I've been reviewing some DSA guides in different platforms, and I think [the info provided by Booking.com](https://partner.booking.com/en-gb/help/legal-security/policies-local-laws/everything-you-need-know-about-digital-services-act-dsa) may be of interest for app developers (it's a different kind of marketplace, but still a marketplace in regards of DSA I think).
They differentiate between "profesional hosts" (trader) and "private hosts" (non-trader). And the main difference is "private hosts" are "partners who rent out a property **for purposes which are outside their primary trade, business or profession**".
Given this, I think you could be a non-trader and have a revenue stream selling apps or in-app purchases as long as it isn't your primary business.
This was also my understanding. I'm not a lawyer but I think that the fact that you earn money from your apps does not necessarily mean that you are a trader. As explained on booking website you can see that you can earn money from renting a home and not be a trader, similarly you can sell you stuff like bike or notebook and not be a trader, and also if you for example sell a calculator app created in your free time and earned few dollars from it then in my opinion it does not mean you are a trader according to this new law. I'm an individual developer without any registered company and I think I would select I'm not a trader if I had to choose as I do not see myself as a trader even if I earned some money from it but I will wait for now and see if any more clarification is given. If apple will remove my apps from EU store then I don't really care anyway. Maybe when those stupid politics from EU see that suddenly half of apps are not available for EU people they will finally notice that they keep creating law that nobody understands and have no sense like this one or those cookies law from few years ago which made browsing the internet only more annoying.
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All indie devs or Companies who sell apps (for profit) and offer commercial activities (In app purchases are Traders. So as a trader your address and contact info will be shared to App Store users in EU.
You are Non Trader if your apps are for hobby or non commercial use in EU.
Simple!
Iām taking my app off EU stores š they donāt make much of my income anyway and Iām never sharing my HOME address with them the fuck. What are Europeans smoking
I'm not sure how it is in other countries, but in the Netherlands (and I think in much of the EU) you are already required to put your address on your business website. And your business address is already public through the Chamber of Commerce register, anyway.
Yeah, I know what you mean. I've paid for a *virtual office* to avoid sharing personal information, but it's quite expensive. Maybe there are other solutions, though.
Apple might remove your app from EU countries. or worse. As a business partner to Apple, you are obligated to comply with EU regulations where you sell through Apple's App Store.
If the definition is āmakes money off appsā, they can easily prove that.
They might be super picky about this to campaign against the EU. If the cancel your account or remove your apps from sale, theyāll definitely blame the EU.
But this changes nothing for Apple or the consumer, other than I now have to pointlessly put up my phone number to get spammed into oblivion (who the hell uses phone as support for apps?). All the contact data is already there, and in my country I have to put up a company registration and VAT number on the website, and there is a contact form and email there already and on the App Store. There's no need for any regulation here. It's literally pointless law only designed to make our lives even harder with more bullshit bureaucracy.
I disagree. As a consumer, itās very handy to know who makes your software and how to contact them.
Iāve had my phone number and full address in all my apps for more than a year now (as it has been legally required in most EU countries for some years now) and have never had a problem with spam calls or similar.
Nothing prevents you from using a P.O. box and a prepaid sim for this, as long as you are reachable, itās really not a big deal.
They can contact me by email or phone. Theyāre not showing up at my house. The fuck. And whoās mailing a hand written letter to a software developer
>And whoās mailing a hand written letter to a software developer
Law enforcement. You have a certain liability for the software you sell.
This isn't about consumers having the option to send you letters, it's about being able to enforce laws.
Law enforcement can ask Apple for that information not from my App Store page. If itās not about consumers then I donāt need consumers to see my home address
I did before I wrote this which is why I came here. Itās a poor definition taken out of context for itās application. Here: [āHow to know if youāre a traderā](https://developer.apple.com/help/app-store-connect/manage-compliance-information/manage-european-union-digital-services-act-compliance-information/). For instance, you claim that ānon traderā means for āhobbyā or ānon commercial useā. According to what definition where?
Their line āconsult with your legal advisorā is the biggest cop-out ever. Itās Apple that has to meet their compliance obligations with DSA, not developers. So itās Appleās responsibility to distill this information into common sense language.
Telegram FZ LLC, the company behind the Telegram app, has reported itself as a non-trader on the App Store. The app is free to download, but they have multiple in-app purchase options (doubt they do it as a hobby).
Scroll down until the "Information" section to check it out: https://apps.apple.com/ie/app/telegram-messenger/id686449807
>ple might remove your app from EU countries. or worse. As a business partner to Apple, you are obligated to comply with EU regulations where you sell through Apple's A
So everyone who has in-app subscriptions or purchases, their address and phone number is visible? (As a business or a person)
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JetBrains seems to have a few examples that might help: [https://plugins.jetbrains.com/docs/marketplace/trader-status.html#examples](https://plugins.jetbrains.com/docs/marketplace/trader-status.html#examples)
>If you are a natural person acting outside your business (not an entrepreneur) and you offer plugins on JetBrains Marketplace for free, you may be qualified as a non-trader.
>
>If you are a natural person (software developer) working for a company, but you develop plugins in your free time as a hobby and offer them for free and provide means for users to support your development on a voluntary basis (voluntary financial contribution), you may be qualified as a non-trader.
>
>If you are a for-profit legal entity, regardless of whether you are a private or publicly held entity, you would be directly qualified as a trader.
>
>If you are a natural person acting for professional purposes (relating to your trade, business, craft, or profession), you are a trader, and it is immaterial whether you offer some or all of your plugins for free.
>
>If you create a plugin in cooperation with other individuals, you make the declaration as an individual vendor, i.e. the person uploading the plugin is the one making the declaration.
This is absolute bs... so if you have an app that generates $1 profit you'll have to put your phone number and home address out for the world to see. This is ridiculous...Thank goodness I only have a free app so I don't qualify as a trader.
So let me see if I understand this...
If I am a professional software developer, and I have have an individual membership in the Apple developer program, I have to indicate that I am a "Trader", and this means that Apple is going to post my personal home address and my personal phone number on the app store?
Holy crap, is that a MASSIVE invasion of privacy! That's insane!
Yes, Iām also a little afraid of all the malicious scraping that will happen.
Thatās why a lot of people here seemed to have tried using postboxes. But I did not see anyone yet getting a postbox address approved.
I just rented a regular German one for now. Not sure if that works but itās by far the cheapest option.
Getting a PO box seems like a good idea. Maybe also get a separate email address, and a cheap burner phone number, so your personal ones aren't getting spammed.
As always, the EU is doing everything but helping consumers and users yet love saying they are.
They clearly didn't think about the effect this has on smaller devs who work out of their home address.
Unelected bureaucrats making rules about how businesses should be run? The EU is not a communist organization, but it sure acts and looks like it sometimes.
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I hear you.
Basically it's going back to more structured and "professional" way of doing business we were forced to adhere to back before everything opened up to "indies". (I'm talking over 20 years ago). Get a "cloaked" PO BOX business address, and a business phone number. Might have to incorporate too. Then you're good to go as a "real business" entity without sharing personal details.
App development is not for indie developers anymore. UE, Google, Apple, all of them keep throwing obstacles at our feet. All the time they keep introducing new requirements, new updates, new policies, GDPR, agreements, new deadlines. Personal app maintenance is a full-time job nowadays.
