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

AppTrackingTransparency Consent Requirement

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

What it is

Apps must ask for your explicit permission before tracking your activity across other apps and websites for advertising purposes, and cannot penalize you or offer you fewer features if you decline.

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 consent gate that users must pass through before cross-app and cross-website behavioral tracking for advertising can occur, and prohibits retaliatory restriction of app functionality for users who decline.

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

added Jun 9, 2026

This new provision establishes mandatory user consent for cross-app tracking and prevents functionality discrimination based on tracking consent, reflecting heightened privacy enforcement standards.

View full change record →

Consumer impact (what this means for users)

Consumers are required to receive an explicit opt-in prompt before an app may track their activity across other apps or websites for advertising or measurement purposes; declining this prompt is expressly protected from adverse app functionality consequences under the guidelines.

How other platforms handle this

Square Medium

to withdraw your consent to our processing of your data (where such processing is based on consent)

Instacart Medium

By providing your mobile phone number, you consent to receive automated text (SMS) messages from Instacart...To opt out, reply STOP. For help, reply HELP or contact us directly...

Netflix Medium

If you do not want us to have this access, you should not consent to support through the remote access tool, and we will assist you through other means.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Apps that use device data from third-party apps and websites to target ads or to measure advertising campaign effectiveness must request permission to track using the App Tracking Transparency framework. Apps must not track users who have not granted permission to be tracked. Apps must not offer different functionality or content in response to a user's decision to not allow tracking.

Excerpt from Apple's App Store Review Guidelines

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: The AppTrackingTransparency requirement engages with GDPR consent requirements (enforced by EU data protection authorities, particularly regarding behavioral advertising and the legal basis of consent), ePrivacy Directive obligations, and CCPA opt-out rights.

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-011498
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-011498
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-011498/apptrackingtransparency-consent-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 AppTrackingTransparency Consent Requirement clause do?

This provision establishes a consent gate that users must pass through before cross-app and cross-website behavioral tracking for advertising can occur, and prohibits retaliatory restriction of app functionality for users who decline.

How does this clause affect you?

Consumers are required to receive an explicit opt-in prompt before an app may track their activity across other apps or websites for advertising or measurement purposes; declining this prompt is expressly protected from adverse app functionality consequences under the guidelines.

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.