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App Store rejectionGuideline 5.1.1(ix) - Legal - Privacy - Data Collection and Storage

Guideline 5.1.1(ix) says apps for highly regulated fields, such as banking, healthcare, gambling, air travel and crypto exchanges, should be submitted by the legal entity that provides the service, not by an individual developer. If the app was submitted from an individual account, the fix is to submit it from the provider’s organization account.

Short answer

Enroll the company that provides the service in the Apple Developer Program as an organization, which needs a D-U-N-S Number, then transfer the app to that account or submit it from there. If you build the app for a client, the app should be submitted from the client’s organization account.

Rather not fix it yourself? App Fix Ticket starts with a fixed-price diagnosis, then a fixed price for the fix before any fix work.

Why 5.1.1(ix) applies, and the fix

  1. 01

    The app is in a personal developer account

    “should be submitted by a legal entity that provides the services, and not by an individual developer.” Apple, Guideline 5.1.1(ix)

    An app for banking and financial services, healthcare, gambling or a crypto exchange, submitted from an individual account, fails this rule. Submit it from an organization account owned by the company that provides the service.

  2. 02

    The company has no organization membership yet

    “Your D‑U‑N‑S Number will be used to check the identity and legal entity status of your organization” Apple, D-U-N-S Number

    Enrolling as an organization needs the company’s D-U-N-S Number, which Apple uses to verify the legal entity. Look the number up, or request it, before you start enrolling.

  3. 03

    The app already has users in the wrong account

    “During and after the transfer, the app retains its reviews and ratings, and users continue to receive updates.” Apple, Overview of app transfer

    Moving an existing app does not mean starting over. An app transfer keeps the app live with its reviews, ratings and updates, and keeps the bundle ID.

  4. 04

    A developer built the app for the provider

    Also check: if an agency or freelancer builds the app, it should be submitted from the provider’s organization account, not the developer’s own. Adding the developer to that account in App Store Connect lets them upload builds while the provider stays the account holder.

Checked against the vendor’s docs on : Apple: App Review Guidelines, 5.1.1 Data Collection and Storage; Apple Developer Help: D-U-N-S Number; App Store Connect Help: Overview of app transfer; Apple: App Review (replying and appeals).

Rather hand it over?

Fixed scope, fixed price, paid upfront. The work happens in writing; no call needed.

Resubmit before Apple’s holiday slowdown

Pay for the Diagnosis and send the rejection and access to the app by (US Eastern). The Diagnosis is back by . Pay for the Fix that day and it arrives as a pull request by , in time to build and resubmit before .

In past years Apple said reviews may take longer around the holidays: December 20 to 26 in 2024 (opens in a new tab), December 22 to 27 in 2023 (opens in a new tab), December 23 to 27 in 2022 (opens in a new tab). Apple hasn’t posted its 2026 dates yet (checked ). Approval stays Apple’s decision.

“Very responsive, attentive to fixing bugs, and completed the project as needed! Thank you!”
A buyer in the United States, July 2022. Shopify on Fiverr
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Related: App Store Guideline 5.1.1 · App Store Guideline 1.4.1 medical apps · App Store Guideline 1.5 developer information · App Store Guideline 5.1.5

Questions

More on this rejection

Should I reply to App Review or appeal?

Reply first. Apple says you can correspond with App Review in App Store Connect to resolve the issues before resubmitting, which is the place for a demo account, a screen recording or an explanation. Appeal to the App Review Board only if you believe App Review misunderstood the app or treated you unfairly. Apple allows one appeal per rejected submission and asks for specific reasons the app complies.

Which fields count as highly regulated?

Apple’s examples are banking and financial services, healthcare, gambling, legal cannabis use, air travel and crypto exchanges, plus apps that require sensitive user information.

Can you fix it for me?

Yes, through the App Fix Ticket: you send the rejection message and access to the app, Simon writes a diagnosis of what App Review hit and how to fix it, then fixes the code so you can resubmit. Each step has a fixed price, paid upfront. Approval stays Apple’s decision; the ticket covers the fix.

A different error?

Describe it and get a written quote

Send the error and what you were doing. You get a written scope, a fixed price and a timeline; Simon replies by email, usually within one business day.

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