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Manage European Union Digital Services Act trader requirements

Articles 30 and 31 of the Digital Services Act (DSA) require Apple to verify and display trader contact information for all traders distributing apps on the App Store in the European Union (EU). This includes an address, phone number, and email address that you provide to Apple for the purpose of posting on your App Store product page in accordance with the DSA. Once verified, Apple will publish this information on your App Store product page when your app is distributed in any of the 27 territories of the EU.

If you haven't already confirmed your trader status, next time you submit a new app in App Store Connect you’ll be asked to disclose whether or not you’re a trader in connection with the DSA in order to stay compliant across territories when distributing on the App Store. You'll need to confirm your trader status if you have at least one app on the App Store in the EU that qualifies you as a trader. You’ll then have the option to turn off or specify your trader status for each specific app that you distribute. If you’re not a trader, consumers in the EU will be informed that consumer rights stemming from applicable consumer protection laws won’t apply to contracts between you and them.

Trader self-assessment

You must assess whether you are a trader for EU law purposes. If you don't distribute apps on the App Store in the EU (e.g. you only distribute apps via alternative distribution, or TestFlight, or on the App Store only outside the EU), you're not acting as a trader on the App Store. Apple can't determine whether you're a trader.

How to know if you’re a trader

The DSA defines a trader as “any natural person, or any legal person irrespective of whether privately or publicly owned, who is acting, including through any person acting in his or her name or on his or her behalf, for purposes relating to his or her trade, business, craft or profession.”

The European Commission (EC) has issued a Notice on what constitutes a trader (See Section 2.2. “Concept of Trader"), though it is not specific to digital commerce. The EC has also published Guidance in the digital commerce context, from the perspective of when an ”influencer“ may be considered a trader.

To determine if you're a trader, you should consider a range of non-exhaustive and non-exclusive factors (see those listed on page 2 in the EC’s Guidance), which may include:

  • Whether you make revenue as a result of your app, for example if your app includes in-app purchases, or if it's a paid or ad-sponsored app — especially if you're transacting in large volumes;

  • Whether you engage in commercial practices towards consumers, including advertising, or promoting products or services;

  • Whether you're registered for VAT purposes; and

  • Whether you develop your app in connection with your trade, business, craft, or profession—meaning that you’re acting in a professional/business capacity. You're unlikely to be a trader for EU law purposes if you're acting “for purposes which are outside your trade, business, craft, or profession.” For example, if you're a hobbyist and you developed your app with no intention of commercializing it, you may not be considered a trader.

Regardless of whether you’re an individual developer or organization, if you have a legal status associated with a business activity, that would suggest you may be a trader.

The material contained herein is informational, general in nature, and does not constitute legal advice. If you're uncertain about your status as a trader, consult with your legal advisor.

Information you need to provide if you're a trader

The information you need to provide depends on whether you’re enrolled in the Apple Developer Program as an individual or organization.

Organizations: The address associated with your D-U-N-S Number will automatically display. You’ll need to enter the following for display on your App Store product pages:

  • Phone number

  • Email address

This information is for display purposes only and won’t impact the information associated with your Apple Developer Program membership. If you need to update your physical address, contact us.

Individuals: You’ll need to enter the following for display on your App Store product pages:

  • Address or P.O. Box

  • Phone number

  • Email address

This information is for display purposes only and won’t impact the information associated with your Apple Developer Program membership.

All traders: You’ll need to provide payment account details, if you haven’t already entered them in App Store Connect. You'll also be asked to certify that you only offer products or services that comply with the applicable rules of EU law.

Enter EU Digital Services Act compliance information

Required role: Account Holder or Admin. View role permissions.

  1. From the home page, click Business.

  2. On the Agreements tab, scroll down to the Compliance section.

  3. Next to Digital Services Act, click Complete Compliance Requirements.

  4. Select from the following options:

    1. “This is a trader account.” You’ll need to enter contact information for display on your App Store product pages. Continue to step 5.

      Note: You’ll still have the option to turn off your trader status for specific apps later.

    2. “This is not a trader account.” You won’t need to provide any contact information. Click Done.

  5. Enter or confirm the required contact information and click Next.

  6. Validate the email address you provided using two-factor authentication. Once you’re done, you’ll automatically be directed to the next step.

  7. Validate the phone number you provided on the previous screen using two-factor authentication. Once you’re done, you’ll automatically be directed to the next step.

  8. Follow the instructions to upload your documentation. You’ll need to provide a current document that verifies your business name and address. Acceptable documents include business or legal records. If you’re displaying an alternate address, such as a P.O. Box, you’ll also need to provide documentation that reflects your association with this alternate address (for example, a receipt or bill). When you’re done, click Next.

  9. Review your information to make sure it’s correct, then click Confirm.

Enter app-specific EU Digital Services Act compliance information

Required role: Account Holder and Admin. View role permissions.

If you need to change your trader status for one or more of your individual apps, you can do so.

  1. From the home page, click Apps.

  2. Select your app from the list.

  3. In the left sidebar, click App Information.

  4. Scroll to the App Store Regulations and Permits section.

  5. Under Digital Services Act, click Edit.

  6. In the pop-up window, change your trader status for that app. If you’re declaring yourself a trader for the first time, you’ll need to enter and verify your contact information that displays on your app’s App Store product page.

Enter labels and markings URLs

Required role: Account Holder and Admin. View role permissions.

Under the Digital Services Act, you have the option to provide a Labels and Markings URL to display labels or markings required by European Union law. This URL will be visible on your App Store product pages.

  1. From the home page, click Apps.

  2. Select your app from the list.

  3. In the left sidebar, click App Information.

  4. Scroll to the App Store Regulations and Permits section.

  5. Click Add Labels and Markings.

  6. In the pop-up window, enter the URL and click Done. You can edit this URL at any time.