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Understanding and Implementing Digital Services Act (DSA) Compliance in the Apple Developer Program
The digital landscape is undergoing a important transformation, particularly within the European Union (EU). A key driver of this change is the Digital Services Act (DSA), a landmark regulation designed to create a safer and more accountable online habitat. As of late 2024 and continuing into 2025,developers distributing applications thru the Apple App Store are now required to actively demonstrate compliance with these new rules. This article provides a comprehensive guide to understanding the DSA’s implications for the Apple Developer Program,detailing the necessary steps for DSA compliance,and offering practical advice for a smooth transition.We’ll explore how Account Holders and Admins can accurately report their trader status within App Store Connect, ensuring continued access to the EU market.
What is the Digital Services Act and Why Does it Matter?
Enacted in February 2024 and progressively enforced throughout the year, the DSA aims to regulate online platforms and services, addressing issues like illegal content, disinformation, and clarity. It establishes a tiered system of obligations based on the size and reach of the platform.For app developers, the DSA primarily focuses on identifying and reporting their status as a ‘trader’ – essentially, anyone offering goods or services through their app.This isn’t merely a bureaucratic exercise; failing to comply can result in substantial fines – up to 6% of global annual turnover, according to the DSA itself – and potential removal from the App Store within the EU. Recent reports from Digital Commerce 360 (Digital Commerce 360, March 21, 2024) highlight the increasing scrutiny on businesses operating within the EU digital space.
Understanding ‘Trader’ Status: A Detailed Breakdown
determining whether you qualify as a ‘trader’ under the DSA isn’t always straightforward. The EU defines a trader as anyone offering goods or services to consumers. This encompasses a broad range of scenarios, including in-app purchases, subscriptions, and even apps that facilitate transactions between users. For example, a mobile game offering virtual items for purchase clearly falls under this definition. However, a free utility app with no commercial elements might not. the key consideration is whether yoru app generates revenue directly or indirectly through commercial activities. As of November 26, 2025, the European commission is expected to release further clarifying guidelines on nuanced cases, particularly regarding apps that integrate with third-party marketplaces.
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