2022 Annotated App Store Guidelines
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2022 Annotated App Store Guidelines
www.actonline.org As lawmakers continue to consider measures that would restrict the ability of app platforms to manage their ecosystems, ACT | The App Association remains concerned that such limitations would massively reduce marketplace trust. For many small app developers within our membership, this threat is existential - without possessing a well-known brand presence themselves, they rely on a trusted ecosystem to seamlessly enter the market, reach millions of potential users, and grow their business. Though proponents of the so-called platform competition bills, including S. 2992, the American Innovation and Choice Online Act and S. 2710, the Open App Markets Act, repeatedly extol the pro-competitive virtues of reducing gatekeeper control over the platforms, they often overlook what platforms currently do to keep users safe and to create an ecosystem that users are actually comfortable transacting within. Without those protections and trust, the app marketplace is unlikely to remain a viable forum for smaller players to flourish. With this document, we conduct a section-by-section investigation into one app platform’s guidelines (the App Store Review Guidelines) to assess how exactly S. 2992 and S. 2710 are likely to erode currently existing consumer protections if they are passed into law. What this analysis --which is not exhaustive and is only the beginning of the inquiry into how the bills would impact app store management--reveals should concern anyone who proclaims to care about a safe app store experience for users. Our annotations (in blue) suggest that the legislation in question likely renders vast portions of the current guidelines—even uncontroversial protections against manip- ulative marketing practices, deceptive monetization of device features, misuse of children’s data, and dozens of others—illegal outright or unenforceable without the platform initiating a costly legal defense in each instance. Even for the staunchest supporters of the bills, this analysis should provide good reason to question whether the legislation, as currently drafted, appropriately scopes prohibitions on plainly pro-consumer platform behavior. We hope these annotations add produc- tive nuance to a discussion that too often exists in the lofty but vague realm of anti-Big Tech senti- ment and consistently seems to ignore the common-sense mechanisms by which platforms ensure that bad actors stay out of the app store, maintaining a safe environment for developers who play by the rules. 2 ACT | The App Association | Annotated App Store Guidelines
www.actonline.org
Key Findings
On the following pages, we find that the platform antitrust bills would likely disrupt key
consumer protections and quality control measures in each of the major sections of the
App Store Review Guidelines, including Safety, Performance, Business, Design, and Legal.
Some of our critical findings include that:
• The bills could prevent app stores from removing medical apps that provide inaccurate
information. The bills would prevent limits on device hardware and software features,
even if apps use them to make erroneous medical claims or diagnoses.
• The bills could prevent app stores from removing apps that request excessive battery
resources or risk damage to the device. The bills could prevent app stores from limit-
ing access by apps to device features, even when that access compromises user safety
by imposing excessive battery demands.
• The bills could prevent app stores from removing apps that rip-off users with decep-
tive subscription terms and conditions. Under S. 2710, such techniques may be consid-
ered “legitimate business communications” and thus protected under the bill.
• The bills could prevent app stores from removing apps that spam or copy-cat other
apps. The bills bar app stores from enforcing any terms that may discriminate among
similarly situated apps, even if those apps seek to game the system.
• The bills could prevent app stores from removing apps that misrepresent their data
sharing practices. The bills force app stores to rely on hard-to-prove legal defenses to
justify pro-privacy platform decisions.
ACT | The App Association | Current App Store Principles 3www.actonline.org www.actonline.org
INTRODUCTION
The guiding principle of the App Store is simple—we want
to provide a safe experience for users to get apps and a
great opportunity for all developers to be successful. We WHAT WOULD CHANGE
do this by offering a highly curated App Store where every
app is reviewed by experts and an editorial team helps S. 2710, Sec. 3(d) would interfere with the en-
users discover new apps every day. For everything else forcement of more or less the entire guidelines
there is always the open Internet. If the App Store model on third-party apps because the provision would
and guidelines are not best for your app require Apple to provide “readily accessible means”
or business idea that’s okay, we provide Safari for a great for consumers to install third-party apps or app
web experience too. stores through means other than the App Store, thus
creating a separate class of apps not subject to the
guidelines.
On the following pages you will find our latest guidelines S. 2992, Sec. 3(a)(4) also would interfere with the
arranged into five clear sections: Safety, Performance, enforcement of substantially the entire set of guide-
Business, Design, and Legal. lines on third-party apps because the provision would
prohibit any material restriction on the capacity of a
The App Store is always changing and improving to keep business user to access or interoperate with the plat-
up with the needs of our customers and our products. Your form, which may include imposing consequences like
apps should change and improve as well in order to stay on removal of an app for any violation of the guidelines,
the App Store. effectively mandating the acceptance of third-party
software distributed outside the App Store and there-
A few other points to keep in mind. fore not subject to the guidelines.
We have lots of kids downloading lots of apps. Parental Similarly, Sec. 3(a)(1), (2), (3), (5), and (7) would inter-
controls work great to protect kids, but you have to do your fere with the enforcement of the entire set of guide-
part too. So know that we’re keeping an eye out for the lines on third-party apps, because they reinforce the
kids. requirement for Apple to accept apps distributed
through third-party means onto the platform by limit-
The App Store is a great way to reach hundreds of millions ing restrictions that could be imposed on those apps.
of people around the world. If you build an app that you
just want to show to family and friends, the App Store isn’t
the best way to do that. Consider using Xcode to install
your app on a device for free or use Ad Hoc distribution
available to Apple Developer Program members. If you’re
just getting started, learn more about the Apple Developer
Program.
We strongly support all points of view being represented
on the App Store, as long as the apps are respectful to
users with differing opinions and the quality of the app
experience is great. We will reject apps for any content or
behavior that we believe is over the line. What line, you
ask? Well, as a Supreme Court Justice once said, “I’ll know it
when I see it”. And we think that you will also know it when
you cross it.
If you attempt to cheat the system (for example, by trying
to trick the review process, steal user data, copy another
developer’s work, manipulate ratings or App Store
discovery) your apps will be removed from the store and
you will be expelled from the Apple Developer Program.
