Apple tightens App Store age controls and data sharing disclosure

Apple revised its App Review Guidelines on November 13, 2025, introducing several policy changes affecting mobile app developers and marketers operating within the company's ecosystem. The updates address content moderation, financial service restrictions, third-party branding protections, and enhanced privacy disclosure requirements that extend to artificial intelligence applications.

The guidelines now mandate that creator apps implement age restriction mechanisms based on verified or declared user age to limit underage access to content exceeding the application's age rating, according to newly added section 1.2.1(a). This requirement reflects broader platform concerns about content safety for younger users, particularly as apps increasingly incorporate user-generated content and AI-powered features.

Section 4.7 received expanded clarification specifically naming HTML5 and JavaScript mini apps and mini games within its scope. The update addresses growing platform concerns about embedded software that operates outside standard app review processes. Developer discussions surrounding Apple's Mini Apps Partner Program have highlighted tensions between the company's 30% standard commission structure and alternative distribution models offering 85% revenue shares to developers.

Financial service applications face new constraints under revised section 3.2.2(ix), which establishes that loan apps cannot charge maximum annual percentage rates exceeding 36%, including all costs and fees. The policy further prohibits requiring full repayment within 60 days or less. These restrictions represent significant regulatory intervention in mobile lending practices, potentially affecting payday loan applications and short-term credit services distributed through the App Store.

Privacy disclosure requirements received substantial reinforcement through updates to section 5.1.2(i). Developers must now clearly disclose when personal data will be shared with third parties, explicitly including third-party AI systems, and obtain explicit user permission before such sharing occurs. The requirement comes as privacy regulators intensify scrutinyof how AI model providers collect and utilize personal information for training purposes.

The guidelines added crypto exchanges to the list of apps providing services in highly regulated fields under section 5.1.1(ix), subjecting cryptocurrency trading platforms to enhanced review standards previously applied to banking, medical, and gambling applications. This classification could affect how marketing campaigns position crypto-related applications and what compliance documentation developers must provide during the submission process.

Section 4.1(c) introduces new intellectual property protections preventing developers from using another developer's icon, brand, or product name within their application's icon or name without explicit approval. The restriction addresses growing concerns about application spoofing and brand confusion within crowded App Store categories where similar names and iconography sometimes mislead users about an application's actual developer or affiliation.

Applications offering software not embedded in the binary received multiple clarifications affecting mini apps, HTML5 games, and JavaScript-based content. Section 4.7.2 now explicitly states that such applications cannot extend or expose native platform APIs or technologies to the software without prior Apple permission. Section 4.7.5 requires these applications to provide age restriction mechanisms identical to those mandated for creator apps under section 1.2.1(a).

The November 13 announcement noted that Apple deleted previous language under section 2.5.10 which had stated "Apps should not be submitted with empty ad banners or test advertisements." This removal potentially signals shifting enforcement priorities around advertising implementation within applications, though Apple provided no explanation for the deletion.

Marketing professionals operating within Apple's advertising ecosystem must now consider how these policy changes affect content targeting, user acquisition strategies, and compliance obligations. The age verification requirements could limit addressable audiences for applications featuring user-generated content or AI-powered features that occasionally produce content exceeding stated age ratings. Privacy disclosure requirements create additional friction points in user onboarding flows where explicit consent must be obtained before data sharing occurs.

The updates arrive as Apple continues expanding its own advertising business beyond search placement to include Today tab and "You Might Also Like" sections, creating increased scrutiny around whether platform policies create competitive advantages for Apple's own services. French antitrust regulators fined Apple €150 million in early 2025 over App Tracking Transparency implementation, arguing the consent framework created asymmetrical requirements favoring Apple Ads over third-party advertising networks.

The loan app APR restrictions represent one of the most concrete financial service limitations Apple has implemented through App Store policies. The 36% maximum rate and 60-day minimum repayment period effectively prohibit certain payday lending models from operating through iOS applications, regardless of whether such lending practices remain legal under applicable state or federal regulations. This creates potential conflicts where App Store policies impose stricter standards than governing financial service laws.

Age restriction mechanisms required under sections 1.2.1(a) and 4.7.5 must rely on "verified or declared age" to limit underage user access. The guidelines do not specify technical requirements for age verification systems, leaving developers to implement solutions ranging from simple date-of-birth declarations to third-party identity verification services. Implementation choices could significantly impact conversion rates in user acquisition funnels, particularly for applications targeting younger demographics where parental involvement may be required.

