Apple has released an updated version of the Apple Developer Program License Agreement, introducing important revisions that affect how developers manage interpreted code, location-based features, EU data compliance, and payment tools like Tap to Pay.
The new terms must be reviewed and accepted within the Apple Developer account before new app submissions or updates can proceed.
Key Revisions in the Updated Agreement
Interpreted Code and App Behavior
Apple has refined Section 3.3.1(B) to clarify restrictions on apps that execute or embed interpreted code.
This update impacts apps that use dynamic scripting, runtime code loading, or external script engines, reinforcing Apple's focus on platform security and controlled app behavior.
Location Push and Data Compliance
Under Section 3.3.3(F), Apple has updated terms related to the Location Push Service Extension.
The clarification aims to standardize the way apps handle location-triggered notifications.
Additionally, Section 3.3.8(A) and Attachment 4 introduce new references for Xcode Cloud and CloudKit in line with EU Regulation 2023/2854 (EU Data Act), ensuring developers comply with evolving European data protection standards.
Payment and API Authorization
Section 3.3.9(D) revises conditions for distributing and managing the Tap to Pay APIs.
The changes define which entities can integrate or license these APIs, ensuring secure handling of payment features and compliance with financial regulations in supported regions.
Promotional Tools and Offer Codes
Apple has redefined the use of Promo Codes and Offer Codes under Schedule 1 and Schedule 2.
These updates clarify the limits and usage conditions for digital promotions, potentially affecting marketing strategies and in-app user acquisition campaigns. Developers using these tools should review the updated definitions and distribution rules.
Implementation Timeline & Next Steps
Apple advises developers to log into their accounts to accept the revised agreement immediately.
Translated versions of the document will be available within approximately one month.
Teams leveraging dynamic code, Tap to Pay, or EU data-related services are encouraged to re-evaluate their implementations to ensure full compliance with the new guidelines.
Editor's Comments
The October 2025 update to Apple's Developer Program License reflects the company's broader commitment to legal clarity, data transparency, and global compliance.
The inclusion of EU Data Act references signals Apple's proactive adaptation to regional regulations, while changes to code execution and payment frameworks suggest a continued emphasis on platform integrity and financial security.
These updates may also streamline future interactions between Apple's ecosystem and third-party developers, especially in the EU market where data-sharing obligations are tightening.
The clarified definitions for promotional tools could further align App Store marketing with emerging consumer protection norms, enhancing trust and accountability across the developer community.
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