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For app developers looking to distribute their applications on Apple’s App Store, ensuring compliance with local and international regulations is crucial. In some cases, Apple may require a legal opinion to confirm that an app complies with relevant laws, particularly when operating in regulated industries (the App Store legal requirements). Understanding when and why you need such an opinion can help streamline the approval process and prevent unnecessary delays.

Why would Apple require a legal opinion?

Apple enforces strict guidelines on app distribution, particularly for applications operating in regulated industries such as cryptocurrency, fintech, healthcare, and AI-powered services. According to the App Review Guidelines, all apps must comply with applicable laws in every region where they are available.

Apple may request a legal opinion in the following scenarios…

  1. Jurisdictional licensing requirements: If an app provides services that require a government-issued licence (e.g., financial transactions, medical consultations, or online gaming), Apple may ask for proof of compliance. For instance, cryptocurrency exchange apps must demonstrate that they are legally authorised to operate in specific jurisdictions.
  2. Unclear regulatory landscape: Some regions have evolving or ambiguous regulations regarding digital services. When there is no clear licensing requirement, Apple may request a legal opinion confirming that the app can legally operate in those jurisdictions. Example: A cryptocurrency app operating in India—where the country requires no formal licence—may still need a legal opinion to satisfy Apple’s compliance checks.
  3. Content and intellectual property restrictions: If an app includes licensed content, APIs, or third-party integrations, Apple may require confirmation that the app is not violating territorial licensing agreements. This is common in media streaming, gaming, and SaaS platforms where usage rights vary by region.
  4. Distribution in high-risk or restricted markets: Apple may require additional scrutiny for apps launching in China, Russia, India, the EU, or the Middle East, as these regions often have strict data protection, financial, or content regulations. Certain jurisdictions require local partnerships or data localisation measures before an app can be legally distributed.
  5. Shifting legal responsibility to the developer: By requesting a formal legal opinion, Apple minimises its own risk of liability in case of regulatory violations. Instead,  it places the burden the developer to ensure full compliance.

Insights from Apple developer forums: Legal opinion requests in action

Discussions on the Apple developer forums reveal that developers of apps related to cryptocurrency, financial transactions, and media distribution have frequently encountered requests for legal opinions.

  • In one case, Apple rejected a cryptocurrency exchange targeting the Indian market owing to licensing concerns. Even though no formal licence was required in India, Apple insisted on a legal opinion confirming compliance.
  • Other developers noted that even after providing a legal opinion, Apple sometimes still requests a business licence or further clarifications. This underscores the importance of submitting a well-structured legal opinion that aligns with Apple’s expectations.

How ITLawCo can help

If your app is expanding into multiple regions and you need confirmation of licensing and regulatory compliance, ITLawCo can assist with:

  • Reviewing existing licences and partner agreements to determine covered territories.
  • Identifying regions where you don’t need licensing and confirming compliance.
  • Preparing a well-reasoned legal opinion that meets App Store submission requirements.
  • Providing strategic advice on regulatory risks and expansion planning.

Final thoughts

Whether Apple has explicitly requested a legal opinion or you are proactively ensuring a smooth approval process, a well-prepared legal opinion can make the difference between swift approval and prolonged delays. At ITLawCo, we specialise in tech, AI, and digital platform compliance, ensuring that your app is not just legally sound but also market-ready.

Need expert guidance? Contact us today to discuss how we can help secure your app’s distribution across global markets.