The Digital Services Act (DSA) is a landmark EU regulation that came into full effect in February 2024, fundamentally changing how digital platforms โ including app stores โ operate in Europe. If you publish iOS apps targeting EU users, DSA compliance is no longer optional: it directly affects how your app is reviewed, what information you must provide, and how Apple processes your submissions.
Here's everything iOS developers need to know about DSA in 2025.
What Is the Digital Services Act (DSA)?
The DSA is an EU regulation aimed at creating a safer and more accountable digital environment. It requires online platforms to be transparent about their algorithms, content moderation practices, and how they handle user data. The regulation classifies platforms by size and impact โ from basic hosting services to "Very Large Online Platforms" (VLOPs) like Apple's App Store.
Apple's App Store is classified as an online marketplace under the DSA, which means Apple must ensure that developers listing apps on its platform comply with certain transparency and accountability requirements.
How Does DSA Affect the App Store?
Apple has updated its App Store submission process to align with DSA requirements. As of 2024, Apple requires all developers distributing apps in the EU to provide additional trader information as part of their App Store Connect profile.
Trader Status Declaration
When submitting an app for distribution in the EU, you must declare whether you are a trader (a business or professional acting in a commercial capacity) or a non-trader (a private individual not acting for commercial purposes).
- Traders must provide: full legal name, business address, phone number, email, VAT or business registration number
- Non-traders simply declare that status โ no additional info required
- Misrepresenting your status can result in app removal
โ ๏ธ Important: Even if your app is free and doesn't monetize EU users, if it's available in EU App Stores and you operate commercially, you are likely a trader under DSA definitions. When in doubt, consult a legal professional.
Key DSA Requirements for App Developers
1. Transparent Contact Information
Traders must provide accurate contact details visible to users and Apple. This information will be displayed on your App Store product page so EU users can contact you directly.
2. Content Moderation Transparency
If your app features user-generated content (UGC) โ comments, posts, reviews, media uploads โ you need a clear content moderation policy. Apple may ask for this as part of the review process for apps with UGC functionality in the EU region.
3. Algorithmic Transparency
Apps that use recommendation systems or personalized feeds targeting EU users must provide meaningful explanations of how these systems work โ often called "recommender system transparency."
4. Advertising Transparency
If your app displays targeted ads to EU users, you must clearly label them as advertisements and disclose the main parameters used for targeting. This applies to both third-party ad networks and any proprietary advertising within your app.
5. Minor Protection
Apps that might be accessed by minors must implement appropriate safeguards. You cannot profile minors for targeted advertising, and systems that present risk to minors require additional mitigations.
How Apple Enforces DSA Compliance
Apple acts as the "gatekeeper" platform and enforces DSA-related requirements at the submission stage. Here's what to expect:
- App Review: Apps targeting EU users are reviewed for DSA-relevant features. Missing trader information will cause rejection
- App Store Connect: There are new mandatory fields for trader status and contact details in the agreements, tax, and banking section
- Product Page: Trader contact information is now displayed publicly on EU App Store pages
- Ongoing compliance: Apple may remove apps from EU stores if trader information becomes inaccurate or outdated
Does DSA Affect Account Type Choice?
Yes โ this is where the Individual vs Corporate distinction becomes even more important for EU distribution:
- Individual accounts used commercially: If you're a solo developer acting as a trader, you still need to provide your personal address and contact info publicly on the App Store. This is a privacy concern many developers want to avoid
- Corporate accounts: Business contact details are listed instead of personal info โ preferred for traders who want to maintain privacy while staying compliant
- Non-EU distribution: DSA only applies to apps available in EU App Stores. If you target non-EU markets exclusively, these requirements don't apply
Step-by-Step: How to Become DSA Compliant
- Log into App Store Connect
- Go to Agreements, Tax, and Banking
- Complete the trader status questionnaire
- If you're a trader, fill in all required contact fields accurately
- Review and update your app's privacy policy and terms of service
- Add content moderation and advertising policies if applicable
- Re-submit any apps that previously lacked this information
๐ Deadline note: Apple began enforcing DSA trader information requirements in Spring 2024. Apps without valid trader information were removed from EU storefronts. If you're just now setting up your account, complete this step before submitting any app targeting EU users.
What Happens If You're Not Compliant?
- Your app may be rejected during App Review
- Existing apps can be removed from EU App Stores without warning
- In severe cases of deliberate misrepresentation, your developer account can be terminated
- EU authorities can impose fines on the platform (Apple) which may cascade into stricter enforcement
DSA and Non-EU Developers
The DSA applies based on where your users are, not where you are as a developer. If you're based in the US, Ukraine, or anywhere outside the EU but your app is distributed in EU App Stores, you are subject to DSA requirements as a trader selling to EU consumers.
This is why many developers choose GEO-specific Apple Developer accounts โ to clearly define the legal entity behind each app and manage compliance per market. At Developer-iOS.Shop, we offer accounts in 10+ GEOs so you can choose the right setup for your distribution strategy.
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