According to the EU Digital Services Act (DSA) requirements, Apple must verify and display trader contact information for all traders/ stores distributing apps on the App Store in the EU region. Developers must disclose whether they fall under the definition of a "trader" as defined by the EU DSA to ensure compliance when distributing apps on the App Store across the EU region.
*Reminder:
‣ When the store first launches the app, regardless of whether the app needs to be published in the European Union region, account compliance requirements must be met before the app can be published.
‣ If your app has already been published in the EU region, please complete the compliance requirements before 16 October 2024. If the compliance requirements are not completed by 17 February 2025, your app will be removed from the EU App Store.
‣ Click here for more detailed compliance info about the App Store.
This article will cover the following:
1. How to confirm if you are a trader
The Digital Services Act (DSA) defines a trader as “any natural person, or any legal person irrespective of whether privately or publicly owned, who is acting, including through any person acting in his or her name or on his or her behalf, for purposes relating to his or her trade, business, craft or profession.”
The European Commission (EC) has issued a Notice on what constitutes a trader (See Section 2.2. “Concept of Trader"). The EC has also published Guidance in the digital commerce context, from the perspective of when an ”influencer“ may be considered a trader.
To determine if you're a trader, you should consider a range of non-exhaustive and non-exclusive factors (see those listed on page 2 in the EC’s Guidance), which may include:
- Whether you make revenue as a result of your app, for example if your app includes in-app purchases, or if it's a paid or ad-sponsored app — especially if you're transacting in large volumes.
- Whether you engage in commercial practices towards consumers, including advertising, or promoting products or services.
- Whether you're registered for VAT purposes.
- Whether you develop your app "in connection with your trade, business, craft, or profession"—meaning that you’re acting in a professional/business capacity. You're unlikely to be a trader for EU law purposes if you're acting “for purposes which are outside your trade, business, craft, or profession.” For example, if you're a hobbyist and you developed your app with no intention of commercializing it.
Regardless of whether you’re an individual developer or an organization, if you have a legal status associated with a business activity, that would suggest you may be a trader.
The material contained herein is informational, general in nature, and does not constitute legal advice. If you're uncertain about your status as a trader, consult with your legal advisor.
2. Apple business account
App Store will automatically display the address associated with your DUNS number, and you must provide the following information to be displayed on the App Store product page.
- Phone number
- Email address
This information is for display purposes only and does not affect the information for registering the Apple Developer Program.
Process of completing compliance requirements
*Please be reminded before you start: The "Account Holder" role is required to proceed with the operation.
Step 1
Go to App Store Connect > the "Business" tab and click on Complete Compliance Requirements for XXX.
Step 2
Select the "Agreements" tab, and within the "⚠️ The Digital Services Act" reminder field, click Complete Compliance Requirements.
Step 3
Choose your trade provider identity. Check "This is a trader provider account" and click Next to proceed.
*Note: If you are not a trader or your app does not need to be published in the EU region, you can simply check "This is a non-trader provider account" and click Next to complete the compliance requirements.
Step 4
Enter or confirm all required contact information, then click Next.
Step 5
Verify the phone number you provided in the previous step through two-factor authentication. Once completed, the system will automatically proceed to the next step.
Step 6
Verify the email address you provided through two-factor authentication. Once completed, the system will automatically proceed to the next step.
Step 7
Follow the instructions to upload the relevant proof documents. Please provide documents proving your business name and address, ensuring that the latest versions are submitted. Supported proof documents include business or legal records. If you choose to display a different address, such as a postal mailbox address, you will also need to provide documents proving your association with that address (e.g. receipts or bills). Upon completion, click Next.
Step 8
Review the information you provided, ensure its accuracy, and then click Confirm.
3. Apple personal account
App Store will automatically display the address associated with your DUNS number, and you must provide the following information to be displayed on the App Store product page.
- Address or postal mailbox address
- Phone number
- Email address
This information is for display purposes only and does not affect the information for registering the Apple Developer Program.
Process of completing compliance requirements
*Please be reminded before you start: The "Account Holder" role is required to proceed with the operation.
Step 1
Go to App Store Connect > the "Business" tab and click on Complete Compliance Requirements for XXX.
Step 2
Select the "Agreements" tab, and within the "⚠️ The Digital Services Act" reminder field, click Complete Compliance Requirements.
Step 3
Choose your trade provider identity. Check "This is a trader provider account" and click Next to proceed.
*Note: If you are not a trader or your app does not need to be published in the EU region, you can simply check "This is a non-trader provider account" and click Next to complete the compliance requirements.
Step 4
Fill in personal information, which will be displayed on the App Store.
Step 5
Verify the email address you provided in the previous step through two-factor authentication. Please check your inbox for the 6-digit verification code. Once entered here, the system will automatically proceed to the next step.
Step 6
Verify the phone number you provided in the previous step through two-factor authentication. Please check your mobile phone for the 6-digit verification code. Once entered here, the system will automatically proceed to the next step.
Step 7
Review the information you provided, ensure its accuracy, and then click Confirm.
Read more
- What is the difference between Apple iOS Developer Account's Individual/Sole Proprietor and Company/Organization?
- D-U-N-S Number Verification
- Apple ID Registration and D-U-N-S Number Request
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