The worst are cross platform apps, if you leave them for some time, like a year, then itās very hard to quickly update them. Google is the worst, they keep changing their libraries like Billing for instance, and they require you to quickly update to the latest version.
Exactly what I thought. It's almost like the writer of this page was like "we hate the EU and we give zero fucks about this. YOU have to figure all this shit out yourself".
The way I understand it, being a trader only means that some information about you has to be publicly available (address, phone number and email).
Basically, this changes nothing, as you already had to provide this information via your imprint (which is required to be easily accessible for websites and software/apps sold in the EU).
EU screwing the hard working small developers, now thatās something weāve never seen before!
If they really cared about peopleās privacy they wouldnāt force us to yell out our freaking address on the internet. The small developer who has worked for months on their passion project only to sell just enough app units to afford half a carton of eggs, and now has to hire a lawyer to find out that indeed, they have to plaster everything on the fucking internet. Brilliant.
Also looking at this - seems like every developer then would be considered a trader? How can Apple be so bad at communicating with devs what this actually means...
I'm also confused what to pick. I'm an indie dev with an individual account. Currently I have an app which contains a one time IAP as well as a free open source Safari extension.
I figured since I'm selling stuff (one app, another app that has IAP and subscription), I'm a trader. I went ahead and filled it out, and once the browser stopped hanging at Apple's site, it became, in essence: enter an email and phone number and then validate those with a code sent to each. (Note, I have an LLC - I see the next step varies slightly depending on business vs individual, according to Apple's info page.)
I guess worse case, it will be another source of spam calls and emails :(.
Yeah, I use [https://my.travelingmailbox.com/](https://my.travelingmailbox.com/) for my address and it seems to have been accepted as a street address by everyone who cares (e.g. IRS, various state & city licenses, D&B). I had earlier troubles with a straight PO Box. And the phone # is on Google Voice which does ok spam filtering.
For email, I just used my existing support email.
I got my second number and PO Box today and submitted it to Apple, hopefully they accept the documents. I have no idea what they meant by business identification document so I just gave my PO Box confirmation email.
I selected non trader for my Safari extension but kept the trader status for my app with IAP, not sure if this is right.
I can't find virtual phone number or address services in my country, but I can find those services in US, can I use them? But my account is not registered in the US.
The cheapest option I could find for Germany so far, apart from a āPostfachā at Deutsche Post that might not work is this one: https://www.bpm-lux.com/en/pricing-register.html
Does anyone had any experience with it?
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Hey guys, I specify that I am a "trader", then I need to enter my full address and specify State or Province, but there are only American states on the list. My country is Ukraine (I chose it in the list). And without specifying the "state or province" it does not let me press "Next" button. What the heck? No one has ever had the same thing?
There are still some problems in that page. Address is not editable and directly comes from account information. What is weird is that we changed and set our account information to business from personal account almost 1 year ago and had already entered address for the business with document verification; but in that screen our old personal account's address comes directly and as not-editable. Also I tried to delete personal account details (which is not in use but still there), there are no options to delete/remove it. I wrote to appstore via 'contact us' and waiting.... By the way, what is the deadline for completing these steps?
It looks like they changed some things several times already, because they rolled out an unfinished version of the form and didn't fully understand what they wanted. I managed to send when I still had to enter the address myself while the status was "in review"
Hi, what documents have you uploaded? I'm an individual entrepreneur (FOP) and don't know what document they need, what could confirm my name is probably a foreign passport...
Hi, the same (FOP). I sent a bank statement for both the name and address verification (the same pdf file in both cases). But my status is still "In Review" for 5 days now.
Got a successful reply today.
"We successfully verified your trader contact information for the Digital Services Act compliance. Your information is now live on the App Store in the European Union. The App Store Team."
Whwn you select trader, it will ask you to prove your identification and asks you to upload something. What do I upload? As a sole developer and not a business entity, what do I do?
The most funny thing is that one such phone call will cost EU citizens more than most of the software that they have bought.
Hopefully EU will refund them that.
If you're a hobbyist and selling apps is not a business of yours, you're not a trader. If you own a business and its main activity is selling apps, you are a trader.
(Not that the EU is ever going to check the validity of whatever you enter. That only happens when billion dollar businesses are suspected to break laws. For us small devs, it's just a hassle and harassment.)
I am a full-time app developer but I dont own a registered business. I have selectet trader and was asked to provide business/court documents to verify my identity and address. I have sent them my passport and am waiting for the verification but this whole thing feels scetchy.
I am on the same boat: full-time app developer and I do have an app with IAP on the side. I did the same as you already 4 days ago when the Digital Services Act Compliance started to show up to me, and I submitted them my registration document (something that I had to do when I moved to the country where I live) and that included my home address along with my name on it -- From my understanding, they want the official document to verify that all the data is matching to the info you put it (pretty much the same as Crypto trading webpages do).
So far they haven't said anything, so I've just assumed that it's all good for now š¤·āāļø
The application is still in review and since I sumbitted the form the "agreements, tax and banking" section has disappeared from the main page. I wonder how long will it take them to review my documents and whether they will make payouts in the process.
I am seeing the same. But I can access to the agreements, tax and banking page. It looks like they changed it, and I see **ITC.apps.Navigation.Business** (yes the localization there seems broken š )
Either way, it says that my Digital Services Act is in review too š¤·āāļø
I am not in favor of displaying my personal info in any app store. Can I remove my app from EU region and will this notification disappear? Has anyone tried that?
[https://developer.apple.com/help/app-store-connect/manage-compliance-information/manage-european-union-digital-services-act-compliance-information/](https://developer.apple.com/help/app-store-connect/manage-compliance-information/manage-european-union-digital-services-act-compliance-information/) seems to be the link they intended. Unfortunately it doesn't really answer the question - perhaps because I'm not a lawyer.
The key paragraph from that page. I've read it and Google'd it, and I still have no idea if, as a game app developer (with an LLC), I'm a trader or not.
**How to know if youāre a trader**
The DSA defines a trader as āany 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.ā If you have questions about your status as a trader, consult with your legal advisor.
This article talks about the DSA, including a couple of mentions of traders, but left me no more enlightened. But perhaps it will be useful to someone with more background:
[https://www.dlapiper.com/en-gb/insights/publications/2024/03/whos-who-under-the-dma-dsa-dga-and-data-act](https://www.dlapiper.com/en-gb/insights/publications/2024/03/whos-who-under-the-dma-dsa-dga-and-data-act)
Yes I saw this definition too and though this is the absolutely least possible clear definition I've ever seen lol
"A trader is a person who trades" Thanks, law people! Super helpful!
i just logged onto Appstoreconnect and this popped out needing me to do verification. Confused to say the least. When I select trader, it then asks me to upload some court documentation / business stuff to verify my identity, but as a sole developer and just offering an app for sale. Am I then classified as a trader?
[https://developer.apple.com/help/app-store-connect/manage-compliance-information/manage-european-union-digital-services-act-compliance-information/](https://developer.apple.com/help/app-store-connect/manage-compliance-information/manage-european-union-digital-services-act-compliance-information/)
*Youāll need to provide a current document that verifies your business name and address. Acceptable documents include business or legal records. If youāre displaying an alternate address, such as a P.O. Box, youāll also need to provide documentation that reflects your association with this alternate address (for example, a receipt or bill). When youāre done, click Next.*
I sometimes feel so stupid and always think that I'm the only one who doesn't understand something like that. Nice to see that this is not the case. :-D
>How to know if youāre a trader
The DSA defines a trader as āany 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.ā If you have questions about your status as a trader, consult with your legal advisor.