4| The App Association | Annotated App Store Guidelines
ACT 4
ACT | The App Association | Current App Store Principleswww.actonline.org www.actonline.org
SAFETY
Apps with user-generated content or services that end
up being used primarily for pornographic content,
Chatroulette-style experiences, objectification of real
people (e.g. “hot-or-not” voting), making physical threats, WHAT WOULD CHANGE
or bullying do not belong on the App Store and may
be removed without notice. If your app includes user-
S. 2992, Sec. 3(a)(4) would interfere with the
generated content from a webbased service, it may display
enforcement of this entire section because the
incidental mature “NSFW” content, provided that the
provision bars material restrictions on a business
content is hidden by default and only displayed when the
user’s capacity to access the operating system and
user turns it on via your website.
hardware and software features that are available to
the platform’s own offerings, and removing an app
for violation of this guideline could be a
1. Safety material restriction on access to the operating sys-
tem and hardware and software
When people install an app from the App Store, they want features.
to feel confident that it’s safe to do so —that the app
doesn’t contain upsetting or offensive content, won’t
damage their device, andisn’t likely to cause physical harm
from its use. We’ve outlined the major pitfalls below, but if
you’re looking to shock and offend people, the App Store
isn’t the right place for your app
WHAT WOULD CHANGE
1.1 Objectionable Content
S. 2710, Sec. 3(d) and 3(h) would interfere with the
Apps should not include content that is offensive, enforcement of this entire section because these pro-
insensitive, upsetting, intended to disgust, in exceptionally visions would require Apple to allow third-party apps
poor taste, or just plain creepy. Examples of such content not subject to the guidelines onto a device and would
include: also bar Apple from restricting access by any app to
the operating system and device features, and a trial
1.1.2 attorney could easily claim that removal or rejection
Realistic portrayals of people or animals being killed, on the basis of any of these safety measures materially
maimed, tortured, or abused, or content that encourages restricts an app’s access to the platform.
violence. “Enemies” within the context of a game cannot
solely
target a specific race, culture, real government, corpora-
tion, or any other real entity.
1.1.3
Depictions that encourage illegal or reckless use of weap-
ons and dangerous objects, or facilitate the purchase of
firearms or ammunition.
1.1.4
Overtly sexual or pornographic material, defined by
Webster’s Dictionary as “explicit descriptions or displays
of sexual organs or activities intended to stimulate erotic
rather than aesthetic or emotional feelings.” This includes
“hookup” apps that may include pornography or be used
to facilitate prostitution.
5| The App Association | Current App Store Principles
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ACT | The App Association | Annotated App Store Guidelineswww.actonline.org
1.2 User-Generated Content
WHAT WOULD CHANGE
Apps with user-generated content present particular challenges,
ranging from intellectual property infringement to anonymous S. 2992, Sec. 3(a)(4) would interfere with the
bullying. To prevent abuse, apps with user-generated content or enforcement of this guideline because the provi-
social networking services must include: sion bars material restrictions on a business user’s
capacity to access the operating system and hard-
A method for filtering objectionable material from being ware and software features that are available to the
posted to the app A mechanism to report offensive content platform’s own offerings, and removing an app for
and timely responses to concerns The ability to block abusive violation of this guideline could be a material
users from the service Published contact information so users restriction on access to the operating system and
can easily reach you Apps with user-generated content or hardware and software features.
services that end up being used primarily for pornographic
content, Chatroulette-style experiences, objectification of real
people (e.g. “hot-or-not” voting), making physical threats, or
bullying do not belong on the App Store and may be removed
without notice. If your app includes user-generated content
from a webbased service, it may display incidental mature
“NSFW” content, provided that the content is hidden by
default and only displayed when the user turns it on via your
website.
1.2.1 Creator Content
Apps which feature content from a specific community of
users called “creators” are a great opportunity if properly
WHAT WOULD CHANGE
moderated. These apps present a singular, unified experience
for customers to interact with various kinds of creator S. 2992, Sec. 3(a)(4) and (7) would also interfere with
content. They offer tools and programs to help this this provision because they could require the
community of non-developer creators to author, share, and platform to allow creators to have access to the
monetize user-generated experiences. These experiences software, OS, and hardware features that a native app
must not change the core features and functionality of the would have, and because the guideline may
native app—rather, they add content to those structured operate to restrict creators’ ability to collect data
experiences. about a covered platform user directly through the
OS.
These experiences are not native “apps” coded by
developers—they are content within the app itself and are S. 2710, Sec. 3(a) and (f) would interfere with the
treated as user-generated content by App Review. Such enforcement of this section because the provisions
creator content may include video, articles, audio, and even would require the platform to allow creators to
casual games. The App Store supports apps offering such potentially create things that function like native
user-generated content so long as they follow all Guidelines, apps, while prohibiting the platform from requiring
including Guideline 1.2 for moderating user-generated them to follow IAP rules.
content and Guideline 3.1.1 for payments and in-app
purchases. Creator apps should share the age rating of the
highest age-rated creator content available in the app, and
communicate to users which content requires additional
purchases.
6 ACT | The App Association | Annotated App Store Guidelineswww.actonline.org
1.3 Kids Category
The Kids Category is a great way for people to easily find WHAT WOULD CHANGE
apps that are designed for children.
S. 2992, Sec. 3(a)(7) would interfere with the enforce-
If you want to participate in the Kids Category, you should ment of this guideline because the provision bars
focus on creating a great experience specifically for material restrictions on a business user’s access to
younger users. These apps must not include links out of data generated on the platform by an individual on
the app, purchasing opportunities, or other distractions the business user’s service, even if the business us-
to kids unless reserved for a designated area behind a er’s data collection or processing conduct is illegal.
parental gate.
