EU Trader Status: Fix This Before Your App Gets Removed

Apple added a consequential requirement to App Store Connect on October 17, 2024: every Account Holder or Admin who publishes an app update in the EU must first enter "trader status." In this post I walk through what the App Store EU trader status requirement is, who it covers, how to fill it in inside App Store Connect, and the deadline you need to hit.

💡 Pro Tip: You enter trader status once at the account level; if you want a different status for a single app, you can also edit it separately from App Information → App Store Regulations and Permits → Digital Services Act.

Table of Contents

• What trader status is, and which regulation it comes from
• Who counts as a trader: the individual developer vs. company distinction
• Step-by-step entry in App Store Connect
• Verification process and rejection reasons
• Where this information appears to users
• Removal risk and deadline planning
• How you determine whether you're a trader
• FAQ
• What is App Store trader status and who is it required from?
• Will my app be removed if I don't enter this information?
• What should I enter as an individual developer?
• Is there a specific clause about trader status in the App Review Guidelines?
• What should I do if I'm rejected?
• How do I change the status at the app level?
• Update (September 2026)
• Timeline (at a glance)
• Conclusion
• Sources

What trader status is, and which regulation it comes from

Apple's official October 17, 2024 announcement opens with a blunt sentence: "Starting today, in order to submit updates for apps on the App Store in the European Union (EU) Account Holders or Admins in the Apple Developer Program need to enter trader status in App Store Connect." So this isn't a suggestion — it's an entry step imposed by App Store Connect itself.

The basis is the EU's Digital Services Act (DSA). Under the DSA's own definition, a trader is: "any natural person, or any legal person irrespective of whether privately or publicly owned, who is acting, including through any person acting in his or her name or on his or her behalf, for purposes relating to his or her trade, business, craft or profession." In other words, the DSA covers anyone "acting for commercial purposes" — this doesn't have to be a company; an individual developer acting commercially can fall under this definition too.

Apple didn't cram this regulation into a single screen: it built a default status at the account level, plus a separate override mechanism at the app level. That matters for developers who say "one of my apps isn't commercial, but the others are" — I walk through it step by step below.

Who counts as a trader: the individual developer vs. company distinction

Apple's current help page defines a clear exit for non-traders: "If you don't distribute apps on the App Store in the EU (for example you only distribute apps through alternative distribution, or TestFlight, or on the App Store only outside the EU), you're not acting as a trader on the App Store."

But if you distribute through the App Store in the EU (not alternative distribution or TestFlight-only, but directly on the App Store) and you're doing it for commercial purposes, you count as a trader — being an individual developer doesn't automatically exempt you.

The information requested depends on account type. For organization accounts, Apple auto-fills the address tied to your D-U-N-S Number; all that's left for you is a phone number and email address. In the help page's own words: "The address associated with your D-U-N-S Number will automatically display. You'll need to enter the following for display on your App Store product pages: Phone number / Email address." For individual accounts there's no auto-filled address — you manually enter all three: address or P.O. Box, phone number, and email address.

Step-by-step entry in App Store Connect

Only someone with the Account Holder or Admin role can make this entry; the help page marks this as "Required role: Account Holder or Admin." Here's the process in brief:

• Choosing trader status: In App Store Connect, go to the Business tab at the top, scroll down in the Agreements tab to the Compliance section, and click Complete Compliance Requirements next to the Digital Services Act row — you get two options: "This is a trader account." or "This is not a trader account." If you're not a trader, Done ends the flow without asking for contact info; if you are, you move on. Which information you enter depends on your account type — this isn't a separate choice in App Store Connect, it's determined by how you're registered with the Apple Developer Program.
• Entering and verifying information: If you're a trader, enter the contact information above based on account type (organizations get the address auto-filled, individuals enter it manually), then click Next. The system confirms your email, then your phone via a two-factor code; a number that can't receive one lets you request manual verification. Finally, upload a current document proving your business name/address (a P.O. Box also needs a receipt or invoice), review, and hit Confirm.
• App-level override: If you want a different status for specific apps, the path is: App Information → App Store Regulations and Permits → Digital Services Act → Edit.
• Additional fields: Those marked as traders are also asked for payment account details, plus you sign a self-certification that you only offer products/services compliant with EU law.
• Labels and Markings URL: The help page defines this as: "Under the Digital Services Act, you have the option to provide a Labels and Markings URL to display labels or markings required by European Union law." This field is optional and only appears on the App Store product page for apps marked as traders.

If you want to support the process with tooling/automation, take a look at iOS CI/CD Pipeline: GitHub Actions and Fastlane for approaches that tie the App Store Connect process into CI/CD — the trader status field itself can't be automated, but you can add your pre-submission checklist there.

Here's what's requested by account type:

This table only applies if you select "This is a trader account." — if you mark "This is not a trader account.", no contact information is requested at all.

