts. Where the text says publicly accessible or regularly conducts online auctions, pick a platform that fits that wording and keep a note of why.
- Put the web address in the notice if your state asks for it, and make sure the date, time and terms of the sale match what you will list.
- Run the newspaper ad if your row says newspaper required, even though bidding is online.
- Check any extra conditions, such as the tenant initialing a rental agreement clause (West Virginia) or a licensed auctioneer (South Carolina).
- Keep proof. Save a dated screenshot of each listing, the publisher receipt for each ad and the list of registered bidders.
- Plan the surplus. Know what you owe back to the tenant before the sale closes; see the lien law page for your state.
Common mistakes
- Assuming an online auction replaces the newspaper ad. In 15 states it does not.
- Using a site that does not fit the statute wording, such as a general classified site where the law says a site that regularly conducts online auctions.
- Skipping the web address in the notice in states that require it.
- Counting from the wrong date. Several states count the ad from notice delivery.
- Relying on a row that says Statute silent as if it were permission.
- Forgetting that Oregon wants the sale completed at the facility even if the listing is online.
- Not checking military status before the listing goes live.
- Using a summary from another site without checking the section number. Statutes change, and a 2019 or 2023 summary may be out of date.
How Stitch helps
Stitch Storage is self storage management software for independent owners, made by Hive Asset Group, LLC. Stitch tracks lien timelines by state, so you see the next step and the earliest date for each delinquent unit before you list anything. See lien and auction management for how it works, and Stitch pricing for the plans. Stitch does not run the auction site itself.
If you are comparing tools, start with the best self storage software list or read about Storable alternatives. For an overview of what a management system covers, see self storage software.
Method and limits of this table
We started from our own state lien research and then re-read the sale and advertising sections on 2026-10-21 and 2026-10-22, using official legislature and code sites where they loaded. Where they did not, we used the enacted act or a code mirror, and the note says so. Where our earlier research and the statute text disagreed, we followed the text.
For Arkansas and Tennessee we could not open the current compiled code, so those rows come from the enacted acts (Arkansas Act 363 of 2021, Tennessee Public Chapter 674 of 2020). Confirm them against the current code before you rely on them. Our self storage lien laws by state pages carry the full notice, timing and sale rules.
This guide is general information, not legal advice. Statutes change, and your facts matter. Review every notice and listing with your attorney before you act.