Keep in mind that once customers expect your app to fol- Apple could overcome the prohibition with an affir-
low the Kids Category requirements, it will need to contin- mative defense, which would apply only to the facts
ue to meet these guidelines in subsequent updates, even in the case at bar, and only if the platform meets nar-
if you decide to deselect the category. Learn more about row evidentiary requirements, if a lawsuit were filed
parental gates. to protect the app that was subject to removal.
You must comply with applicable privacy laws around
the world relating to the collection of data from children WHAT WOULD CHANGE
online. Be sure to review the Privacy section of these
guidelines for more information. In addition, Kids Category S. 2992, Sec. 3(a)(4) and (7) would also interfere
apps may not send personally identifiable information or with this provision because they could require the
device information to third parties. Apps in the Kids Cate- platform to allow creators to have access to the soft-
gory should not include thirdparty analytics or third-party ware, OS, and hardware features that a native app
advertising. This provides a safer experience for kids. In would have, and because the provision may operate
limited cases, third-party analytics may be permitted pro- to restrict creators’ ability to collect data about a
vided that the services do not collect or transmit the IDFA covered platform user directly through the OS.
or any identifiable information about children (such as
name, date of birth, email address), their location, or their
devices. This includes any device, network, or other
information that could be used directly or combined with
other information to identify users and their devices.
Third-party contextual advertising may also be permitted
WHAT WOULD CHANGE
in limited cases provided that the services have publicly
documented practices and policies for Kids Category S. 2710, Sec. 3(f) would interfere with the enforce-
apps that include human review of ad creatives for age ment of this guideline, because the provision would
appropriateness. require Apple to give developers making fake
medical apps full access to the system’s sensors even
if they use them to make false medical claims. Sec.
1.4 Physical Harm 3(b) would also interfere with the enforcement of the
guideline, because the
If your app behaves in a way that risks physical harm, we provision would prohibit Apple from interfering with
may reject it. For example: an app originally designed for a separate purpose,
but communicated within the app after it had been
1.4.1 approved to users that they could receive real medi-
Medical apps that could provide inaccurate data or cal help without the validation requirements in this
information, or that could be used for diagnosing or guideline.
treating patients may be reviewed with greater scrutiny.
S. 2992, Sec. 3(a)(4) would interfere with Apple’s
Apps must clearly disclose data and methodology to enforcement of this guideline because rejecting a
support accuracy claims relating to health measurements, medical app due to inability to validate the accura-
and if the level of accuracy or methodology cannot be cy or methodology of health measurements could
validated, we will reject your app. For example, apps that easily be interpreted as a material restriction or im-
claim to take x-rays, measure blood pressure, body tem- pediment to the app’s ability to access hardware or
perature, software features (the sensors in particular) versus
Apple’s own offerings.
ACT | The App Association | Annotated App Store Guidelines 7www.actonline.org
blood glucose levels, or blood oxygen levels using only the
sensors on the device are not permitted.
Apps should remind users to check with a doctor in
addition to using the app and before making medical
decisions. If your medical app has received regulatory
clearance, please submit a link to that documentation with
your app.
1.4.2
Drug dosage calculators must come from the drug
manufacturer, a hospital, university, health insurance
WHAT WOULD CHANGE
company, pharmacy or other approved entity, or receive
approval by the FDA or one of its international S. 2710, Sec. 4(b) would interfere with the enforce-
counterparts. Given the potential harm to patients, we ment of this guideline because the provision would
need to be sure that the app will be supported and prohibit Apple from imposing restrictions on com-
updated over the long term. munications of a developer “concerning legitimate
business offers,” and a trial attorney could claim that
1.4.3 restricting an app from calculating dosages or other
drug facts would be a restriction on a communica-
Apps that encourage consumption of tobacco and vape tion concerning a legitimate business offer.
products, illegal drugs, or excessive amounts of alcohol
are not permitted on the App Store. Apps that encourage
minors to consume any of these substances will be
rejected. Facilitating the sale of controlled substances
(except for licensed pharmacies and licensed or otherwise
legal cannabis dispensaries), or tobacco is not allowed.
1.4.4
Apps may only display DUI checkpoints that are published
by law enforcement agencies, and should never encourage
drunk driving or other reckless behavior such as excessive WHAT WOULD CHANGE
speed.
S. 2710, Sec. 3(b) would interfere with the enforce-
1.4.5 ment of this guideline because the provision would
Apps should not urge customers to participate in activities prohibit Apple from imposing restrictions on com-
(like bets, challenges, etc.) or use their devices in a way that munications of a developer “concerning legitimate
risks physical harm to themselves or others. business offers,” and a trial attorney could claim that
restricting an app from urging customers to partici-
pate in bets, challenges, etc., or use devices in a way
1.5 Developer Information that risks physical harm to themselves or others is a
restriction on a communication concerning a legiti-
People need to know how to reach you with questions mate business offer.
and support issues. Make sure your app and its Support
URL include an easy way to contact you; this is particularly
important for apps that may be used in the classroom. Fail-
ure to include accurate and up-to-date contact information
not only frustrates customers, but may violate the law in
some countries. Also ensure that Wallet passes include val-
id contact information from the issuer and are signed with
a dedicated certificate assigned to the brand or trademark
owner of the pass.
8 ACT | The App Association | Annotated App Store Guidelineswww.actonline.org
1.6 Data Security
Apps should implement appropriate security measures
to ensure proper handling of user information collected
pursuant to the Apple Developer Program License
WHAT WOULD CHANGE
Agreement and these Guidelines (see Guideline 5.1 for
more information) and prevent its unauthorized use, S. 2992, Sec. 3(a)(4) and Sec. 3(a)(7) would interfere
disclosure, or access by third parties. with the enforcement of this guideline because the
provisions would prohibit restrictions on access by
certain apps to device and software features—as
1.7 Reporting Criminal Activity well as personal information—and requiring an app
developer to ensure proper handling of user infor-
Apps for reporting alleged criminal activity must involve mation and prevent its unauthorized use, disclosure,
local law enforcement, and can only be offered in countries or access by third parties, would constitute such
where such involvement is active. restrictions.