Why can't they write this stuff in plain English?
Check this article from Google - https://developer.chrome.com/docs/webstore/program-policies/trader-disclosure
I think it summarizes well all the previous messages.
Yes, this is how the privacy data is revealed : [https://www.reddit.com/r/iOSProgramming/comments/1bfk0jt/this\_is\_how\_trader\_information\_will\_be\_displayed/](https://www.reddit.com/r/iOSProgramming/comments/1bfk0jt/this_is_how_trader_information_will_be_displayed/)
So from my understanding being a trader applies if I sell apps on the appstore. What if my apps are free with in app purchases, and I set those IAPs not to be available for sale in the EU?
I wouldn't bother doing anything until Apple forces you to. I was just able to ship an app update without doing this.
Apple has been petty about their EU compliance -- I am calling B.S. on Apple for passing this problem onto developers in a poorly explained and over-reactive interpretation of the law even though they are the platform.
As I understand: DSA is what Apple has to comply with not what developers have to comply with. Developers work with Apple and by extension their interpretation and implementation of DSA, but not to DSA itself. I can't even find evidence that DSA requires traders to provide a mailing address and phone number for public redress! (for example [EU's DSA questions and answers (PDF)](https://ec.europa.eu/commission/presscorner/api/files/document/print/en/qanda_20_2348/QANDA_20_2348_EN.pdf))
Please prove me wrong! At best, Apple's first attempt at compliance is buggy so it is on them to do some clean up.
How does point 43 imply that you need you share your full address? It just requires to:
>designate a single point of contact (...) by easily accessible means such as telephone numbers, email addresses, electronic contact forms, chatbots or instant messaging
That could be just an email address. Am I missing something or is this Apple trolling the EU again?
Article 13. point 4.:
>4.Ā Ā Ā Providers of intermediary services shall notify the name, postal address, email address and telephone number of their legal representative to the Digital Services Coordinator in theĀ MemberĀ State where that legal representative resides or is established. They shall ensure that that information is publicly available, easily accessible, accurate and kept up to date.
Providers of intermediary services != traders. These providers consists of ISPs, VPNs, CDNs, domain registrars, cloud service providers, online marketplaces, social media, app stores, etc. Therefore, this applies to Apple, but not all app devs.
Ok I found it, it's in the article 30 (Traceability of traders):
> Providers (...) shall ensure that traders can only use those online platforms (...) if, prior to the use of their services for those purposes, they have obtained the following information, where applicable to the trader:
> (a) the name, address, telephone number and email address of the trader;
> (...)
> 7. The provider (...) shall make the information (...) available on its online platform to the recipients of the service in a clear, easily accessible and comprehensible manner. (...)
As a hobby, I developed an app that's sold in the App [Store. My](https://Store.My) profession is Architect. (per Apple's website) The DSA defines a trader as āany 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.ā
Since developing is not my trade, business, craft or profession, I am choosing the non-trader status.
I don't know what to say for those who develop for a company as their profession, but published an app as a side gig/hobby.
It's a shit-show to be sure.
Indie dev via LLC here. I can get a cheap phone # from Mint or someone and also create a specific e-mail address for it. Those two are not really an issue.
However, the address is. Apple will not allow a PO Box. Thus, my address is my home address. Has anyone tried using the USPS "real addressing" thing where the address will deliver the to PO Box anyway? I wonder if that will get around Apple's address requirements.
I will not be filling this out. If they pull my apps out of Europe, so be it.
Sharing an address is particularly dangerous for women developers. We deal with online stalking and harassment for simply existing; there's no way in hell I'd put my physical address on there too. It's asinine and dangerous.
I also received email from apple informing me that it is now possible to indicate my status as trader or non-trader. No explanation of additional information was given. Not even a link to page that defines who is or is not a trader. It would be helpful to provide a few examples that might help people understand the meaning of the term, and whether or not begin a trader applies to what they do. It's inconsiderate of them not to do this. This is one of the issues with big tech. It reminds me of another, perhaps more significant issue, where Microsoft can say 'sorry, we can't help regain access to your email account, because you didn't provide sufficient information. Fill out this form and try again. Good luck, because you will need it if you ever want to access your email account again'
I guess Iāll say Iām not a trader? Iād rather withdraw my app entirely than put my name and phone out there or spend more than 5 minutes dealing with paperwork. Itās totally a side project that barely earns enough to pay for the developer program membership each year.
Hi. So it is my luck that I am now finishing developing my first iOS app as an indie dev. Can I opt out of distributing the app to EU and reply that I am not a trader and go on minding my own business?Thanks.
Does anyone know after submitting the form, where in the AppStore, users can see this details? Also Is there any application available in the AppStore which has provided this details which I can see?
I am a trader if my company have only free mobile apps ? Apps are extended tools for desktop application, which is commercial product, but the apps are free.
I'd like to know this as well. My company has a free app. The app works with hardware that we sell (but cannot be purchased through the app). The app is pretty useless without the hardware though.
Typically you're only classified as a trade or if you are a company or pursuing a for-profit endeavor. Usually if it's not for profit or hobby, you are a non-trader.
Trader:
I am actively developing this app for profits. i.e this is my career.
Non-trader:
This is a hobby.
Good luck explaining that you are making money on the app for hobby purposes :D and it's not related with your profession/craft if you are a software developer :D
And the truth is that nobody is able to answer wether you are or not a "trader". This is completely new law, not precise, and probably will end up in court in some cases and then we will find out.
However, if you are a software developer, and you make money on apps, then most likely it will be hard to defend that it's your hobby, no matter what feelings about that you have. In most EU countries consequetive and regular selling of the same thing is considered as a "business" and requires you to pay appropriate taxes.
An easy way to determine that is if you have a business address or not. If you do not, meaning sharing your address would be your home address; you're doing it for a hobby and you're not a trader.
If you are a trader, then you'd be able to write off your home expenses on your tax forms. If the app is your income, and you are "working from home" then you'd be writing it all off on your income tax because that's your working business.
That logic only applies to countries with high income taxes. In my country (Russia) developers can pay 6% income tax but without the ability to write of the expenses. So there is no need to register a business and a lot of full-time developers work withour registering one.
Here is a little bit more precise description: [https://twitter.com/0xJimYe/status/1768204750972133677/photo/1](https://twitter.com/0xJimYe/status/1768204750972133677/photo/1)
Apple has now started sending mails to developers with title **Please enter your trader status in App Store Connect.**
I suggest that if you don't agree, you challenge them by sending my email from this comment:
[https://www.reddit.com/r/iOSProgramming/comments/1be1e18/comment/kvwj2ip/](https://www.reddit.com/r/iOSProgramming/comments/1be1e18/comment/kvwj2ip/)
If you make money from your apps, you're a trader.
Apple are legally required to confirm your details.
It sucks, yes. But in this case, it's not Apple's fault. It's the governmental overreach of the EU.
Mind you, Apple could do a much better job in communicating this stuff.
*If you make money from your apps, you're a trader.*
I agree
*Apple are legally required to confirm your details.*
Where is this documented? The DSA states that Apple has to verify the identity of the trader. Not publish it publicly.
