App may be affected by post-Epic alternative billing rules

The post-Epic v. Apple regulatory environment has produced jurisdiction-specific carve-outs to the rule that all digital goods must be sold through the platform store. For EU iOS apps under the Digital Markets Act, Apple must permit alternative payment methods for Core Technology Fee-registered developers. For US iOS apps following the 2024 court order, Apple allows apps to link to external purchase — subject to a 27% commission on purchases within 7 days. Developers who implement alternative billing without understanding these jurisdiction-specific rules, eligibility requirements, and commission structures risk building a payment flow that is simultaneously policy-compliant in one market and a violation in another. Regulatory-conformance is the directly applicable taxon.

If your codebase contains any references to com.apple.developer.storekit.external-purchase-link, EXTERNAL_PURCHASE, or User Choice Billing alongside standard platform billing, review the current requirements before shipping.

For EU (Digital Markets Act) distribution via alternative marketplaces:

• Read Apple's Alternative Distribution documentation; the Core Technology Fee still applies
• Alternative payment entitlements require a separate App Store Connect configuration from standard IAP

For US external payment links (post-2024 court order):

• The 27% commission applies to purchases made within 7 days of an external link tap
• Required disclosure language must appear before the user leaves the app

For now, the safest path for global App Store distribution — and the only one with no regulatory uncertainty — remains exclusive use of platform IAP with no external payment links. Consult Apple's official App Store Review Guidelines section 3.1 (updated frequently) before implementing any alternative billing path.

• ID: app-store-iap-subscriptions.risk-indicators.alternative-billing-rules

• Severity: info

• What to look for: Count all relevant instances and enumerate each. Following the Epic v. Apple ruling and subsequent DOJ/EU regulatory actions, the alternative payment landscape for app stores is evolving. Look for signals that the app is in a category or market that might be affected: (1) App targets the United States market and is in a category that has been subject to antitrust scrutiny (games, video streaming, music, productivity). (2) The developer's terms of service or codebase contains language referencing "alternative payment methods", "external payment links", or "third-party billing". (3) iOS 17.4+ EU-specific entitlements in the Entitlements.plist or Xcode project (com.apple.developer.storekit.external-purchase-link). (4) Any references to the EXTERNAL_PURCHASE StoreKit capability or appStoreConnectEnabled: false patterns indicating alternative marketplace distribution. (5) Play Billing Library use alongside User Choice Billing (Google's alternative billing program in certain markets). This is an informational risk indicator only — the regulatory environment is changing, and what is prohibited today may be permitted (with restrictions and fees) in specific jurisdictions tomorrow. Not a scored failure.

• Pass criteria: Not applicable — this is an info check. Result is pass or skip only, never fail.

• Fail criteria: Not applicable — result is pass or skip only.

• Skip (N/A) when: App is Android-only in a jurisdiction with no alternative billing regulations; or no signals indicating awareness of or planning for alternative billing; or cannot be determined.

• Detail on fail: Not applicable.

• Remediation: The alternative billing regulatory landscape is actively changing (as of early 2026):

  1. For US iOS apps: Apple's court-ordered alternative payment link entitlement allows apps to link to external purchase in the US, subject to a 27% commission on purchases made within 7 days. The rules are complex — consult Apple's official documentation before implementing.
  2. For EU iOS apps (Digital Markets Act): Apple must allow alternative app stores and alternative payment methods for Core Technology Fee-registered developers. If distributing via alternative marketplaces, IAP rules differ significantly.
  3. Recommended reading: Apple's App Store Review Guidelines section 3.1 (updated frequently) and Google Play's Billing Policy.
  4. For now, the safest path for global App Store distribution remains exclusive use of platform IAP with no external payment links.

  Review the configuration in src/ or app/ directory for implementation patterns.