EU Digital Services Act (DSA) trader status on the App Store
Under Articles 30 and 31 of the EU Digital Services Act, every App Store developer must declare in App Store Connect whether they are a trader, and Apple verifies and shows a trader's address, phone number and email on the product page in all 27 EU countries, while non-traders' EU customers are told that consumer-protection rights do not apply.
What does the DSA require on the App Store?
Articles 30 and 31 of the Digital Services Act (DSA) require Apple, as an online marketplace, to verify and display contact information for every trader who distributes apps on the App Store in the European Union. In App Store Connect this becomes one declaration: are you a trader or not?
- Everyone declares. Apple says that "even if you don't distribute apps in the EU, you'll still need to declare a trader status".
- Traders are shown. Once verified, a trader's address, phone number and email appear on the App Store product page in all 27 EU territories.
- Non-traders are labelled. If you are not a trader, EU consumers are informed that consumer rights from consumer-protection law do not apply to contracts between you and them.
- When you are asked. If you have not declared yet, App Store Connect asks the next time you submit a new app.
Are you a trader? A decision tree
Apple cannot decide this for you, and its page says its guidance "does not constitute legal advice". The DSA defines a trader as any natural or legal person "acting ... for purposes relating to his or her trade, business, craft or profession". Apple lists factors from the European Commission's guidance. Use them in order:
- Do you distribute on the App Store in the EU? If not (only outside the EU, only TestFlight, or only alternative distribution), you are not acting as a trader on the App Store.
- Does the app make money? In-app purchases, a paid app or an ad-supported app, especially at volume, point towards trader.
- Do you promote products or services to consumers, including through advertising? That points towards trader.
- Are you registered for VAT? That points towards trader.
- Do you build the app as part of your business or profession? If yes, trader. If you are a hobbyist with no intention to commercialize, you may not be a trader.
- Do you have a legal business status? Apple notes that a legal status associated with a business activity "would suggest you may be a trader", whether you enrolled as an individual or an organization.
If you are unsure, ask a legal adviser before you declare. You can set the account-level status and then turn trader status off or on for specific apps.
What appears on the product page?
| Enrolled as | What you provide | What EU users see |
|---|---|---|
| Individual, trader | Address or P.O. box, phone number, email; payment account details; a document verifying your name and address | Your address (or P.O. box), phone and email |
| Organization, trader | Phone number and email; payment account details; a business document. The address tied to your D-U-N-S Number is used automatically | The D-U-N-S address, phone and email |
| Not a trader | No contact details | A notice that consumer-protection rights do not apply |
Traders also certify that they only offer products or services that comply with EU law. If you show a P.O. box or another alternate address, you must upload a document that shows your connection to it, such as a receipt or a bill. The display details are for the App Store only and do not change your Apple Developer Program membership record.
How do you declare trader status? Step by step
Required role: Account Holder or Admin.
- In App Store Connect, select Business at the top of the page.
- On the Agreements tab, scroll to the Compliance section.
- Next to Digital Services Act, click Complete Compliance Requirements.
- Choose "This is a trader account" or "This is not a trader account". Non-traders click Done here.
- Traders enter or confirm the contact information and click Next.
- Verify the email address with two-factor authentication.
- Verify the phone number with two-factor authentication. If the number cannot receive codes, you can request manual verification.
- Upload a current document that verifies your business name and address (business or legal records), plus proof for any alternate address.
- Review the details and click Confirm.
How do you change the status for one app?
In Apps, select the app, click App Information in the sidebar, scroll to App Store Regulations and Permits, and under Digital Services Act click Edit. If you declare an app as a trader app for the first time, you enter and verify the contact details that will show on that app's page.
What is the Labels and Markings URL?
Under the same section you can optionally add a Labels and Markings URL for labels or markings required by EU law. It is shown on the product pages of apps for which you are a trader, and you can edit it at any time.
What are the common mistakes?
- Assuming "individual" means "not a trader". The test is what you do, not how you enrolled. A solo developer who sells subscriptions may well be a trader.
- Using a phone number that cannot receive 2FA codes and getting stuck at step 7. Request manual verification instead.
- Forgetting that the details are public in the EU. If you do not want your home address shown, consider a P.O. box with the supporting document.
- Mixing it up with the support URL. Guideline 1.5 separately requires an easy way to contact you through the app and its support URL. The DSA details do not replace it.
- Leaving the declaration to the last minute before an EU launch. Verification steps take time.
How does this fit with App Review?
The DSA declaration is a compliance step, not an App Review Guideline, but it can block a new app submission until you complete it. For guideline rejections, see App Store rejection reasons and fixes; for disagreements with App Review, see replying to App Review and appealing.
Where does Uptika fit?
Uptika does not file compliance information for you; that stays in App Store Connect. What it does is watch your listing in each storefront you track: Kelime radarı (keyword radar) reads your positions in each EU country every day, and if your app stops appearing in a storefront's search results, the drop shows in the next morning's Günlük ping (daily brief). For the rest of the launch list, see the ASO checklist, or start free.
Questions
What is DSA trader status in App Store Connect?
It is your declaration, required by the EU Digital Services Act, of whether you act as a trader (for purposes of your trade, business, craft or profession) when you distribute apps on the App Store in the EU. If you are a trader, Apple verifies your contact details and shows them on your product pages in the EU.
Do I have to declare if I don't sell in the EU?
Yes. Apple says that even if you don't distribute apps in the EU, you still need to declare a trader status. If you only distribute outside the EU, through TestFlight or through alternative distribution, you are not acting as a trader on the App Store, and you can declare yourself a non-trader.
What happens if I don't declare trader status?
App Store Connect asks for the declaration the next time you submit a new app, so you cannot complete that submission without it. Apple's current help page does not publish a separate removal date; declare it before your next submission to avoid delays.
Is my address shown on the App Store?
Only if you declare yourself a trader, and only on your product pages in the EU. Individuals enter an address or a P.O. box (with a document that links them to it), a phone number and an email. For organizations, the address tied to the D-U-N-S Number is shown automatically, plus the phone and email you enter.
Does my app need an Impressum or legal notice on the App Store?
The DSA trader details Apple shows on the product page are Apple's way of meeting its own DSA duties as a marketplace. Whether your app or website also needs a separate legal notice under national law is a legal question for your adviser; Apple's page states that its material is not legal advice.