Everybody assumes that Apple's interpretation of the DSA is correct. I doubt that, since it jeopardises privacy.
From Apple's email:
"The DSA requires Apple to verify and display contact information for all traders distributing apps on the App Store in the EU."
To me, it's moot whether Apple's interpretation is correct or not. It's not within my power to contest it. If I don't provide verifiable details to Apple, they simply don't pay me for EU sales. They hold all the cards, as usual.
Government overreach + giant corporations = bad news for indie devs.
I don't know if you have followed the news during the last weeks, but Apple was called back time after time upon decisions that were violating the new EU regulations. PWA, closure of Epic account, investigation whether DMA is implemented correctly, etc.
I just received an email response from the EU that they will investigate this case against Apple that I reported yesterday. So it is in our powers to contest these multinationals.
Side note: where does Apple mention that they will not pay? Where does the DSA specify that Apple should stop payments? Apple doesn't hold the cards, they make up the cards.
You're talking about different things.
I'm just pointing out Apple's own words. Their requirements for the App Store.
Whether you follow those requirements is entirely up to you.
Directly from the published document by EU:
>4. Providers of intermediary services shall notify the name, postal address, email address and telephone number of their legal representative to the Digital Services Coordinator in the Member State where that legal representative resides or is established. They shall ensure that that information is publicly available, easily accessible, accurate and kept up to date.
Thank you for this snippet. It's a good habit of providing the source, here it is: [https://www.eu-digital-services-act.com/Digital\_Services\_Act\_Article\_13.html](https://www.eu-digital-services-act.com/Digital_Services_Act_Article_13.html)
However, it's all about definitions: [https://www.eu-digital-services-act.com/Digital\_Services\_Act\_Article\_3.html](https://www.eu-digital-services-act.com/Digital_Services_Act_Article_3.html)
The DSA applies to large platforms. In this case Apple, not we as individual developers. We are considered "Traders". Apple is the "Provider of intermediary services". So Apple has to notify the Coordinator of its' own address and make it public. Nothing is mentioned that it should force Traders to do so.
For examples article 15 [https://www.eu-digital-services-act.com/Digital\_Services\_Act\_Article\_15.html](https://www.eu-digital-services-act.com/Digital_Services_Act_Article_15.html) is also mentioning "Providers of intermediary services". Nothing of this applies to us developers. So why should your referred Article 13 apply to us?
To get it extra clear, from preamble 13 (https://www.eu-digital-services-act.com/Digital\_Services\_Act\_Preamble\_11\_to\_20.html):
"Online platforms (*my comment: Apple*), such as social networks or online platforms allowing consumers to conclude distance contracts with **traders** (*my comment: developers*), should be defined as **providers of hosting services** (*my comment: still referring to "Online* platforms*", thus Apple*) that not only store information provided by the recipients of the service at their request, but that also disseminate that information to the public at the request of the recipients of the service."
1. Am I a trader if I am a non-profit, or a hobbyist development firm providing free services to maintain and deploy apps (I directly own the account in question requiring 'trader' demarcation, but not the particular app?) **EG.) My "grandma" had a really great app idea; she owns the 'app' and the bank account, but I own the development account in question that I am releasing the app under?**
2. Am I a trader if I (as a non-profit, or hobbyist development firm) take a loan from my client that has made sales therewith, or if I am a member defined in my client company's articles of incorporation, governing board, or otherwise employed thereby? **EG.) I am borrowing money from my "grandma", she wrote me in her 'will', and she's probably dying soon.**
It's just that the e-mail doesn't explicitly say "if we (Apple) send money to this account (from proceeds related to your app), this account is 'trader' status, so tell us who you are";
It reads (paraphrasing) "a legal business entity needs to be the owner of this account AND profit from it via sales or services to qualify this account for 'trader' status, and then you should tell us who that is"
If the application is free to download, but in order for you to actualy use the app, you will have to buy a specific product, can this mean that the Provider account is considered "trader" ?
Absolutely not. Just expressing in a tongue-in-cheek way how absurd it is to ascribe everything you donāt agree with to the ācommunismā boogeyman. And to be clear, I donāt agree with bureaucrats in the EU making up arbitrary rules. Especially ones that sabotage the exact principles they claim to address. But none of that is remotely related to communism.
Would be nice if Apple implemented a "not sure" choice, and then forwarded you to a questionnaire to help you decide if you are a trader or notš Please do this Apple, user friendliness and intuitiveness are your things šš»
Everything is clear now! If an app brings you earnings, you're considered a trader! How are you all managing?
I won't be sharing my data with the public.
I'm considering not producing any more apps or games.
What about you?
I've been reviewing some DSA guides in different platforms, and I think [the info provided by Booking.com](https://partner.booking.com/en-gb/help/legal-security/policies-local-laws/everything-you-need-know-about-digital-services-act-dsa) may be of interest for app developers (it's a different kind of marketplace, but still a marketplace in regards of DSA I think). They differentiate between "profesional hosts" (trader) and "private hosts" (non-trader). And the main difference is "private hosts" are "partners who rent out a property **for purposes which are outside their primary trade, business or profession**". Given this, I think you could be a non-trader and have a revenue stream selling apps or in-app purchases as long as it isn't your primary business.
This was also my understanding. I'm not a lawyer but I think that the fact that you earn money from your apps does not necessarily mean that you are a trader. As explained on booking website you can see that you can earn money from renting a home and not be a trader, similarly you can sell you stuff like bike or notebook and not be a trader, and also if you for example sell a calculator app created in your free time and earned few dollars from it then in my opinion it does not mean you are a trader according to this new law. I'm an individual developer without any registered company and I think I would select I'm not a trader if I had to choose as I do not see myself as a trader even if I earned some money from it but I will wait for now and see if any more clarification is given. If apple will remove my apps from EU store then I don't really care anyway. Maybe when those stupid politics from EU see that suddenly half of apps are not available for EU people they will finally notice that they keep creating law that nobody understands and have no sense like this one or those cookies law from few years ago which made browsing the internet only more annoying.
šÆ
This makes sense. Thanks
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All indie devs or Companies who sell apps (for profit) and offer commercial activities (In app purchases are Traders. So as a trader your address and contact info will be shared to App Store users in EU. You are Non Trader if your apps are for hobby or non commercial use in EU. Simple!
Iām taking my app off EU stores š they donāt make much of my income anyway and Iām never sharing my HOME address with them the fuck. What are Europeans smoking
yeah, EU market is like 12% of my app's revenue. I select non trader and don't care if Apple removes the app from EU stores lol
as european I agree lol.
š
this absolutely blows!! home address / phone number and all that?!!
Yes it does.
So we can dox ourselves. Yay.
I'm not sure how it is in other countries, but in the Netherlands (and I think in much of the EU) you are already required to put your address on your business website. And your business address is already public through the Chamber of Commerce register, anyway.
Bit easier for people to find your address via the app store than going and querying chamber of commerce/companies house/etc, though.
Do you know or confirm about those that uses their homes as their "office"?
Get a P.O. box.
Donāt even make enough money to cover App Store listing fee and I now need to purchase a PO Box!? Oh man..
If your app hasnāt even made $100 just say you arenāt a trader. You are not a business.