PERFORMANCE
2.1 App Completeness
Submissions to App Review, including apps you make
available for pre-order, should be final versions with all
necessary metadata and fully functional URLs included;
placeholder text, empty websites, and other temporary
content should be scrubbed before submission. Make sure
your app has been tested on-device for bugs and stability
before you submit it, and include demo account info (and
turn on your back-end service!) if your app includes a log-
in. If you offer in-app purchases in your app, make sure
they are complete, up-to-date, and visible to the reviewer, WHAT WOULD CHANGE
or that you explain why not in your review notes. Please
don’t treat App Review as a software testing service. We S. 2710, Sec. 3(b) would interfere with the enforce-
will reject incomplete app bundles and binaries that crash ment of this guideline because the provision would
or exhibit obvious technical problems. prohibit Apple’s interference with developer commu-
nications concerning “a legitimate business offer,”
2.2 BETA Testing and a requirement to explain in-app purchases could
constitute such a restriction on business offers.
Demos, betas, and trial versions of your app don’t be-
long on the App Store –use TestFlight instead. Any app
submitted for beta distribution via TestFlight should be
intended for public distribution and should comply with
the App Review Guidelines. Note, however, that apps using
TestFlight cannot be distributed to testers in exchange
for compensation of any kind, including as a reward for
crowd-sourced funding. Significant updates to your beta
build should be submitted to TestFlight App Review before
being distributed to your testers. To learn more, visit the
TestFlight Beta Testing page.
ACT | The App Association | Annotated App Store Guidelines 9www.actonline.org
2.3 Accurate Metadata
Customers should know what they’re getting when they
download or buy your app, so make sure all your app
metadata, including privacy information, your app WHAT WOULD CHANGE
description, screenshots, and previews accurately reflect
the app’s core experience and remember to keep them S.2992, Sec. 3(a)(2) would make it difficult for Ap-
upto-date with new versions. ple to enforce this guideline because the platform
making a determination that an app is not accurately
2.3.1 representing its privacy practices and removing it
Don’t include any hidden, dormant, or undocumented based on that determination could be interpreted as
features in your app; your app’s functionality should be a limitation on the ability of a rival app to compete.
clear to end users and App Review. All new features,
functionality, and product changes must be described with
specificity in the Notes for Review section of App Store
Connect (generic descriptions will be rejected) and
accessible for review. Similarly, marketing your app in a
misleading way, such as by promoting content or services
that it does not actually offer (e.g. iOS-based virus and WHAT WOULD CHANGE
malware scanners) or promoting a false price, whether
within or outside of the App Store, is grounds for removal
of your app from the App Store and termination of your S. 2710, Sec. 3(a)(3) could interfere with Apple’s
developer account. Egregious or repeated behavior is enforcement of this guideline because the provision
grounds for removal from the Apple Developer Program. would bar Apple from taking punitive action against
We work hard to make the App Store a trustworthy ecosys- a developer for offering “different pricing terms” on
tem and expect our app developers to follow suit; if you’re another app store.
dishonest, we don’t want to do business with you.
Sec. 3(b) could also interfere with the guideline’s
2.3.2 enforcement because that provision bars Apple from
If your app includes in-app purchases, make sure your app imposing restrictions on developers’ communica-
description, screenshots, and previews clearly indicate tions with the users of their app through the app or
whether any featured items, levels, subscriptions, etc. directly.
require additional purchases. If you decide to promote
in-app purchases on the App Store, ensure that the in-app
purchase Display Name, Screenshot and Description are
appropriate for a public audience, that you follow the
guidance found in Promoting Your In-App Purchases, and
WHAT WOULD CHANGE
that your app properly handles the S. 2710, Sec. 3(a)(3) could interfere with Apple’s
SKPaymentTransactionObserver method so that enforcement of this guideline because the provision
customers can seamlessly complete the purchase when would bar Apple from taking punitive action when a
your app launches. developer offers “different pricing terms” or “condi-
tions of sale” through a third-party in-app payment
2.3.3 system.
Screenshots should show the app in use, and not merely
the title art, login page, or splash screen. They may also
include text and image overlays (e.g. to demonstrate input
mechanisms, such as an animated touch point or Apple
Pencil) and show extended functionality on device, such as
Touch Bar.S
10 ACT | The App Association | Annotated App Store Guidelineswww.actonline.org
2.3.4
Previews are a great way for customers to see what your
app looks like and what it does. To ensure people WHAT WOULD CHANGE
understand what they’ll be getting with your app,
previews may only use video screen captures of the app
itself. Stickers and iMessage extensions may show the user S. 2710, Sec. 3(b) would interfere with Apple’s
experience in the Messages app. You can add narration enforcement of this guideline because it would bar
and video or textual overlays to help explain anything that Apple from imposing restrictions on developers’
isn’t clear from the video alone. communications with users of their apps concerning
“legitimate business offers” (the guideline would limit
2.3.5 how any business offers may appear in previews).
Select the most appropriate category for your app, and
check out the App Store Category Definitions if you need
help. If you’re way off base, we may
change the category. WHAT WOULD CHANGE
2.3.6
Answer the age rating questions in App Store Connect S. 2992, Sec. 3(a)(2) would interfere with Apple’s
honestly so that your app aligns properly with parental enforcement of this guideline because Apple’s uni-
controls. If your app is mis-rated, customers might be lateral decision, even if the developer was “way off
surprised by what they get, or it could trigger an inquiry base,“ to re-categorize an app could be interpreted
from government regulators. If your app includes media as a limitation on the ability for that app to compete
that requires the display of content ratings or warnings on the platform (e.g., if Apple re-categorizes it as a
(e.g. films, music, games, etc.), you are responsible for Kids app).
complying with local requirements in each territory where
your app is available.
