Cloud-Based App Builder: Rules for Automated App Store Submission on Behalf of Users

Hello everyone,

I'm building a cloud-based AI mobile app development platform called TryAppnetic (https://tryappnetic.com), where users can generate React Native/Expo applications and publish them under their own Apple Developer accounts.

I'm currently researching how to implement automated iOS app publishing and have some questions regarding the Apple Developer Program License Agreement.

Specifically, Section 2.9 appears to restrict third-party service providers from submitting applications to the App Store or using TestFlight on behalf of developers. Section 5.1 also introduces restrictions around certificates and private keys.

I'd like to understand what is technically and legally permitted for a platform like ours.

Our intended workflow:

  1. A user generates an iOS application using our platform.
  2. We build the application in our cloud infrastructure.
  3. The user authorizes access to their Apple Developer account.
  4. We use authorized credentials or App Store Connect API keys to manage the build and upload process.
  5. The application is published under the user's own Apple Developer account.

My questions:

  1. Is it permitted for a cloud-based platform to build and compile iOS applications on behalf of users?

  2. Can we automate code signing using certificates and provisioning profiles belonging to the user, provided they explicitly authorize their use?

  3. Can we use customer-generated App Store Connect API keys to automate uploading builds to App Store Connect?

  4. Does Section 2.9 prohibit automated build uploads as well, or does it specifically prohibit the actual submission of an app for App Store review and TestFlight distribution?

  5. Would it be compliant to automate the entire build and upload process but leave the final App Store submission and TestFlight distribution actions to the account owner?

I'm particularly interested in hearing from developers who have built cloud-based development platforms, CI/CD services, or automated iOS publishing workflows.

I'd also appreciate clarification from anyone familiar with Apple's interpretation of Sections 2.9 and 5.1.

Thanks!