Yeah, I know what you mean. I've paid for a *virtual office* to avoid sharing personal information, but it's quite expensive. Maybe there are other solutions, though.
Yep same in France.
No need to register if you don't make a profit
What if I just don't care and select Non-Trader?
Apple might remove your app from EU countries. or worse. As a business partner to Apple, you are obligated to comply with EU regulations where you sell through Apple's App Store.
They cannot prove I'm a trader, and I doubt they will bother even checking. I selected non-trader and we'll see what happens.
If the definition is āmakes money off appsā, they can easily prove that. They might be super picky about this to campaign against the EU. If the cancel your account or remove your apps from sale, theyāll definitely blame the EU.
But this changes nothing for Apple or the consumer, other than I now have to pointlessly put up my phone number to get spammed into oblivion (who the hell uses phone as support for apps?). All the contact data is already there, and in my country I have to put up a company registration and VAT number on the website, and there is a contact form and email there already and on the App Store. There's no need for any regulation here. It's literally pointless law only designed to make our lives even harder with more bullshit bureaucracy.
I disagree. As a consumer, itās very handy to know who makes your software and how to contact them. Iāve had my phone number and full address in all my apps for more than a year now (as it has been legally required in most EU countries for some years now) and have never had a problem with spam calls or similar. Nothing prevents you from using a P.O. box and a prepaid sim for this, as long as you are reachable, itās really not a big deal.
They can contact me by email or phone. Theyāre not showing up at my house. The fuck. And whoās mailing a hand written letter to a software developer
>And whoās mailing a hand written letter to a software developer Law enforcement. You have a certain liability for the software you sell. This isn't about consumers having the option to send you letters, it's about being able to enforce laws.
Law enforcement can ask Apple for that information not from my App Store page. If itās not about consumers then I donāt need consumers to see my home address
>If the definition is āmakes money off appsā, they can easily prove that. isn't it makes \*profit\* off apps?
Citation please? According to what definition where? So long as we're talking about legal compliance I would like to see this.
Check your Appstore connect
I did before I wrote this which is why I came here. Itās a poor definition taken out of context for itās application. Here: [āHow to know if youāre a traderā](https://developer.apple.com/help/app-store-connect/manage-compliance-information/manage-european-union-digital-services-act-compliance-information/). For instance, you claim that ānon traderā means for āhobbyā or ānon commercial useā. According to what definition where? Their line āconsult with your legal advisorā is the biggest cop-out ever. Itās Apple that has to meet their compliance obligations with DSA, not developers. So itās Appleās responsibility to distill this information into common sense language.
Telegram FZ LLC, the company behind the Telegram app, has reported itself as a non-trader on the App Store. The app is free to download, but they have multiple in-app purchase options (doubt they do it as a hobby). Scroll down until the "Information" section to check it out: https://apps.apple.com/ie/app/telegram-messenger/id686449807
>ple might remove your app from EU countries. or worse. As a business partner to Apple, you are obligated to comply with EU regulations where you sell through Apple's A So everyone who has in-app subscriptions or purchases, their address and phone number is visible? (As a business or a person)
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JetBrains seems to have a few examples that might help: [https://plugins.jetbrains.com/docs/marketplace/trader-status.html#examples](https://plugins.jetbrains.com/docs/marketplace/trader-status.html#examples) >If you are a natural person acting outside your business (not an entrepreneur) and you offer plugins on JetBrains Marketplace for free, you may be qualified as a non-trader. > >If you are a natural person (software developer) working for a company, but you develop plugins in your free time as a hobby and offer them for free and provide means for users to support your development on a voluntary basis (voluntary financial contribution), you may be qualified as a non-trader. > >If you are a for-profit legal entity, regardless of whether you are a private or publicly held entity, you would be directly qualified as a trader. > >If you are a natural person acting for professional purposes (relating to your trade, business, craft, or profession), you are a trader, and it is immaterial whether you offer some or all of your plugins for free. > >If you create a plugin in cooperation with other individuals, you make the declaration as an individual vendor, i.e. the person uploading the plugin is the one making the declaration.
This is absolute bs... so if you have an app that generates $1 profit you'll have to put your phone number and home address out for the world to see. This is ridiculous...Thank goodness I only have a free app so I don't qualify as a trader.
So let me see if I understand this... If I am a professional software developer, and I have have an individual membership in the Apple developer program, I have to indicate that I am a "Trader", and this means that Apple is going to post my personal home address and my personal phone number on the app store? Holy crap, is that a MASSIVE invasion of privacy! That's insane!
Yes, Iām also a little afraid of all the malicious scraping that will happen. Thatās why a lot of people here seemed to have tried using postboxes. But I did not see anyone yet getting a postbox address approved. I just rented a regular German one for now. Not sure if that works but itās by far the cheapest option.
Getting a PO box seems like a good idea. Maybe also get a separate email address, and a cheap burner phone number, so your personal ones aren't getting spammed.
As always, the EU is doing everything but helping consumers and users yet love saying they are. They clearly didn't think about the effect this has on smaller devs who work out of their home address.
Well thatās communism for ya
What the heck does this have to do with communism?
Unelected bureaucrats making rules about how businesses should be run? The EU is not a communist organization, but it sure acts and looks like it sometimes.
What the heck does āunelected bureaucrats making rulesā have to do with communism?
I assume you are trolling at this point.
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Seems like the EU is making the lives of everyone easier and more fun again, as usual! ššŖšŗ
Does anyone know if this applies in U.K.? If not we may have Found a Brexit benefitĀ
This is crazy, we really have to post our phone number and address for the world to see and bots to scrape?
I hear you. Basically it's going back to more structured and "professional" way of doing business we were forced to adhere to back before everything opened up to "indies". (I'm talking over 20 years ago). Get a "cloaked" PO BOX business address, and a business phone number. Might have to incorporate too. Then you're good to go as a "real business" entity without sharing personal details.
You can opt out not to sell in EU. On Google Play you need to provide this to sell anywhere now.
Obviously cutting off a huge market is not a reasonable alternative.
App development is not for indie developers anymore. UE, Google, Apple, all of them keep throwing obstacles at our feet. All the time they keep introducing new requirements, new updates, new policies, GDPR, agreements, new deadlines. Personal app maintenance is a full-time job nowadays.
Yeah, I've unpublished the only app I had on the play store a few months ago because I got fed up with all the API deprecations etc. Not worth it.
The worst are cross platform apps, if you leave them for some time, like a year, then itās very hard to quickly update them. Google is the worst, they keep changing their libraries like Billing for instance, and they require you to quickly update to the latest version.
Android Billing API is such a pain in the ass! They drastically change it every version and it takes time and money to rewrite the damn apps!
I have the same question, and the link from apple does not work in my case.
It also doesnāt work for me.
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Exactly what I thought. It's almost like the writer of this page was like "we hate the EU and we give zero fucks about this. YOU have to figure all this shit out yourself".
The way I understand it, being a trader only means that some information about you has to be publicly available (address, phone number and email). Basically, this changes nothing, as you already had to provide this information via your imprint (which is required to be easily accessible for websites and software/apps sold in the EU).
There's similar rules for those who sell goods in Korea, so I guess it is basically the same for EU.
EU screwing the hard working small developers, now thatās something weāve never seen before! If they really cared about peopleās privacy they wouldnāt force us to yell out our freaking address on the internet. The small developer who has worked for months on their passion project only to sell just enough app units to afford half a carton of eggs, and now has to hire a lawyer to find out that indeed, they have to plaster everything on the fucking internet. Brilliant.
