In the EU only, Apple permits developers to distribute iOS apps through stores other than the App Store and to use browser engines other than WebKit, subject to additional Apple terms and a notarization process.
This analysis describes what Apple's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
These EU-specific provisions reflect Apple's response to Digital Markets Act obligations and create a distinct distribution and technical framework that applies only to EU users and developers, operationally separating EU app distribution from the global App Store model.
Interpretive note: The scope and specific requirements of Apple's notarization process for alternatively distributed EU apps are subject to ongoing DMA regulatory proceedings and may be modified by European Commission enforcement decisions.
The updated guidelines state that developers must ensure kids receive age-appropriate experiences within their apps and must remove user-generated content that violates the guidelines, terms of service, or community standards. Under the revised policy, if Apple identifies policy-violating content, the developer will be asked to remove it and provide a compliance improvement plan. Based on the developer's response, the app may be removed from the App Store until compliance is demonstrated. This establishes a formal escalation pathway where developer inaction or inadequate remediation can result in app suspension or removal.
View change record →Severity downgraded from high to medium, scope expanded to include alternative browser engine provision for EU developers, added requirement for notarization of apps distributed outside App Store, and removed specific mention of alternative payment service providers and fee structures.
View full change record →EU consumers may access iOS apps distributed through alternative marketplaces outside the App Store, though those apps are subject to Apple's notarization requirements rather than full App Review; the practical security and content standards applied in this context may differ from those applied to App Store-reviewed apps.
How other platforms handle this
These Terms shall be governed by the laws of the State of California, excluding its conflicts of law rules, and the federal laws of the United States. Any dispute arising from or relating to the subject matter of these Terms shall be finally settled by arbitration in San Francisco County, California...
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"In the European Union, developers can distribute iOS apps from alternative marketplaces. Developers can also use alternative browser engines for browser apps on iOS in the EU. Developers who wish to use these capabilities must agree to additional terms and undertake additional requirements to be eligible. Apps distributed outside of the App Store in the EU are not reviewed under these guidelines but must comply with Apple's notarization requirements.— Excerpt from Apple's Apple App Store Review Guidelines
REGULATORY LANDSCAPE: These provisions directly reflect obligations imposed on Apple as a designated gatekeeper under the EU Digital Markets Act (DMA), enforced by the European Commission. The DMA requires gatekeepers to permit alternative app distribution and browser engines on their platforms. Apple's implementation of these provisions is subject to ongoing DMA compliance monitoring and potential enforcement action by the European Commission. Notarization requirements may themselves be subject to DMA scrutiny if they are found to impose unjustified restrictions. GOVERNANCE EXPOSURE: Medium. Developers using alternative distribution in the EU must assess the additional contractual terms Apple requires and evaluate how notarization requirements interact with their distribution model. The regulatory landscape for alternative distribution is actively evolving and compliance requirements may change as DMA enforcement progresses. JURISDICTION FLAGS: These provisions apply exclusively in the EU and do not affect app distribution or browser engine requirements in other jurisdictions. UK developers and apps targeting UK users are not covered by these provisions as the UK is not subject to the DMA. Developers with both EU and non-EU operations must maintain separate compliance frameworks. CONTRACT AND VENDOR IMPLICATIONS: Developers considering alternative marketplace distribution must review and agree to Apple's additional terms for this program. Marketplace operators themselves must comply with Apple's requirements for alternative marketplace authorization. B2B app vendors should assess whether enterprise customers in the EU expect or require alternative distribution options. COMPLIANCE CONSIDERATIONS: Legal teams advising EU-based app businesses should monitor European Commission DMA enforcement actions against Apple's alternative distribution implementation. Developers using alternative browser engines should assess WebKit-specific compatibility issues and ensure their browser engine choice does not conflict with other Apple platform requirements. Notarization requirements for alternatively distributed apps should be documented and workflow-integrated.
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These EU-specific provisions reflect Apple's response to Digital Markets Act obligations and create a distinct distribution and technical framework that applies only to EU users and developers, operationally separating EU app distribution from the global App Store model.
EU consumers may access iOS apps distributed through alternative marketplaces outside the App Store, though those apps are subject to Apple's notarization requirements rather than full App Review; the practical security and content standards applied in this context may differ from those applied to App Store-reviewed apps.
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