If you want to track the days remaining until the deadline with a script, you can use this line in the terminal (with the macOS/Linux date command):

1# Days remaining to the February 17, 2025 deadline, as of 2024-11-06
2start="2024-11-06"
3deadline="2025-02-17"
4d1=$(date -j -f "%Y-%m-%d" "$start" "+%s" 2>/dev/null || date -d "$start" "+%s")
5d2=$(date -j -f "%Y-%m-%d" "$deadline" "+%s" 2>/dev/null || date -d "$deadline" "+%s")
6echo $(( (d2 - d1) / 86400 ))
7# output: 103

As of the day this post was written (2024-11-06), the remaining window is 103 days; the total window from the announcement (2024-10-17) to the deadline (2025-02-17) was 123 days.

Verification process and rejection reasons

Entering your email and phone number alone isn't enough — Apple verifies them with a two-factor code; if you're using a phone number that can't receive a two-factor code, you may drop into a manual verification step. A current document proving your business name/address is also required; if you use a P.O. Box as your address, you also need a second document such as a receipt or invoice.

Apple's help page also gets specific about document types: "Acceptable documents include business or legal records" — a trade registry record, official correspondence, or similar business records; it must be current and clearly show the business name/address. A P.O. Box alone isn't enough, since it doesn't verify a physical address: the help page asks for a second document, such as a receipt or invoice.

The document side isn't limited to identity verification alone. For every trader account, the help page adds: "All traders: … payment account details … certify that you only offer products or services that comply with the applicable rules of EU law." So the process bundles three declarations: completing payment account details, proving your business registration with a document, and self-certifying EU-law compliance. Verification doesn't close out until all three are complete.

Apple's help page doesn't publish an explicit list of "rejection criteria." It can be inferred that verification may fail if documentation is missing or information is inconsistent, but beyond that there's no published rate or fixed rule.

Don't neglect account security either: trader information falling into the wrong hands is no different from a full account compromise. See iOS Security Best Practices 2024 for how to protect your App Store Connect account.

Where this information appears to users

The phone, email, and address information you enter is for display purposes only — it doesn't change the information tied to your Apple Developer Program membership. In the help page's own words this information is entered "for display on your App Store product pages"; meaning it becomes visible on the App Store product page (the page with the app name, screenshots, description) for the app as distributed in the EU. If you're marked as a trader and entered a Labels and Markings URL, that appears on the same page too.

Easy to miss: this isn't a compliance record that stays in the background — it's information a user can openly see while reviewing your app. If you don't want to enter your home address, Apple allows individual accounts to use a P.O. Box instead.

Removal risk and deadline planning

The most critical sentence in Apple's announcement is this: "Starting February 17, 2025, apps without trader status will be removed from the App Store in the EU until trader status is provided and verified in order to comply with the Digital Services Act." So if the information is missing, the app is removed entirely — this isn't a temporary warning.

As of today (2024-11-06), the window ahead is 103 days, as calculated above. Considering that the verification steps (two-factor code, document upload, possible manual review) can take days, leaving it to the last week is a risky strategy. I'd suggest adding a small checklist to your own calendar and marking your progress:

1# trader-status-checklist.yaml — your own tracking file, not part of Apple's API
2task: "EU Trader Status entry"
3deadline: "2025-02-17"
4steps:
5  - choose_trader_status: pending
6  - enter_contact_info: pending
7  - two_factor_verification: pending
8  - document_upload: pending
9  - check_app_level_override_needed: check

This YAML is purely a personal tracking template — it's not an official App Store Connect API field or parameter, just a practical way to note your own progress.

How you determine whether you're a trader

At this point the real question is: who decides you're "acting for commercial purposes"? Apple's help page is clear on this: "Apple can't determine whether you're a trader." The decision isn't Apple's to make — you assess your own situation and check the relevant box.

It isn't entirely arbitrary, though. The European Commission defines a few factors for assessing trader status; the ones the help page lists are: whether you earn revenue from your app (in-app purchases, a paid app, or ads — especially at high volume), whether you engage in commercial practices like advertising aimed at consumers, whether you're registered for VAT, and whether you develop the app as part of your trade, business, craft, or profession. These aren't exhaustive — the Commission can consider other factors too — but the App Store Connect question steers you toward exactly these.

There's an exception: the help page says "You're unlikely to be a trader for EU law purposes if you're acting 'for purposes which are outside your trade, business, craft, or profession,'" then gives an example — a hobby project with no intent to commercialize may not count. This disproves the assumption that "every individual developer is automatically a trader" — the deciding factor is commercial purpose, not account type.

Another easy-to-miss rule: even if you don't distribute at all through the EU App Store, you can't leave this field blank. The help page is explicit: "Even if you don't distribute apps in the EU, you'll still need to declare a trader status." You can't skip the step by saying "this doesn't apply to me" — at minimum, check "This is not a trader account."

This information isn't limited to a single market either. When your app is distributed in any of the EU's 27 territories, Apple publishes it on your App Store product page — one information set applies across the EU, with no per-country setting. There's also a visible consequence for declaring you're not a trader: the help page states "consumers in the EU will be informed that consumer rights stemming from applicable consumer protection laws won't apply to contracts between you and them." So it's not a penalty, but it is shown directly to the user — anyone visiting your page sees that standard consumer-protection rights don't apply to their contract with you. "Not a trader" is therefore not a consequence-free checkbox — it's a declaration with a user-facing consequence.