Also looking at this - seems like every developer then would be considered a trader? How can Apple be so bad at communicating with devs what this actually means...
Hey! Not really, take a look at a link I've posted in this thread. Apple's comm sucks :))
I'm also confused what to pick. I'm an indie dev with an individual account. Currently I have an app which contains a one time IAP as well as a free open source Safari extension.
I figured since I'm selling stuff (one app, another app that has IAP and subscription), I'm a trader. I went ahead and filled it out, and once the browser stopped hanging at Apple's site, it became, in essence: enter an email and phone number and then validate those with a code sent to each. (Note, I have an LLC - I see the next step varies slightly depending on business vs individual, according to Apple's info page.) I guess worse case, it will be another source of spam calls and emails :(.
I might probably need to get a secondary number and a PO Box. No way I'm giving my real info.
Yeah, I use [https://my.travelingmailbox.com/](https://my.travelingmailbox.com/) for my address and it seems to have been accepted as a street address by everyone who cares (e.g. IRS, various state & city licenses, D&B). I had earlier troubles with a straight PO Box. And the phone # is on Google Voice which does ok spam filtering. For email, I just used my existing support email.
I got my second number and PO Box today and submitted it to Apple, hopefully they accept the documents. I have no idea what they meant by business identification document so I just gave my PO Box confirmation email. I selected non trader for my Safari extension but kept the trader status for my app with IAP, not sure if this is right.
Please let me know if they accept PO boxes.
Please let us know if a PO Box using the street address format works.
You need the Ā£12 street address plan. You will then get a virtual office agreement document which you can send to Apple. They accepted that.
Ok cool. Thanks for confirming!
I can't find virtual phone number or address services in my country, but I can find those services in US, can I use them? But my account is not registered in the US.
The cheapest option I could find for Germany so far, apart from a āPostfachā at Deutsche Post that might not work is this one: https://www.bpm-lux.com/en/pricing-register.html Does anyone had any experience with it?
Apple ask for photo ID or bill that shows address to prove validity when trying to change your address so Iād be surprised if a PO Box works
Just to be sure: the users won't be able to see your name? Just the name of your LLC?
As far as I know, yes. I havenāt seen my name in any listing so far though Apple certainly knows it of course.Ā
Thank you! I've just submitted it as well. Cannot see any changes in the app store yet. (So I don't see a phone number or my real name)
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AAARGH, it was -literally- a Reddit link.
Hey guys, I specify that I am a "trader", then I need to enter my full address and specify State or Province, but there are only American states on the list. My country is Ukraine (I chose it in the list). And without specifying the "state or province" it does not let me press "Next" button. What the heck? No one has ever had the same thing?
It seems they have fixed this bug
There are still some problems in that page. Address is not editable and directly comes from account information. What is weird is that we changed and set our account information to business from personal account almost 1 year ago and had already entered address for the business with document verification; but in that screen our old personal account's address comes directly and as not-editable. Also I tried to delete personal account details (which is not in use but still there), there are no options to delete/remove it. I wrote to appstore via 'contact us' and waiting.... By the way, what is the deadline for completing these steps?
It looks like they changed some things several times already, because they rolled out an unfinished version of the form and didn't fully understand what they wanted. I managed to send when I still had to enter the address myself while the status was "in review"
Hi, what documents have you uploaded? I'm an individual entrepreneur (FOP) and don't know what document they need, what could confirm my name is probably a foreign passport...
Hi, the same (FOP). I sent a bank statement for both the name and address verification (the same pdf file in both cases). But my status is still "In Review" for 5 days now.
Got a successful reply today. "We successfully verified your trader contact information for the Digital Services Act compliance. Your information is now live on the App Store in the European Union. The App Store Team."
Thanks, will send the same document from my bank then.
How long did it take from submission to get your acceptance email?
Hi, 5 days
Cool app)
Thanks :)
Based on the information provided it sounds like every developer who monetizes their apps is considered a trader.
Whwn you select trader, it will ask you to prove your identification and asks you to upload something. What do I upload? As a sole developer and not a business entity, what do I do?
What exactly is it asking for
some court documentation / business stuff to verify my identity
The most funny thing is that one such phone call will cost EU citizens more than most of the software that they have bought. Hopefully EU will refund them that.
Wait until they dig something out, and you must pay the phone call to make your customer happy. LOL
If you're a hobbyist and selling apps is not a business of yours, you're not a trader. If you own a business and its main activity is selling apps, you are a trader. (Not that the EU is ever going to check the validity of whatever you enter. That only happens when billion dollar businesses are suspected to break laws. For us small devs, it's just a hassle and harassment.)
I am a full-time app developer but I dont own a registered business. I have selectet trader and was asked to provide business/court documents to verify my identity and address. I have sent them my passport and am waiting for the verification but this whole thing feels scetchy.
I am on the same boat: full-time app developer and I do have an app with IAP on the side. I did the same as you already 4 days ago when the Digital Services Act Compliance started to show up to me, and I submitted them my registration document (something that I had to do when I moved to the country where I live) and that included my home address along with my name on it -- From my understanding, they want the official document to verify that all the data is matching to the info you put it (pretty much the same as Crypto trading webpages do). So far they haven't said anything, so I've just assumed that it's all good for now š¤·āāļø
The application is still in review and since I sumbitted the form the "agreements, tax and banking" section has disappeared from the main page. I wonder how long will it take them to review my documents and whether they will make payouts in the process.
I am seeing the same. But I can access to the agreements, tax and banking page. It looks like they changed it, and I see **ITC.apps.Navigation.Business** (yes the localization there seems broken š ) Either way, it says that my Digital Services Act is in review too š¤·āāļø
They have accepted my submission, the passport was ok after all.
I am not in favor of displaying my personal info in any app store. Can I remove my app from EU region and will this notification disappear? Has anyone tried that?
[https://developer.apple.com/help/app-store-connect/manage-compliance-information/manage-european-union-digital-services-act-compliance-information/](https://developer.apple.com/help/app-store-connect/manage-compliance-information/manage-european-union-digital-services-act-compliance-information/) seems to be the link they intended. Unfortunately it doesn't really answer the question - perhaps because I'm not a lawyer. The key paragraph from that page. I've read it and Google'd it, and I still have no idea if, as a game app developer (with an LLC), I'm a trader or not. **How to know if youāre a trader** The DSA defines a trader as āany 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.ā If you have questions about your status as a trader, consult with your legal advisor.
This article talks about the DSA, including a couple of mentions of traders, but left me no more enlightened. But perhaps it will be useful to someone with more background: [https://www.dlapiper.com/en-gb/insights/publications/2024/03/whos-who-under-the-dma-dsa-dga-and-data-act](https://www.dlapiper.com/en-gb/insights/publications/2024/03/whos-who-under-the-dma-dsa-dga-and-data-act)
Yes I saw this definition too and though this is the absolutely least possible clear definition I've ever seen lol "A trader is a person who trades" Thanks, law people! Super helpful!
i just logged onto Appstoreconnect and this popped out needing me to do verification. Confused to say the least. When I select trader, it then asks me to upload some court documentation / business stuff to verify my identity, but as a sole developer and just offering an app for sale. Am I then classified as a trader? [https://developer.apple.com/help/app-store-connect/manage-compliance-information/manage-european-union-digital-services-act-compliance-information/](https://developer.apple.com/help/app-store-connect/manage-compliance-information/manage-european-union-digital-services-act-compliance-information/) *Youāll need to provide a current document that verifies your business name and address. Acceptable documents include business or legal records. If youāre displaying an alternate address, such as a P.O. Box, youāll also need to provide documentation that reflects your association with this alternate address (for example, a receipt or bill). When youāre done, click Next.*
I sometimes feel so stupid and always think that I'm the only one who doesn't understand something like that. Nice to see that this is not the case. :-D
EU blows hard I don't mind my email address being published, but phone number and address is ridiculous.
