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
If you reside in the EEA, you can also raise the dispute with an alternative dispute resolution body via the European Commission's Online Dispute Resolution (ODR) Platform...
The Federal Trade Commission has jurisdiction over ZipRecruiter's compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.
you consent as part of these Terms to venue for such cases exclusively in these courts.
"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 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.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
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.
ConductAtlas has identified this type of provision across 266 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Apple.