App rejected for “containing copyrighted video game files” — how to make an emulator app compliant?

Hi everyone, We’re looking for advice regarding an App Store review rejection and would really appreciate insights from developers with similar experience.

Our app is a retro game emulator platform. It provides emulator functionality only (e.g. NES / GB / GBA emulation) and does NOT include, bundle, or download any game ROMs.

Key points about our app design:

❌ No ROMs are bundled or distributed

❌ No in-app ROM downloads

✅ Users can only import their own ROM files that they legally own (e.g. personal backups)

✅ No copyrighted game names, box art, screenshots, or branding are used

✅ The app is positioned as a general-purpose emulator tool, similar to a media player that plays user-provided files

However, during review we received the following rejection:

The app appears to contain copyrighted video game files. Apps and their content should not infringe upon the rights of another party…

We’re confused about what might have triggered this decision and would appreciate guidance on:

On what basis Apple may conclude that the app “contains” copyrighted game files?

Could this be related to:

App screenshots or preview videos?

Default demo flows or UI text?

The emulator functionality itself?

What changes are typically required to pass review, such as:

Adding stronger legal disclaimers

Requiring user confirmation that imported ROMs are legally owned

Removing any potentially misleading UI wording

Explicitly clarifying ROM ownership responsibility

We’ve noticed that similar emulator apps already exist on the App Store, so we’re trying to understand:

Whether there is a clear compliance path

What modifications have worked for other developers in similar cases

Thanks a lot in advance for any advice or shared experience 🙏 Happy to provide more details if needed.

Thank you for your post. We recommend that you sign up for a session with App Review during the weekly Meet with Apple event. Sign in with your Developer ID and select "Request a one-on-one App Review consultation". A member of the App Review team will help you with your questions regarding the review process and the App Review Guidelines.

App rejected for “containing copyrighted video game files” — how to make an emulator app compliant?
 
 
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