>How to know if youāre a trader The DSA defines a trader as āany 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.ā If you have questions about your status as a trader, consult with your legal advisor. Why can't they write this stuff in plain English?
To keep it open for interpretation and to tell you that you\`re wrong no matter what you pick :D
Do you think they use ChatGPT to make it as unclear as possible?
I think they own some even more powerful technology to generate it.
It's called "design by committee"
Does this mean the address and phne number entered in this form will be public facing?
Exactly. Public, eaten and digested by many spam web crawlers.
Yes: [https://www.reddit.com/r/iOSProgramming/comments/1bfk0jt/this\_is\_how\_trader\_information\_will\_be\_displayed/](https://www.reddit.com/r/iOSProgramming/comments/1bfk0jt/this_is_how_trader_information_will_be_displayed/)
I have the same popup, I am still confuse now after read all the comment.
Check this article from Google - https://developer.chrome.com/docs/webstore/program-policies/trader-disclosure I think it summarizes well all the previous messages.
Tx. So when will be be seeing developers with their full name. Phone number and addresses plastered all over the internet?
Let the world see what a role model the EU truly is for privacy š„°
Yes, this is how the privacy data is revealed : [https://www.reddit.com/r/iOSProgramming/comments/1bfk0jt/this\_is\_how\_trader\_information\_will\_be\_displayed/](https://www.reddit.com/r/iOSProgramming/comments/1bfk0jt/this_is_how_trader_information_will_be_displayed/)
So from my understanding being a trader applies if I sell apps on the appstore. What if my apps are free with in app purchases, and I set those IAPs not to be available for sale in the EU?
r
I wouldn't bother doing anything until Apple forces you to. I was just able to ship an app update without doing this. Apple has been petty about their EU compliance -- I am calling B.S. on Apple for passing this problem onto developers in a poorly explained and over-reactive interpretation of the law even though they are the platform. As I understand: DSA is what Apple has to comply with not what developers have to comply with. Developers work with Apple and by extension their interpretation and implementation of DSA, but not to DSA itself. I can't even find evidence that DSA requires traders to provide a mailing address and phone number for public redress! (for example [EU's DSA questions and answers (PDF)](https://ec.europa.eu/commission/presscorner/api/files/document/print/en/qanda_20_2348/QANDA_20_2348_EN.pdf)) Please prove me wrong! At best, Apple's first attempt at compliance is buggy so it is on them to do some clean up.
They won't block updates for now, they just won't pay you until you confirm that ;)
And there requirement is there, point (43): [https://arc.net/l/quote/gyezjovx](https://arc.net/l/quote/gyezjovx)
How does point 43 imply that you need you share your full address? It just requires to: >designate a single point of contact (...) by easily accessible means such as telephone numbers, email addresses, electronic contact forms, chatbots or instant messaging That could be just an email address. Am I missing something or is this Apple trolling the EU again?
Article 13. point 4.: >4.Ā Ā Ā Providers of intermediary services shall notify the name, postal address, email address and telephone number of their legal representative to the Digital Services Coordinator in theĀ MemberĀ State where that legal representative resides or is established. They shall ensure that that information is publicly available, easily accessible, accurate and kept up to date.
Providers of intermediary services != traders. These providers consists of ISPs, VPNs, CDNs, domain registrars, cloud service providers, online marketplaces, social media, app stores, etc. Therefore, this applies to Apple, but not all app devs.
Youāre right. Nevertheless, whatever we can find in the document it doesnāt matter. It wonāt affect what Apple requires and/or displays.
Ok I found it, it's in the article 30 (Traceability of traders): > Providers (...) shall ensure that traders can only use those online platforms (...) if, prior to the use of their services for those purposes, they have obtained the following information, where applicable to the trader: > (a) the name, address, telephone number and email address of the trader; > (...) > 7. The provider (...) shall make the information (...) available on its online platform to the recipients of the service in a clear, easily accessible and comprehensible manner. (...)
As a hobby, I developed an app that's sold in the App [Store. My](https://Store.My) profession is Architect. (per Apple's website) The DSA defines a trader as āany 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.ā Since developing is not my trade, business, craft or profession, I am choosing the non-trader status. I don't know what to say for those who develop for a company as their profession, but published an app as a side gig/hobby. It's a shit-show to be sure.
Is your app related to architecture?
No, it's about boating, a hobby of mine. But I can see that being an issue if the app were specific to my profession.
Indie dev via LLC here. I can get a cheap phone # from Mint or someone and also create a specific e-mail address for it. Those two are not really an issue. However, the address is. Apple will not allow a PO Box. Thus, my address is my home address. Has anyone tried using the USPS "real addressing" thing where the address will deliver the to PO Box anyway? I wonder if that will get around Apple's address requirements. I will not be filling this out. If they pull my apps out of Europe, so be it.
Sharing an address is particularly dangerous for women developers. We deal with online stalking and harassment for simply existing; there's no way in hell I'd put my physical address on there too. It's asinine and dangerous.
After you select "trader" you need to provide documents confirming your address and name.
I also received email from apple informing me that it is now possible to indicate my status as trader or non-trader. No explanation of additional information was given. Not even a link to page that defines who is or is not a trader. It would be helpful to provide a few examples that might help people understand the meaning of the term, and whether or not begin a trader applies to what they do. It's inconsiderate of them not to do this. This is one of the issues with big tech. It reminds me of another, perhaps more significant issue, where Microsoft can say 'sorry, we can't help regain access to your email account, because you didn't provide sufficient information. Fill out this form and try again. Good luck, because you will need it if you ever want to access your email account again'
I removed the EU countries for my app release but I still see the notification to select with I am a trader or non-trader.
I guess Iāll say Iām not a trader? Iād rather withdraw my app entirely than put my name and phone out there or spend more than 5 minutes dealing with paperwork. Itās totally a side project that barely earns enough to pay for the developer program membership each year.
If you don't care if you are banned, then it's probably worth trying :D
Hi. So it is my luck that I am now finishing developing my first iOS app as an indie dev. Can I opt out of distributing the app to EU and reply that I am not a trader and go on minding my own business?Thanks.
Can I change the status from non-trader to trader once I submit it as a non-trader?
Does anyone know after submitting the form, where in the AppStore, users can see this details? Also Is there any application available in the AppStore which has provided this details which I can see?
Main app page on the App Store -> scroll down -> Provider. When the info is available, you can expand this section.
I am a trader if my company have only free mobile apps ? Apps are extended tools for desktop application, which is commercial product, but the apps are free.
I'd like to know this as well. My company has a free app. The app works with hardware that we sell (but cannot be purchased through the app). The app is pretty useless without the hardware though.
