Exhibit 5.1

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June 10, 2026

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Ladies and Gentlemen:

We have acted as counsel for Ulta Beauty, Inc., a Delaware corporation (the “Company”), in conjunction with the preparation of a Post-Effective Amendment No. 2 (the “Post-Effective Amendment”) to Registration Statement No. 333-176735 (the “Registration Statement”) to be filed by the Company with the Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”), relating to up to 2,153,027 shares of the Company’s common stock, par value $0.01 per share (the “Shares”), that may be issued pursuant to the Ulta Beauty, Inc. 2026 Incentive Award Plan (the “2026 Plan”), consisting of 1,501,201 Shares that remained available for future awards under the Company’s Amended and Restated Ulta Beauty, Inc. 2011 Incentive Award Plan (the “2011 Plan”) as of April 13, 2026 and therefore became available for future awards under the 2026 Plan (the “Carryforward Shares”), plus 651,826 Shares that were subject to outstanding awards under the 2011 Plan as of April 13, 2026 (the “Recycled Shares”) and that may therefore become available for future awards under the 2026 Plan pursuant to the replenishment provisions of the 2026 Plan.

In connection with our representation, we have examined:  (i) the 2026 Plan and the 2011 Plan and related documents; (ii) the Registration Statement and the Post-Effective Amendment, in each case, including the exhibits (including those incorporated by reference) constituting a part of the Registration Statement and Post-Effective Amendment; (iii) the Certificate of Incorporation of the Company, as amended to date, and the Bylaws of the Company, as amended to date; (iv) the resolutions of the Company’s Board of Directors relating to the 2026 Plan and the issuance of Common Stock thereunder; and (v) originals or copies, certified or otherwise identified to our satisfaction, of such records, agreements and instruments of the Company, certificates and receipts of public officials and of officers or other representatives of the Company, and such other documents and records, and such matters of law, as we have deemed necessary or appropriate as a basis for the opinions stated below.

In our examination, we have assumed the genuineness of all manual and electronic signatures, including endorsements, the legal capacity and competency of all natural persons, the authenticity of all documents submitted to us as originals and the conformity to the original documents of all documents submitted

AUSTIN  |  BOSTON  |  BRUSSELS  |  CHICAGO  |  DALLAS  |  DENVER  |  DETROIT  |  HOUSTON  |  JACKSONVILLE  | LOS ANGELES
MADISON  |  MEXICO CITY  |  MIAMI  |  MILWAUKEE  | NASHVILLE  |  NEW YORK  |  ORLANDO  |  RALEIGH  |  SACRAMENTO  |  
SALT LAKE CITY   |  SAN DIEGO  |  SAN FRANCISCO  |  SILICON VALLEY  |  TALLAHASSEE  |  TAMPA  |  TOKYO  |  WASHINGTON, D.C.

June 10, 2026

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to us as facsimile, electronic, certified or photostatic copies, and the authenticity of the originals of such copies. As to various questions of fact material to this opinion, we have relied upon, without independent verification of their accuracy, certificates of public officials, statements and representations of officers and other representatives of the Company, and statements of fact contained in documents we have examined.

For the purpose of the opinion rendered below, we have assumed that in connection with the issuance of the Shares under the 2026 Plan, the Company will receive consideration in an amount not less than the aggregate par value of the Shares covered by each such issuance.

It is understood that this opinion is to be used only in connection with the offer and sale of the Carryforward Shares and the Recycled Shares while the Registration Statement and Post-Effective Amendment is effective.

We express no opinion herein as to the laws of any state or jurisdiction other than the General Corporation Law of the State of Delaware and the federal laws of the United States of America.  This opinion is being furnished in connection with the requirements of Item 601(b)(5) of Regulation S-K under the Securities Act, and no opinion is expressed herein as to any matter pertaining to the contents of the Registration Statement and Post-Effective Amendment or the prospectus that forms a part thereof, other than as expressly stated herein with respect to the issuance of the Shares.

Based upon the foregoing, we are of the opinion that each of the Shares, if and when issued by the Company pursuant to the terms and conditions of the 2026 Plan and as contemplated by the Registration Statement and Post-Effective Amendment, will be validly issued, fully paid and nonassessable.

We consent to the use of this opinion as an exhibit to the Post-Effective Amendment.  In giving our consent, we do not admit that we are “experts” within the meaning of Section 11 of the Securities Act or within the category of persons whose consent is required by Section 7 of the Securities Act.

Very truly yours,

/s/ Foley & Lardner LLP

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Foley & Lardner LLP