FAQ

What is App Store trader status and who is it required from?

Trader status is a mandatory information field Apple added to App Store Connect under the EU's Digital Services Act regulation. It's required from every Account Holder or Admin who publishes an app update on the App Store in the EU; under the DSA's definition, anyone acting for the purpose of "trade, business, craft or profession" can be considered a trader.

Will my app be removed if I don't enter this information?

Yes. In Apple's own words: "Starting February 17, 2025, apps without trader status will be removed from the App Store in the EU until trader status is provided and verified in order to comply with the Digital Services Act." If the information is missing, removal isn't a temporary warning — it means the app is fully removed from the EU store; it becomes visible again once the information is completed and verified.

What should I enter as an individual developer?

As an individual account, you enter an address or P.O. Box, phone number, and email address — unlike organizations, the address isn't auto-filled. If you don't distribute your apps commercially on the EU App Store (only alternative distribution, TestFlight, or App Store outside the EU), you can check "not a trader" and proceed without entering any contact information.

Is there a specific clause about trader status in the App Review Guidelines?

No. Neither "trader" nor "Digital Services Act" appears in the App Review Guidelines. The Guidelines only contain a general EU-compliance clause: "Apps that collect data for a legitimate interest without consent by relying on the terms of the European Union's General Data Protection Regulation ('GDPR') or similar statute must comply with all terms of that law." So the trader status rule doesn't live in the Guidelines — it lives in App Store Connect's own entry flow and a separate help page.

What should I do if I'm rejected?

Apple's help page doesn't publish an explicit list of "rejection criteria"; the general guidance is that documents need to be current and capable of verifying your business name/address. Verification can fail if a document is missing or inconsistent — in that case, retrying with a second piece of evidence such as a current invoice, official correspondence, or trade registry record is a sensible first step.

How do I change the status at the app level?

Via App Information → App Store Regulations and Permits → Digital Services Act → Edit, you can set a different trader status for just that app without changing the account-level default.

Update (September 2026)

When this article was first published (2024-11-06), the deadline hadn't yet arrived. Enforcement did happen: according to Appfigures data reported in TechCrunch's February 18, 2025 story, roughly 135,000 apps went inactive across EU App Stores in the first 30 hours after the deadline passed, and that number climbed to 137,000 by Wednesday — in TechCrunch's own words: "nearly 135,000 apps have gone inactive on all EU member state App Stores over the last 30 hours. (As of Wednesday, that number climbed to 137,000.)" This was the mass removal of apps from developers who hadn't entered contact information (address, phone, email).

As of today (September 2026), the mechanism itself hasn't changed: the fields based on account type, the D-U-N-S auto-filled address, two-factor verification, and the optional Labels and Markings URL field all still work the same way on the same help page.

Timeline (at a glance)

If you want to keep a record on the code side, you can note it as a documentation comment in your project — this isn't a real API call, just a placeholder for your team (or future you) to remember:

1// MARK: - DSA Trader Status (reference note, not a real API)
2// Deadline: 2025-02-17 (passed) — mechanism unchanged as of September 2026.
3// Account level: App Store Connect → Business → Agreements → Compliance → Digital Services Act
4// App-specific override: App Information → Digital Services Act → Edit

If you want to keep your own record, a simple JSON template does the job too (this isn't an official Apple schema — it's for your own archive):

1{
2  "task": "EU trader status entry",
3  "accountType": "individual",
4  "status": "trader",
5  "documentUploaded": true,
6  "deadline": "2025-02-17",
7  "note": "personal tracking file, not an official API"
8}

Conclusion

The EU trader status requirement looks like a small form on paper, but the consequence is severe: missing information means full removal from the App Store in the EU. The 123-day window between announcement and deadline is now in the past, but the mechanism itself (account-type fields, D-U-N-S automation, two-factor verification, app-specific override) works the same way today — so a developer who hasn't entered this information yet still has to go through the same steps.

If you want to think through in-app purchase flows alongside EU compliance, Modern In-App Purchase with StoreKit 2 is useful. If you want to make the process testable, Test-Driven Development (TDD) on iOS: The Complete Guide is a good complement for disciplining your verification steps. If you want to prepare for other EU regulations on the accessibility side, iOS Accessibility: The Complete Guide from VoiceOver to Dynamic Type may also be useful.

Sources

• Apple Developer News: EU Trader Status — official announcement: the entry requirement and the February 17, 2025 deadline.
• Apple: Manage EU Digital Services Act Trader Requirements — trader definition, account-type-based fields, Labels and Markings URL.
• Apple App Review Guidelines — the full text of the App Review Guidelines; contains no clause specific to trader status.
• TechCrunch: Apple purges apps without contact info from EU app store as DSA deadline hits — the February 18, 2025 enforcement and roughly 135,000-137,000 apps going inactive.
• European Commission: Digital Services Act package — the official EU source for the DSA regulation underlying the trader status requirement.