Free sports prediction app with prizes being classified as gambling under Guideline 5.3.4

I’m looking for guidance regarding App Review classifying my app as gambling / real-money gaming under Guideline 5.3.4.

My app is a free football prediction competition app where users predict match scores and compete in rankings based on prediction accuracy.

Top-ranked users may occasionally receive promotional physical prizes such as headphones, consoles, or other products.

Important details:

  • participation is completely free
  • there are no entry fees
  • users cannot deposit money
  • users cannot withdraw money
  • there is no wagering or betting system
  • there are no sportsbooks, odds, or casino mechanics
  • users never risk money to participate
  • prizes are funded directly by the platform as promotional rewards

Apple rejected the app under:

  • Guideline 2.3.6 – Accurate Metadata
  • Guideline 5.3.4 – Gaming, Gambling, and Lotteries

App Review is stating that the app includes “real money gambling, real money betting, or real money skill-based gaming” and is requesting gambling licenses and geo-restrictions.

My understanding was that gambling generally requires users to risk something of value (money/payment/consideration) for a chance to win prizes, which does not happen in this app.

I would appreciate guidance from developers who have experience with:

  1. Free prediction or fantasy-style apps with promotional prizes
  2. Skill-based competitions reviewed by Apple
  3. Sweepstakes/contest compliance on the App Store
  4. UI/wording that may accidentally trigger gambling classification
  5. Whether App Review typically requires legal contest rules instead of gambling licenses in cases like this

If anyone has successfully published a similar app, I’d really appreciate hearing what changes or clarifications helped during review.

I want to launch initially in Brazil

Thank you.

Free sports prediction app with prizes being classified as gambling under Guideline 5.3.4
 
 
Q