2.3.7
Choose a unique app name, assign keywords that
accurately describe your app, and don’t try to pack any WHAT WOULD CHANGE
of your metadata with trademarked terms, popular app
names, pricing information, or other irrelevant phrases
just to game the system. App names must be limited to 30 S. 2710, Sec. 3(b) could interfere with this guideline
characters. Metadata such as app names, subtitles, screen- because the provision bars restrictions on a develop-
shots, and previews should not include prices, terms, or er’s communications concerning “legitimate business
descriptions that are not specific to the metadata type. App offers.”
subtitles are a great way to provide additional context for
your app; they must follow our standard
metadata rules and should not include inappropriate cont
ent, reference other apps, or make unverifiable product
claims. Apple may modify inappropriate keywords at any
time or take other appropriate steps to prevent abuse.
11
ACT | The App Association | Annotated App Store Guidelineswww.actonline.org
2.3.8
Metadata should be appropriate for all audiences, so make
sure your app and in-app purchase icons, screenshots, and
previews adhere to a 4+ age rating even if your app israted
higher. For example, if your app is a game that includes
violence, select images that don’t depict a gruesome death
or a gun pointed at a specific character. Use of terms like“-
For Kids” and “For Children” in app metadata is reserved
for the Kids Category.
Remember to ensure your metadata, including app name
and icons (small, large, Apple Watch app, alternate icons,
etc.), are similar to avoid creating confusion.
2.3.9
You are responsible for securing the rights to use all
materials in your app icons, screenshots, and previews,
and you should display fictional account information
instead of data from a real person.
2.3.10
Make sure your app is focused on the iOS, iPadOS, WHAT WOULD CHANGE
macOS, tvOS or watchOS experience, and don’t include
names, icons, or imagery of other mobile platforms in S. 2710, Sec. (3)(b) would interfere with the platform’s
your app or metadata, unless there is specific, approved enforcement of this guideline because the provision
interactive functionality. Make sure your app metadata is would bar restrictions on a developer’s communi-
focused on the app itself and its experience. Don’t include cations with users regarding a legitimate business
irrelevant information. offer.
2.3.11
Apps you submit for pre-order on the App Store must be
complete and deliverable as submitted. Ensure that the
app you ultimately release is not materially different from
what you advertise while the app is in a pre-order state. If
you make material changes to the app (e.g. change busi-
ness models), you should restart your pre-order sales.
WHAT WOULD CHANGE
2.3.12 S. 2992, Sec. 3(a)(3) would interfere with the plat-
Apps must clearly describe new features and product form’s enforcement of this guideline because certain
changes in their “What’s New” text. Simple bug fixes, in-app events may fall within an event type provided
security updates, and performance improvements may in App Store Connect and others may not, which a
rely on a generic description, but more significant developer could argue materially harms competition
changes must be listed in the notes. among similarly situated business users.
2.3.13
In-app events are timely events that happen within your
app. To feature your event on the App Store, it must fall
within an event type provided in App Store Connect. All
event metadata must be accurate and pertain to the event
itself, rather than the app moregenerally. Events must
happen at the times and dates you select in App Store WHAT WOULD CHANGE
Connect, including across multiple storefronts.
You may monetize your event so long as you follow the S. 2710, Sec. 3(a)(1) would interfere with enforce-
rules set forth in Section 3 on Business. ment of this guideline because the provision would
bar bundling the platform’s own in-app payment
And your event deep link must direct users to the proper system with distribution on the platform.
destination within your app. Read In-App Events for
detailed guidance on acceptable event metadata and
event deep links.
12 ACT | The App Association | Annotated App Store Guidelineswww.actonline.org
2.4 Hardware Compatibility
2.4.1
To ensure people get the most out of your app, iPhone
apps should run on iPad whenever possible. We encourage
you to consider buildinguniversal apps so customers can
use them on all of their devices. Learn more about
Universal apps.
2.4.2
Design your app to use power efficiently and be used WHAT WOULD CHANGE
in a way that does not risk damage to the device.
Apps should not rapidly drain battery, generate excessive S. 2710, Sec. 3(f) would interfere with the enforce-
heat, or put unnecessary strain on device resources. For ment of this guideline because the provision requires
example, apps should not encourage placing the device Apple to provide open access to device features,
under a mattress or pillow while charging or perform including demands on battery life, to the extent an
excessive write cycles to the solid state drive. Apps, aggrieved developer could show that similar apps
including any third-party advertisements displayed within offered by the platform have better access to battery
them, may not run unrelated background processes, such life resources.
as cryptocurrency mining.
S. 2992, Sec. 3(a)(4) would interfere with the enforce-
2.4.3 ment of this guideline because the provision would
People should be able to use your Apple TV app without bar Apple from materially restricting access by a
the need for hardware inputs beyond the Siri remote or developer to device features, including demands on
third-party game controllers, but feel free to provide battery life.
enhanced functionality when other peripherals are
connected. If you require a game controller, make sure you
clearly explain that in your metadata so customers know
they need additional equipment to play.
WHAT WOULD CHANGE
2.4.4
Apps should never suggest or require a restart of the S. 2710, Sec. 3(f) would interfere with the enforcement
device or modifications to system settings unrelated to the of this guideline because the provision would require
core functionality of the app. For example, don’t encourage Apple to provide access to software and hardware
users to turn off Wi-Fi, disable security features, etc. features on equivalent terms as the platform’s similar
apps and an aggrieved developer may be able to find
2.4.5 a platform-provided app with greater access.
Apps distributed via the Mac App Store have some
additional requirements to keep in mind: Sec. 3(b) would interfere with the enforcement of this
guideline because the provision prohibits restrictions
(i) They must be appropriately sandboxed, and follow on communications with a user concerning a legit-
macOS File System Documentation. They should also only imate business offer (in the context of the bill’s re-
use the appropriate macOS APIs for modifying user data quirement to allow sideloading, a trial attorney could
stored by other apps (e.g. bookmarks, Address Book, or easily). Interpret encouragement to disable security
Calendar entries). features as a necessary complement to a legitimate
business offer).
