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ABOUT THE COMMUNICATION
In March 2024, Apple sent all app developers a communication alerting app owners about a new requirement aligning with the Digital Services Act (DSA) in the European Union (EU).
^ Sample of email, subject line:
Please enter your trader status in App Store Connect.
Apple is requiring all app developers (that's you!) to confirm if you are a "trader" or not.
According to the DSA, a "trader" is defined as:
“any natural person, or any legal person irrespective of whether privately or publicly owned, who is acting, including through any person acting in his or her name or on his or her behalf, for purposes relating to his or her trade, business, craft or profession.” If you have questions about your status as a trader, consult with your legal advisor.
Apple provides the following Trader vs Non-Trader Information on their developer website:
Trader versus non-trader
The European Commission defines traders and non-traders as follows:
Trader
Any natural person or any legal person, who is acting for purposes relating to his trade, business, craft or profession in relation to contracts on this marketplace.
Non-trader
Any natural person or any legal person, who is acting for purposes which are outside of his trade, business, craft or profession in relation to contracts on this marketplace.
Read more here.
HOW TO ACCESS AND CONFIRM YOUR INFORMATION
1. Log in to your Apple developer account: https://appstoreconnect.apple.com/
2. The alert will be at the top of your screen:
3. Click on Complete Compliance Requirements. You will be taken to the next Screen:
4. Click on Complete Compliance Requirements for [your name]. You will be taken to the next Screen:
5. Click on Complete Compliance Requirements again. You will be taken to the next Screen:
6. Select if your account is a Trader Provider Account or a Non-Trader Provider Account.
TRADER PROVIDER ACCOUNTS
If you confirm that you are a trader provider account:
Organizations/Businesses:
Your DUNS number will be displayed
You will need to provide a phone number and email address
Individuals:
You will need to provide an address, phone number and email address
This information will be publicly displayed on your app store listing pages.
Read more here.
OUR ACTIONS
In order to expedite your app submission and review, our current policy is to submit all NEW apps on your account as Non-Trader Provider.
We are not taking any actions for existing, launched apps.
We are providing this article to assist and inform you about your responsibility as an app owner. From time to time, you must sign in and accept new policies, agree to regulations, and read through new information. We do our best to inform and educate as these needs arise, however ultimately, it is an app owner's responsibility to remain compliant and informed as developer information and requirements change.
YOUR RESPONSIBILITY
As an app owner, you are also an app developer. Ultimately, it is your decision to identify as a "trader" or not. It is up to you to go into your account and confirm if you are a trader or not.
We recommend that you do so truthfully, as there may be legalities around this. Please consult with a legal professional as we cannot provide you with legal advice here.
ADDITIONAL INFORMATION
At this time, our understanding of the enforcement and consequences around this requirement are minimal.
One potential outcome may include limiting your app's availability in app stores in the following countries: Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden.
What ACTIONERA is Doing For Our Apps:
We are selecting "non-trader" for our own app accounts at this time. This may change in the future as more information becomes available to us.
If you have any concerns or questions, we highly recommend that you contact apple directly for more information, or consult with a legal professional regarding your "trader" status.