On April 30, 2025, the Northern District of California immediately and permanently enjoined Apple's External Purchase Link entitlement programs and its restrictions for apps offered on the United States storefront. Apple announced the following day that it has updated its App Review Guidelines as follows:
The App Review Guidelines have been updated for compliance with a United States court decision regarding buttons, external links, and other calls to action in apps. These changes affect apps distributed on the United States storefront of the App Store, and are as follows:
3.1.1: Apps on the United States storefront are not prohibited from including buttons, external links, or other calls to action when allowing users to browse NFT collections owned by others.
3.1.1(a): On the United States storefront, there is no prohibition on an app including buttons, external links, or other calls to action, and no entitlement is required to do so.
3.1.3: The prohibition on encouraging users to use a purchasing method other than in-app purchase does not apply on the United States storefront.
3.1.3(a): The External Link Account entitlement is not required for apps on the United States storefront to include buttons, external links, or other calls to action.
Prior to the April 30th ruling, Apple had imposed a 27% commission on all purchases made outside of Apple's in-app payment processing system through its "External Purchase Link" entitlement programs. This program set out required tools for developers to offer external payment methods, subject to Apple's 27% cut and various prohibitions on the how developers linked consumers to external payment methods.
In light of this ruling, Apple now is prohibited from imposing its 27% commission on purchases made outside of the app environment, restricting how developers direct their users outside of the app environment (including transparency on low prices on external webstores and pre-populating in product information or other purchase details in webstores, for example), and interfering with a consumer's choice to proceed outside of the app environment in any means other than a natural message notifying users they are existing the app. These changes to the App Review Guidelines are only applicable to apps distributed on the United States storefront.
This alert provides general coverage of its subject area. We provide it with the understanding that Frankfurt Kurnit Klein & Selz is not engaged herein in rendering legal advice, and shall not be liable for any damages resulting from any error, inaccuracy, or omission. Our attorneys practice law only in jurisdictions in which they are properly authorized to do so. We do not seek to represent clients in other jurisdictions.