(ii) They must be packaged and submitted using
technologies provided in Xcode; no third-party installers S. 2992, Sec. 3(a)(4) would interfere with enforcement of
allowed. They must also be self-contained, single app in- this guideline because the provision prohibits material
stallation bundles and cannot install code or resources restrictions on a
in shared locations. developer’s access to device and software features, even if
they are not core to the functionality of the app
(iii) They may not auto-launch or have other code run
automatically at startup or loginwithout consent nor spawn
processes that continue to run without consent after a
user has quit the app. They should not automatically add
icons to the Dock or leave shortcuts on the user desktop.
ACT | The App Association | Annotated App Store Guidelines 13www.actonline.org
(iv) They may not download or install standalone apps, kexts,
additional code, or resources to add functionality or significant-
ly change the app from what we see during the review process.
(v) They may not request escalation to root privileges or use
setuid attributes.
(vi) They may not present a license screen at launch,
require license keys, or implement their own copy
protection.
(vii) They must use the Mac App Store to distribute
updates; other update mechanisms are not allowed.
(viii) Apps should run on the currently shipping OS and may not
use deprecated or optionally installed
technologies (e.g. Java) (ix) Apps must contain all language and
localization support in a single app bundle.
2.5 Software Requirements
2.5.1
Apps may only use public APIs and must run on the
currently shipping OS. Learn more about public APIs. Keep your
apps up-to-date and make sure you phase out any deprecated
features, frameworks or technologies that will no longer be
WHAT WOULD CHANGE
supported in future versions of an OS. Apps should use APIs
and frameworks for their intended S. 2710, Sec. 3(d)(2) could interfere with the enforce-
purposes and indicate that integration in their app ment of this guideline because the provision would
description. For example, the HomeKit framework should pro- require Apple to provide readily accessible means
vide home automation services; and HealthKit should be used for users of its operating system to install third-party
for health and fitness purposes and integrate with the Health apps or app stores through means other than its app
app. store and this guideline restricts developers’ ability to
install apps outside the app store.
2.5.2
Apps should be self-contained in their bundles, and may not
read or write data outside the designated container area, nor
may they download, install, or execute code which introduces
or changes features or functionality of the app, including other
apps.
Educational apps designed to teach, develop, or allow students
to test executable code.
WHAT WOULD CHANGE
2.5.3
Apps that transmit viruses, files, computer code, or S. 2992 3(a)(4) would interfere with the enforcement
programs that may harm or disrupt the normal operation of of this guideline because the provision would prohib-
the operating system and/or hardware features, including Push it Apple from materially restricting a business user’s
Notifications and Game Center, will be rejected. Egregious viola- access to software features and removing an app for
tions and repeat behavior will result in removal from the Apple introducing viruses or other code that “disrupts” nor-
Developer Program. mal operation of the operating system or hardware
features would constitute such a restriction.
Apple could overcome this prohibition on a case-by-
case basis via an affirmative defense, but the guide-
line would be otherwise unenforceable.
14 ACT | The App Association | Annotated App Store Guidelineswww.actonline.org 2.5.4 Multitasking apps may only use background services for their intended purposes: VoIP, audio playback, location, task completion, local notifications, etc. If your app uses location background mode, include a reminder that doing so may dramatically decrease battery life. 2.5.5 Apps must be fully functional on IPv6-only networks. 2.5.6 Apps that browse the web must use the appropriate WebKit framework and WebKit Javascript. 2.5.7 Video streaming content over a cellular network longer than 10 minutes must use HTTP Live Streaming and include a baseline 192 kbps HTTP Live stream. 2.5.8 Apps that create alternate desktop/home screen environments or simulate multi-app widget experiences will be rejected. WHAT WOULD CHANGE 2.5.9 Apps that alter or disable the functions of standard S. 2992, Sec. 3(a)(4) could interfere with Apple’s switches, such as the Volume Up/Down and Ring/Silent enforcement of this guideline because the provision switches, or other native user interface elements or prohibits material restrictions on a business user’s behaviors will be rejected. For example, apps should not access to hardware or software features, which may block links out to other apps or other features that users include altering functions of standard switches like would expect to work a certain way. Learn more about volume, ring, and other native user interface ele- proper handling of links. ments. 2.5.10 Apps should not be submitted with empty ad banners or test advertisements. ACT | The App Association | Annotated App Store Guidelines 15
www.actonline.org
2.5.11 SiriKit and Shortcuts:
(i) Apps integrating SiriKit and Shortcuts should only sign
up for intents they can handle without the support of an
additional app and that users would expect from the stated
functionality. For example, if your app is a meal planning
app, you should not incorporate an intent to start a workout,
even if the app shares integration with a fitness
app.
(ii) Ensure that the vocabulary and phrases in your plist
pertains to your app and the Siri functionality of the intents
the app has registered for. Aliases must relate directly to WHAT WOULD CHANGE
your app or company name and should not be generic terms
or include third-party app names or services.
S. 2710, Sec. 3(b) would interfere with the enforce-
(iii) Resolve the Siri request or Shortcut in the most direct ment of this guideline because the provision bars re-
way possible and do not insert ads or other marketing strictions on communications concerning “legitimate
between the request and its fulfillment. Only request a business offers,” which an aggrieved developer could
disambiguation when required to complete the task (e.g. interpret to include using a third-party app name or
asking the user to specify a particular type of workout). services as an alias in Shortcuts or SiriKit.
2.5.12
Apps using CallKit or including an SMS Fraud Extension
should only block phone numbers that are confirmed spam.
Apps that include call-, SMS-, and MMS- blocking
functionality or spam identification must clearly identify
these features in their marketing text and explain the criteria
for their blocked and spam lists. You may not use the data
accessed via these tools for any purpose not directly related
to operating or improving your app or extension (e.g. you
may not use, share, or sell it for tracking purposes, creating
user profiles, etc.).
2.5.13
Apps using facial recognition for account authentication
must use LocalAuthentication (and not ARKit or other facial
recognition technology) where possible, and must use an
alternate authentication method for users under 13 years
old.
