Navigating teh Digital Services Act: Apple App Store Trader Requirements in the EU
The landscape of app distribution within the European Union is undergoing a meaningful shift. beginning February 17, 2025, a new regulation stemming from the European union’s Digital Services Act (DSA) will necessitate all app developers selling within the EU to establish and verify their “trader status” within the Apple App Store. This isn’t merely a procedural update; it’s a basic change impacting how applications are offered and regulated, demanding immediate attention from developers and account holders. as of August 27, 2025, understanding these requirements is crucial for maintaining app availability and avoiding disruption to your user base. This article provides a comprehensive guide to the DSA’s implications for Apple app store developers, offering practical steps and insights to ensure compliance.
Understanding the Digital Services Act and it’s Impact on App Distribution
The DSA, enacted in late 2022 and coming into full force throughout 2024 and 2025, represents a landmark effort by the EU to regulate online platforms. Its core objective is to establish a more obvious and accountable digital environment, particularly concerning illegal content and harmful activities.A key component of the DSA is the differentiation between “intermediary services” and “hosting services.” Apps offered for sale are categorized as falling under stricter regulations, requiring developers to clearly identify themselves as traders.Recent data from the European Commission indicates that approximately 75% of EU citizens use smartphones daily, making app distribution a critical area for regulation. This regulation isn’t limited to large corporations; it applies to all developers, regardless of size, offering apps within the EU. Failure to comply could result in app removal from the App Store, impacting revenue and user access.Think of it like needing a business license to sell goods in a physical store – the DSA requires a digital equivalent for app distribution.
What Constitutes “Trader Status” in the Apple App Store?
apple, in alignment with the DSA, requires Account Holders or Admins within the Apple Developer Program to explicitly declare their trader status within App Store Connect. But what does “trader” actually mean? According to Apple’s guidelines (link to Apple’s documentation), a trader is any individual or entity offering goods or services through the App Store. This encompasses a broad range of scenarios, including:
Direct Sales: Apps that directly sell digital products or subscriptions (e.g., streaming services, in-app purchases).
facilitating Transactions: Apps that enable transactions between users (e.g., marketplaces, ride-sharing apps).
Lead Generation: Apps that collect user data for commercial purposes or generate leads for businesses.
Promotional Activities: Apps used primarily for advertising or promoting other businesses.
Essentially, if your app has a financial component or is used for commercial gain, you are likely considered a trader under the DSA. The legal definition, as interpreted by the EU, is intentionally broad to ensure comprehensive coverage.
Step-by-Step Guide to Declaring Trader Status in App Store Connect
Complying with the DSA requires a proactive approach. Here’s a detailed guide to declaring your trader status in App Store Connect:
- Access App Store Connect: Log in to your Apple Developer account and navigate to App Store Connect (








