Subject: Clarification on App Store Policy Regarding Payments Through Telegram Bots
Dear Apple Team,
My name is Fedor Skuratov, and I am a CEO at Combot.org. We have received a notification from Telegram (Telegram.org) regarding the necessity to switch to a new payment mechanism—Telegram Stars — for all bots that accept payments for digital goods and services.
This is the text of their announcement:
URGENT Action Required
Dear Bot Developer,
Apple has informed Telegram that @combot is in violation of App Review Guidelines 4.7 and 3.1.1, because it accepts payments for digital goods and services directly from customers without relying on Apple's in-app purchase mechanism.
To ensure that Telegram bots/mini apps such as yours continue operating without interruption on all platforms, we have developed a way for third-party developers on Telegram to accept payments from their customers that is compliant with the App Store and Play Store policies.
To this end, we are rolling out a new in-app currency, Telegram Stars, which users will be able to acquire from Telegram using standard Apple and Google in-app purchases and then use to buy digital goods and services from you. Developers will be able to review their Telegram Stars balance and withdraw them at any time using the TON blockchain.
Starting on June 12, all payments for digital goods and services in bots and mini apps will have to be carried out exclusively in Telegram Stars. Since Telegram has to follow the Guidelines imposed on us by the app stores, failure to comply with these changes will result in the suspension of @combot for most of your customers.
We will publish the full updated API documentation within the next few days, but you can already prepare your bots and mini-apps for the upcoming changes. To accept payments for digital goods and services, you will need to use the sendInvoice or createInvoiceLink methods with the currency field set to "XTR" and the provider_token field left empty.
We expect these changes to positively impact the conversion rate for payments from customers in most markets.
Payments for physical goods and services remain unchanged.
More details will be published on @botnews soon.
The Telegram Team
These changes have raised several questions and concerns as they directly impact our business. We would like to seek clarification on the following points:
**Apple's Requirements: **
- What specific requirements has Apple set for Telegram and bot developers regarding payments for digital goods and services?
- Is this requirement initiated by Apple or is it solely a decision by Telegram?
**Apple's Commission: **
-
According to the new rules, Telegram proposes using in-app currency (Telegram Stars) for all payments for digital goods and services, which adheres to the Apple/Google commission (~30%). These changes can negatively affect existing business models.
-
Are there any plans to ease the conditions or provide additional time for adaptation to the new requirements?
Jurisdictional Issues:
In most jurisdictions, receiving payments for digital goods in cryptocurrency (including TON/Telegram Stars) is illegal. How does Apple plan to address this issue in your relations with Telegram and businesses which uses the bot functionality in Telegram app?
Application of Rules:
- Do these requirements apply only to those developers using in-app Telegram Payments 2.0, or to all who sell any services and have links to these services in its bots?
Payments on Third-Party Websites:
Our service (Combot.org) which is a moderation an community management tool for communities including Telegram chats, uses Stripe to accept payments on our website, and the bot acts as an agent in chats and does not handle payments. How do Apple's new requirements relate to such business models?
We appreciate your assistance and understanding in this matter. Thank you in advance for your clarification.
Sincerely, Fedor Skuratov CEO Combot.org