2.5.14
Apps must request explicit user consent and provide a clear WHAT WOULD CHANGE
visual and/or audible indication when recording, logging, or
otherwise making a record of user activity. This includes any
use of the device camera, microphone, screen recordings, S. 2992, Sec. 3(a)(1) would interfere with this guide-
or other user inputs. line because the provision bars preferencing Apple’s
own services over those of another business user,
2.5.15 which may include requiring the Files app and iCloud
Apps that enable users to view and select files should to appear in prompts to select files.
include items from the Files app and the user’s iCloud
documents.
2.5.16
App Clips, widgets, extensions, and notifications should be
related to the content and functionality of your app.
Additionally, all App Clip features and functionality must be
included in the main app binary. App Clips cannot contain
advertising.
16 ACT | The App Association | Annotated App Store Guidelineswww.actonline.org
BUSINESS WHAT WOULD CHANGE
S. 2710, Sec. 3(b) would interfere with the enforce-
There are many ways to monetize your app on the App ment of this guideline because the provision bars
Store. If your business model isn’t obvious, make sure to restrictions on communications concerning legitimate
explain in its metadata and App Review notes. If we can’t business offers, and an aggrieved developer could
understand how your app works or your in-app purchases argue that a price Apple determines to be "clear rip-
aren’t immediately obvious, it will delay your review and may offs" is nonetheless a "legitimate business offer."
trigger a rejection. And while pricing is up to you, we won’t
distribute apps and in-app purchase items that are clear S.2992, Sec. 3(a)(3) would interfere with the enforce-
rip-offs. We’ll reject expensive apps that try to cheat users ment of this guideline as well because the provisions
with irrationally high prices. would bar discrimination in the application of guide-
line among similarly situated business users and a
If we find that you have attempted to manipulate reviews, trial attorney could interpret the decision to remove
inflate your chart rankings with paid, incentivized, filtered, or or reject an app on this basis as discriminatory.
fake feedback, or engage with third-party services to do so
on your behalf, we will take steps to preserve the integrity Sec. 3(a)(4) would also interfere with the enforcement
of the App Store, which may include expelling you from the of this guideline because the provision would prohibit
Apple Developer Program. material restrictions on the capacity of a business
user to access software features that are available to
offerings of the platform that would compete with
the business user and trial attorney could use this as
a hook to challenge a decision to reject based on an
3.1 Payments app's high price.
3.1.1 In-App Purchase:
If you want to unlock features or functionality within your
app, (by way of example: subscriptions, in-game currencies,
game levels, access to premium content, or unlocking a full
version), you must use in-app purchase. Apps may not use
their own mechanisms to unlock content or functionality,
such as license keys, augmented reality markers,
QR codes, etc. Apps and their metadata may not include
buttons, external links, or other calls to action that direct
customers to purchasing mechanisms other than in-app pur- WHAT WOULD CHANGE
chase. Apps may use in-app purchase currencies to enable
customers to “tip” the developer or digital content providers
S. 2710, Sec. 3(a)(1) would interfere with the
in the app.
enforcement of this guideline because the pro-
vision prohibits Apple from requiring developers
to use its own in-app payment system.
S. 2992, Sec. 3(a)(5) could interfere with this
guideline because it prohibits conditioning ac-
cess to the covered platform on the purchase
or use of other services that are "not part of or
intrinsic to" the covered platform and payment
processing may be interpreted as "not part of or
intrinsic to" the platform.
ACT | The App Association | Annotated App Store Guidelines 17www.actonline.org
Digital gift cards, certificates, vouchers, and coupons which
can be redeemed for digital goods or services can only be
sold in your app using in-app purchase. Physical gift cards WHAT WOULD CHANGE
that are sold within an app and then mailed to customers
may use payment methods other than in-app purchase. S. 2710, Sec. 3(b) would interfere with the enforce-
ment of this guideline because the provision prohibits
Non-subscription apps may offer a free time-based trial restrictions on developer communications concerning
period before presenting a full unlock option by setting up legitimate business offers, and a trial attorney could
a Non-Consumable IAP item at Price Tier 0 that follows the interpret disclosure requirements regarding free
naming convention: “XX-day Trial.” trials as a restriction on communications concerning
legitimate business offers.
Prior to the start of the trial, your app must clearly identify
its duration, the content or services that will no longer be
accessible when the trial ends, and any downstream charges
the user would need to pay for full functionality.
Learn more about managing content access and the
duration of the trial period using Receipts and Device Check.
3.1.2 Subscriptions:
Apps may offer auto-renewing in-app purchase
subscriptions, regardless of category on the App Store.
When incorporating auto-renewable subscriptions into your
app, be sure to follow the guidelines below.
18 ACT | The App Association | Annotated App Store Guidelineswww.actonline.org
Apps may use in-app purchase currencies to enable
customers to “tip” the developer or digital content providers WHAT WOULD CHANGE
in the app.
S. 2710, Sec. 3(a)(1) would interfere with the enforce-
ment of this guideline because the provision prohibits
Any credits or in-game currencies purchased via in-app
Apple from requiring developers to use its own in-app
purchase may not expire, and you should make sure you
payment system.
have a restore mechanism for any restorable in-app
purchases.
S. 2992, Sec. 3(a)(5) could interfere with this guide-
line because it prohibits conditioning access to the
covered platform on the purchase or use of other ser-
Apps may enable gifting of items that are eligible for
vices that are “not part of or intrinsic to” the platform.
in-app purchase to others. Such gifts may only be refunded
to the original purchaser and may not be exchanged.
Apps distributed via the Mac App Store may host plug-ins or
extensions that are rnabled with mechanisms other than the
App Store.
WHAT WOULD CHANGE
Apps offering “loot boxes” or other mechanisms that provide S. 2710, Sec. 3(1) would interfere with the enforce-
randomized virtual items for purchase must disclose the ment of this guideline because the provision prohib-
odds of receiving each type of item to customers prior to its requiring developers to use the platform’s own
purchase. payment system, limiting the platform’s ability to
impose restrictions on payment processing, including
a prohibition on the exchange of gifted items.
