5.3 Gaming, Gambling, and Lotteries

Hello,


I am looking to launch a 'skill based gaming' app which involves players purchasing in game currency to bet against each other on video games with users able to withdraw their winnings. Entirely skill based games and therefore UK legal obligations are covered, however I was hoping to get some clarification on 5.3.3 of the review guidlines.


"5.3.3 Apps may not use in-app purchase to purchase credit or currency for use in conjunction with real money gaming of any kind, and may not enable people to purchase lottery or raffle tickets or initiate fund transfers in the app."

Does this mean there is another form of purchase for my in game currency that would be acceptable?


Is there anything else that might cause my app to be rejected by the Review Team?


Thanks,

MT

Replies

> Does this mean there is another form of purchase for my in game currency that would be acceptable?


yes, any third party system like pay pal or even apple pay.


>Is there anything else that might cause my app to be rejected by the Review Team?


Sure....

5.3.4 Apps that offer real money gaming (e.g. sports betting, poker, casino games, horse racing) or lotteries must have necessary licensing and permissions in the locations where the App is used, must be geo-restricted to those locations, and must be free on the App Store. Illegal gambling aids, including card counters, are not permitted on the App Store. Lottery apps must have consideration, chance, and a prize.

Thanks very much for your answer PBK, good to know.


In response to point 5.3.4, the app will be restricted to the UK where we have the necessary licensing and permissions. The app will be free, and there will be no such illegal aids of any kind.


In which case I'd like to think we are in the clear, however if you have any more thoughts or if anybody else reading this has reason to believe the app may be rejected I'm all ears!


Thanks again,

MT

>the app will be restricted to the UK


I assume you are detecting the geolocation of the device each time the app enters foreground. You can't just rely on the user's App Store country.

Sorry PBK I've had trouble logging into the forum for a week or so.


Thanks again for your response. Following this we will not rely on the user's App Store country, and ensure the app detects the geolocation of the device each time the app enters foreground.


Going back to your inital answer about 5.3.3


5.3.3 Apps may not use in-app purchase to purchase credit or currency for use in conjunction with real money gaming of any kind, and may not enable people to purchase lottery or raffle tickets or initiate fund transfers in the app."

Does this mean there is another form of purchase for my in game currency that would be acceptable?

"yes, any third party system like pay pal or even apple pay."


Isn't this contradicted by:

3.1 Payments

3.1.1 In-App Purchase:

  • If you want to unlock features or functionality within your app, (by way of example: subscriptions, in-game currencies, game levels, access to premium content, or unlocking a full version), you must use in-app purchase. Apps may use in-app purchase currencies to enable customers to “tip” digital content providers in the app. Apps and their metadata may not include buttons, external links, or other calls to action that direct customers to purchasing mechanisms other than in-app purchase.


Sorry to cover this again I just want to be sure before signing off.


Thanks,

MT

I guess this means you can’t unlock code. But the other aspects of the app are the same whether or not the user has money to gamble - the money diesn’t unlock code. Anyone can walk into the casino, it’s not locked even if you have no money.