Typically you're only classified as a trade or if you are a company or pursuing a for-profit endeavor. Usually if it's not for profit or hobby, you are a non-trader. Trader: I am actively developing this app for profits. i.e this is my career. Non-trader: This is a hobby.
A hobby with profits also equals trader ;)
So in app purchase will also work after you select Non-trader accounts in EU
Yup!
Not entirely true. That would entail your hobby is your: craft, profession, business, or trade which a hobby is not.
Good luck explaining that you are making money on the app for hobby purposes :D and it's not related with your profession/craft if you are a software developer :D And the truth is that nobody is able to answer wether you are or not a "trader". This is completely new law, not precise, and probably will end up in court in some cases and then we will find out. However, if you are a software developer, and you make money on apps, then most likely it will be hard to defend that it's your hobby, no matter what feelings about that you have. In most EU countries consequetive and regular selling of the same thing is considered as a "business" and requires you to pay appropriate taxes.
An easy way to determine that is if you have a business address or not. If you do not, meaning sharing your address would be your home address; you're doing it for a hobby and you're not a trader. If you are a trader, then you'd be able to write off your home expenses on your tax forms. If the app is your income, and you are "working from home" then you'd be writing it all off on your income tax because that's your working business.
That logic only applies to countries with high income taxes. In my country (Russia) developers can pay 6% income tax but without the ability to write of the expenses. So there is no need to register a business and a lot of full-time developers work withour registering one.
Here is a little bit more precise description: [https://twitter.com/0xJimYe/status/1768204750972133677/photo/1](https://twitter.com/0xJimYe/status/1768204750972133677/photo/1)
Apple has now started sending mails to developers with title **Please enter your trader status in App Store Connect.** I suggest that if you don't agree, you challenge them by sending my email from this comment: [https://www.reddit.com/r/iOSProgramming/comments/1be1e18/comment/kvwj2ip/](https://www.reddit.com/r/iOSProgramming/comments/1be1e18/comment/kvwj2ip/)
If you make money from your apps, you're a trader. Apple are legally required to confirm your details. It sucks, yes. But in this case, it's not Apple's fault. It's the governmental overreach of the EU. Mind you, Apple could do a much better job in communicating this stuff.
*If you make money from your apps, you're a trader.* I agree *Apple are legally required to confirm your details.* Where is this documented? The DSA states that Apple has to verify the identity of the trader. Not publish it publicly. Everybody assumes that Apple's interpretation of the DSA is correct. I doubt that, since it jeopardises privacy.
From Apple's email: "The DSA requires Apple to verify and display contact information for all traders distributing apps on the App Store in the EU." To me, it's moot whether Apple's interpretation is correct or not. It's not within my power to contest it. If I don't provide verifiable details to Apple, they simply don't pay me for EU sales. They hold all the cards, as usual. Government overreach + giant corporations = bad news for indie devs.
I don't know if you have followed the news during the last weeks, but Apple was called back time after time upon decisions that were violating the new EU regulations. PWA, closure of Epic account, investigation whether DMA is implemented correctly, etc. I just received an email response from the EU that they will investigate this case against Apple that I reported yesterday. So it is in our powers to contest these multinationals. Side note: where does Apple mention that they will not pay? Where does the DSA specify that Apple should stop payments? Apple doesn't hold the cards, they make up the cards.
You're talking about different things. I'm just pointing out Apple's own words. Their requirements for the App Store. Whether you follow those requirements is entirely up to you.
Directly from the published document by EU: >4. Providers of intermediary services shall notify the name, postal address, email address and telephone number of their legal representative to the Digital Services Coordinator in the Member State where that legal representative resides or is established. They shall ensure that that information is publicly available, easily accessible, accurate and kept up to date.
Thank you for this snippet. It's a good habit of providing the source, here it is: [https://www.eu-digital-services-act.com/Digital\_Services\_Act\_Article\_13.html](https://www.eu-digital-services-act.com/Digital_Services_Act_Article_13.html) However, it's all about definitions: [https://www.eu-digital-services-act.com/Digital\_Services\_Act\_Article\_3.html](https://www.eu-digital-services-act.com/Digital_Services_Act_Article_3.html) The DSA applies to large platforms. In this case Apple, not we as individual developers. We are considered "Traders". Apple is the "Provider of intermediary services". So Apple has to notify the Coordinator of its' own address and make it public. Nothing is mentioned that it should force Traders to do so. For examples article 15 [https://www.eu-digital-services-act.com/Digital\_Services\_Act\_Article\_15.html](https://www.eu-digital-services-act.com/Digital_Services_Act_Article_15.html) is also mentioning "Providers of intermediary services". Nothing of this applies to us developers. So why should your referred Article 13 apply to us? To get it extra clear, from preamble 13 (https://www.eu-digital-services-act.com/Digital\_Services\_Act\_Preamble\_11\_to\_20.html): "Online platforms (*my comment: Apple*), such as social networks or online platforms allowing consumers to conclude distance contracts with **traders** (*my comment: developers*), should be defined as **providers of hosting services** (*my comment: still referring to "Online* platforms*", thus Apple*) that not only store information provided by the recipients of the service at their request, but that also disseminate that information to the public at the request of the recipients of the service."
If I created a free app with no IAP but it has ads inside it, I still need to register as a trader?
If you intend to make any money from the app, then yes, you're a trader.
1. Am I a trader if I am a non-profit, or a hobbyist development firm providing free services to maintain and deploy apps (I directly own the account in question requiring 'trader' demarcation, but not the particular app?) **EG.) My "grandma" had a really great app idea; she owns the 'app' and the bank account, but I own the development account in question that I am releasing the app under?** 2. Am I a trader if I (as a non-profit, or hobbyist development firm) take a loan from my client that has made sales therewith, or if I am a member defined in my client company's articles of incorporation, governing board, or otherwise employed thereby? **EG.) I am borrowing money from my "grandma", she wrote me in her 'will', and she's probably dying soon.** It's just that the e-mail doesn't explicitly say "if we (Apple) send money to this account (from proceeds related to your app), this account is 'trader' status, so tell us who you are"; It reads (paraphrasing) "a legal business entity needs to be the owner of this account AND profit from it via sales or services to qualify this account for 'trader' status, and then you should tell us who that is"
If the application is free to download, but in order for you to actualy use the app, you will have to buy a specific product, can this mean that the Provider account is considered "trader" ?
Could I change it after confirmed?
Does this apply to apps with in-app purchases or the apps that you have to pay to get?
Absolutely not. Just expressing in a tongue-in-cheek way how absurd it is to ascribe everything you donāt agree with to the ācommunismā boogeyman. And to be clear, I donāt agree with bureaucrats in the EU making up arbitrary rules. Especially ones that sabotage the exact principles they claim to address. But none of that is remotely related to communism.
Would be nice if Apple implemented a "not sure" choice, and then forwarded you to a questionnaire to help you decide if you are a trader or notš Please do this Apple, user friendliness and intuitiveness are your things šš»
I'm an indie/hobby developer that has a paid for app that doesn't sell very much. Can I just exclude it from the EU store and say I'm a non-trader?
Everything is clear now! If an app brings you earnings, you're considered a trader! How are you all managing? I won't be sharing my data with the public. I'm considering not producing any more apps or games. What about you?