WHAT WOULD CHANGE
S. 2710, Sec. 3(b) would interfere with the enforce-
ment of this guideline because the provision would
prohibit Apple from restricting communications of
developers concerning “legitimate business offers”
and a trial attorney could interpret a requirement to
disclose the odds of receiving certain items in a loot
box as restricting its communication concerning a
legitimate business offer.
ACT | The App Association | Annotated App Store Guidelines 19www.actonline.org
3.1.2(a) Permissible uses: If you offer an auto-renewing
subscription, you must provide ongoing value to the
customer, and the subscription period must last at least
WHAT WOULD CHANGE
seven days and be available across all of the user’s
devices. While the following list is not exhaustive, S. 2710, Sec. 3(b) would interfere with the enforce-
examples of appropriate subscriptions include: new game ment of this guideline because the provision prohibits
levels; episodic content; multiplayer support; apps that restrictions on developer communications concerning
offer consistent, substantive updates; access to large legitimate business offers and a subscription period
collections of, or continually updated, media content; for in-app purchases that auto-renew after less than
software as a service (“SAAS”); and cloud support. seven days may qualify as a legitimate communica-
tion.
In addition:
• Subscriptions may be offered alongside à la carte
offerings (e.g. you may offer a subscription to an
entire library of films as well the purchase or rental of
a single movie).
• You may offer a single subscription that is shared
across your own apps and services.
WHAT WOULD CHANGE
• Games offered in a streaming game service subscrip-
tion may offer a single subscription that is shared S. 2992, Sec. 3(a)(4) and S. 2710, Sec. 3(d) would
across third-party apps and services; however, they interfere with Apple’s ability to enforce this consumer
must be downloaded directly from the App Store, protection.
must be designed to avoid duplicate payment by a
subscriber, and should not disadvantage non-sub-
scriber customers.
• Subscriptions must work on all of the user’s devices
where the app is available. Learn more about sharing
a subscription across your apps.
WHAT WOULD CHANGE
• Apps must not force users to rate the app, review the
app, download other apps, or other similar actions in S. 2992, Sec. 3(a)(4) and S. 2710, Sec. 3(d) would
order to access functionality, content, or use of the interfere with Apple’s ability to enforce this consumer
app. protection.
• As with all apps, those offering subscriptions should
allow a user to get what they’ve paid for without
performing additional tasks, such as posting on social
media, uploading contacts, checking in to the app a
certain number of times, etc. WHAT WOULD CHANGE
S. 2992, Sec. 3(a)(4) and S. 2710, Sec. 3(d) would
interfere with Apple’s ability to enforce this consumer
protection.
20 ACT | The App Association | Annotated App Store Guidelineswww.actonline.org
• Subscriptions may include consumable credits, gems,
in-game currencies, etc., and you may offer subscrip-
tions that include access to discounted consumable
goods (e.g. a platinum membership that exposes gem-
packs for a reduced price).
WHAT WOULD CHANGE
• If you are changing your existing app to a subscrip-
tion-based business model, you should not take away S. 2992, Sec. 3(a)(4) and S. 2710, Sec. 3(d) would
the primary functionality existing users have already interfere with Apple’s ability to enforce this con-
paid for. For example, let customers who have already sumer protection.
purchased a “full game unlock” continue to access the
full game after you introduce a subscription model for
new customers.
• Auto-renewing subscription apps may offer a free trial
period to customers by providing the relevant informa-
tion set forth in App Store Connect. Learn more about
Subscription Free Trials.
WHAT WOULD CHANGE
• Apps that attempt to scam users will be removed from
theApp Store. This includes apps that attempt to trick S. 2992, Sec. 3(a)(4) and S. 2710, Sec. 3(d) would
users into purchasing a subscription under false pre- interfere with Apple’s ability to enforce this con-
tenses to engage in bait-and-switch and scam practices; sumer protection.
these will be removed from the App Store and you may
be removed from the Apple Developer Program.
ACT | The App Association | Annotated App Store Guidelines 21www.actonline.org
• Cellular carrier apps may include auto-renewing mu-
sic and video subscriptions in predefined bundles with WHAT WOULD CHANGE
cellular data plans, with prior approval by Apple. Other
autorenewing subscriptions may also be included in
S. 2992, Sec. 3(a)(4)-(5) may come into play here if
pre-defined bundles with cellular dataplans, with prior
developers can argue that the restrictions on bundles
approval by Apple, if the cellular carrier apps support
are reducing access to the platform.
in-app purchase for new users and the carrier provides
a mechanism for customers to revert to in-app purchase
upon termination of the customer’s bundled service. Such
subscriptions cannot include access to or discounts on
consumable items.
3.1.2(b) Upgrades and Downgrades:
Users should have a seamless upgrade/downgrade
experience and should not be able to inadvertently subscribe
to multiple variations of the same thing. Review best
practices on managing your subscription upgrade and
downgrade options.
WHAT WOULD CHANGE
3.1.2(c) Subscription Information: S. 2710, Sec. 3(b) would interfere with Apple’s ability
Before asking a customer to subscribe, you should to enforce this consumer protection. This guideline
clearly describe what the user will get for the price. How could be interpreted as infringing on a legitimate
many issues per month? How much cloud storage? What kind business communication.
of access to your service? Ensure you clearly communicate the
requirements described in Schedule 2 of the Apple Developer
Program License Agreement, found in Agreements, Tax, and
Banking.
3.1.3 Other Purchase Methods:
The following apps may use purchase methods other than
in-app purchase.
3.1.3(a) “Reader” Apps: Apps may allow a user to access previ-
ously purchased content or content subscriptions (specifically:
magazines, newspapers, books, audio, music, and Reader
apps may offer account creation for free tiers, and account
management functionality for existing customers.
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