Provision record
Apple · Apple App Store Review Guidelines · View original document ↗

App Privacy Label Disclosure Requirement

Medium severity High confidence Explicit document language Common · 289 of 352 platforms
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Document Record

What it is

Developers must publish an accurate summary of all data their app collects, including data gathered by any third-party tools embedded in the app, and this information appears on the App Store listing page as a privacy nutrition label.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes a disclosure mechanism that consumers can use to assess an app's data practices before downloading, covering identifiers, location data, usage data, contact information, and other categories as disclosed by the developer.

Recent Activity

This document changed recently

Medium Jun 9, 2026

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 →

Clause Stability Mostly Stable

1
Change
5
Months Monitored
May 12, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.
This clause has changed once in 5 months of monitoring.

Change history

modified Jun 9, 2026

Requirement extended to explicitly cover app updates (not just new apps), added obligation to clearly describe privacy-related features, and expanded scope to mandate disclosure of third-party partner, SDK, and analytics tool data collection.

View full change record →

Consumer impact (what this means for users)

The App Privacy label on each App Store listing discloses what categories of data the app collects and how they are used, including data from third-party SDKs embedded in the app; the accuracy of these disclosures depends on the developer's compliance with the guideline's requirement to keep labels current and complete.

How other platforms handle this

Google Cloud Medium

When you use them, we'll validate your request by verifying your identity (for example, by confirming that you're signed in to your Google Account).

Notion Medium

Not be Discriminated Against by us for exercising your privacy rights.

Glassdoor Medium

We may provide an option for users to opt into the disclosure of their demographic data in a manner and to an extent that may lead to loss of their anonymity.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
All new apps and app updates must include accurate privacy information in App Store Connect that will be displayed on your App Store product page. Apps must clearly describe new privacy-related features. You must keep this information up to date. Privacy labels should reflect your app's data collection and use practices including data collected by third-party partners, SDKs, and analytics tools used in your app.

Excerpt from Apple's App Store Review Guidelines

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: The App Privacy label requirement engages with GDPR transparency obligations (enforced by EU data protection authorities) and CCPA disclosure requirements (enforced by the California Attorney General and California Privacy Protection Agency).

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Applicable regulations

EU AI Act
European Union
BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
HIPAA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
TCPA
United States Federal
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Apple App Store Review Guidelines
Entity
Apple
Document last updated
May 5, 2026
Tracking information
First tracked
April 28, 2026
Last verified
May 12, 2026
Record ID
CA-P-011497
Document ID
CA-D-00025
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
307db15d06f03003277f88a1476a1308e92cc7cba75906b4fac341d1054f5040
Analysis generated
April 28, 2026 08:36 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Apple
Document: Apple App Store Review Guidelines
Record ID: CA-P-011497
Captured: 2026-04-28 08:36:55 UTC
SHA-256: 307db15d06f03003…
URL: https://conductatlas.com/platform/apple/apple-app-store-review-guidelines/provision/CA-P-011497/app-privacy-label-disclosure-requirement/
Accessed: Aug. 25, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Apple's App Privacy Label Disclosure Requirement clause do?

This provision establishes a disclosure mechanism that consumers can use to assess an app's data practices before downloading, covering identifiers, location data, usage data, contact information, and other categories as disclosed by the developer.

How does this clause affect you?

The App Privacy label on each App Store listing discloses what categories of data the app collects and how they are used, including data from third-party SDKs embedded in the app; the accuracy of these disclosures depends on the developer's compliance with the guideline's requirement to keep labels current and complete.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.

Is ConductAtlas affiliated with Apple?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Apple.