Privacy disclosure obligations under section 5.1.2(i) specifically call out third-party AI as requiring explicit user permission before data sharing occurs. This represents one of the first major platform policies explicitly addressing AI training data collection within the mobile application context. The requirement could affect applications incorporating chatbot features, recommendation engines, or other AI-powered functionality that relies on cloud-based processing of user data.

Crypto exchange classification under highly regulated fields subjects these applications to enhanced review standards and ongoing compliance obligations. Developers operating cryptocurrency trading platforms must now provide documentation demonstrating proper licensing, know-your-customer procedures, and anti-money laundering controls. Marketing materials for these applications face closer scrutiny regarding claims about investment returns, platform security, or regulatory compliance.

The intellectual property protections introduced in section 4.1(c) could affect competitive dynamics in categories where established applications face clone attempts or deliberate brand confusion. Enforcement will likely require trademark holders to actively report violations, as automated detection of brand infringement across icons and application names presents technical challenges given the subjective nature of similarity judgments.

Translations of the updated guidelines will become available on Apple's Developer website within one month of the November 13 announcement, according to the company. This localization timeline means developers operating in non-English markets face a brief period where policy interpretations may vary pending official translated versions of the new requirements.

The policy changes affect applications across iOS, iPadOS, macOS, tvOS, visionOS, and watchOS platforms. Developers must ensure compliance across all supported platforms when submitting new applications or updates to existing software. Cross-platform applications may need to implement different features or restrictions based on the specific capabilities and review requirements of each operating system.

Marketing strategies for applications featuring user-generated content, AI capabilities, or financial services must now account for these additional compliance requirements in messaging, targeting, and user acquisition planning. Age restriction mechanisms may reduce addressable audience sizes for certain categories. Enhanced privacy disclosures could affect conversion rates as users encounter additional permission requests before accessing full application functionality.

App Store Optimization strategies may need adjustment as applications in regulated categories face enhanced review scrutiny that could extend approval timelines. The loan app restrictions completely eliminate certain business models from iOS distribution, forcing affected developers to either restructure lending terms or abandon Apple's platform entirely. Cryptocurrency applications face documentation requirements that smaller exchanges or decentralized finance projects may struggle to provide.

The November 13 update represents Apple's ongoing effort to balance platform openness with content safety, privacy protection, and regulatory compliance obligations. As mobile applications increasingly incorporate AI features, user-generated content, and financial services, platform policies must adapt to address emerging risks while maintaining developer access to distribution channels reaching hundreds of millions of users globally.

Timeline

• April 2021: Apple introduces App Tracking Transparency requiring consent for cross-app tracking
• April 2024: Apple announces updated App Store privacy requirements for third-party SDKs
• June 2024: Apple updates App Store age ratings in Australia and South Korea addressing loot boxes and gambling
• October 2024: Apple Search Ads expands to 21 new countries across Europe, Asia, and Africa
• April 2025: Apple rebrands Search Ads as "Apple Ads" amid expansion plans
• July 2025: Apple updates age ratings system with granular controls expanding to five categories
• November 13, 2025: Apple publishes revised App Review Guidelines introducing age verification, loan restrictions, and AI privacy disclosures

Summary

Who: Apple's App Review team updated policies affecting mobile app developers, marketers, and users across the company's global ecosystem spanning iOS, iPadOS, macOS, tvOS, visionOS, and watchOS platforms.

What: The November 13 revision introduced mandatory age verification for creator apps and mini apps, established 36% maximum APR caps for loan applications, required explicit disclosure of third-party AI data sharing, added crypto exchanges to highly regulated app categories, clarified HTML5 and JavaScript mini app policies, and implemented third-party brand protections in app icons and names.

When: Apple published the updated App Review Guidelines on November 13, 2025, with translations scheduled to become available within one month. The policies take effect immediately for new submissions and updates.

Where: Changes affect Apple's App Store operations globally across 175 storefronts in 44 currencies, with particular impact on developers in regions with existing age rating systems, financial service regulations, and data privacy frameworks like GDPR.

Why: The updates address growing platform concerns around child safety in user-generated content applications, predatory lending practices in mobile financial services, privacy protection amid AI model training data collection, cryptocurrency regulatory compliance, mini app distribution outside standard review processes, and intellectual property protection against brand confusion.