What is the DSA, briefly

The Digital Services Act is an EU regulation that governs how online platforms moderate content, verify sellers, and disclose information to users. For developers, the practical consequence is that Apple treats the App Store as a regulated marketplace. Any app made available to EU users — through the regular EU storefronts or any EU-resident Apple ID — must ship with verified seller information visible to the public.

This applies regardless of whether you charge for the app, and regardless of whether you consider yourself a "business." If you distribute in the EU, you comply.

Trader vs non-trader: which one are you?

Apple now forces every developer to declare themselves a Trader or Non-Trader before submitting to EU storefronts.

  • Trader — you are acting commercially. This includes anyone selling paid apps, running ads, offering in-app purchases, generating subscription revenue, or distributing apps on behalf of a business. Most developer account holders fall here.
  • Non-Trader — a strictly non-commercial hobby developer with no monetization of any kind, no ads, no paid offerings.

The safer declaration in almost all cases is Trader. Mis-declaring as Non-Trader and then monetizing will get the app pulled from EU storefronts with no warning.

The required fields checklist

Inside App Store Connect → Business → Trader Status, you will be asked for:

  1. Legal name of the trader. For an Individual account — your full legal name as it appears on your passport. For a Corporate account — the exact registered company name.
  2. Registered address. Street, city, postal code, country. Must match the address on your company registration certificate or, for Individuals, a utility bill / bank statement / tax document.
  3. Contact email. Must be a working, monitored mailbox. Apple and EU regulators can and will write to it.
  4. Contact phone number. Format: country code + number, in E.164 form. The number has to receive calls — Apple may phone-verify it during review.
  5. Trade register number. For companies, this is your national company registration number (Companies House, Handelsregister, ЄДРПОУ, etc.). Sole proprietors enter the equivalent national ID.
  6. VAT number (where applicable). If you're VAT-registered, add it. Mismatches between VAT number and company address are a common rejection reason.

Documents to have ready before you submit

  • Company registration certificate or sole-proprietor tax ID certificate, as a PDF scan.
  • Recent proof of address (under 3 months old) — utility bill or bank statement in the trader's name.
  • A passport or government ID of the legal representative.
  • For Corporate accounts: the board resolution or equivalent document naming the person authorized to bind the entity.

Apple rarely asks for these upfront but can request any of them during random spot-checks. Keep the folder ready.

Common rejection reasons

  1. Address mismatch. The App Store Connect address differs from the company registration on file. Fix both to match exactly, including punctuation.
  2. Unreachable phone. Apple called, got voicemail in a different language or a disconnected tone. Rejected.
  3. "Non-Trader" declaration on a monetized app. Automatic rejection.
  4. Blank trade register number. Apple used to accept "N/A" — now it doesn't for Trader submissions in most EU countries.
  5. Expired or invalid VAT number. Run the number through the EU VIES checker before saving.

Tips to clear DSA review on the first try

Keep the legal entity information identical across App Store Connect, your D-U-N-S record, your payment tax form (W-8BEN / W-9), and your company registration. Pick one canonical version of the name and address and replicate it character-for-character everywhere. That single alignment resolves the majority of DSA rejections.

If you bought a pre-verified Apple Developer account, the DSA trader fields should already be populated — but always verify them against the accompanying documents before submitting your first app.

Conclusion

DSA compliance is not optional for the EU market and it's not a form-filling exercise. Treat it as part of onboarding the account, not something you deal with on submission day. A clean trader profile makes every future submission faster.