The Guidelines as a Legal Document

Two Policies, One Commercial Reality

The App Store Review Guidelines and Google Play's Developer Policy Center are among the most consequential private regulatory documents in the global economy, yet neither was designed by lawyers for lawyers. Apple's guidelines, first published in 2010, have grown to cover everything from content age-ratings to cryptocurrency custody to the precise wording developers may use when describing their apps in external marketing. Google's equivalent — structured as a policy centre rather than a numbered rulebook — covers similar ground but is organised by harm category rather than by submission stage. The surface differences in drafting style obscure a deeper convergence: both documents are, in practice, take-it-or-leave-it contracts between a gatekeeper and the developers who depend on it, and both have become the subject of sustained legal scrutiny precisely because of that structural asymmetry.

Where the two documents agree most completely is in their treatment of safety and content. Both prohibit apps that facilitate child sexual abuse material, that promote illegal weapons modifications, or that enable non-consensual surveillance — provisions no regulator has challenged. Both require age-gating for mature content and mandate compliance with local law as a condition of distribution, a clause that has done quiet work in markets including South Korea, India, and Japan, where regulators have used it as a lever of their own. Both documents also agree, conspicuously, on the default payment architecture: developers must use platform billing for in-app purchases of digital goods and services, with commission rates set by the platform. It is this clause — not the safety provisions — that has generated the majority of litigation.

Where the Documents Diverge

The sharpest structural difference lies in how each document handles external payment links. Apple's guidelines, until recently, prohibited developers from including any link, button, or call to action directing users to a purchase option outside the App Store. That prohibition — the anti-steering clause — was the central commercial issue in Epic v. Apple, decided by Judge Yvonne Gonzalez Rogers in Oakland, California in September 2021. Gonzalez Rogers found Apple's conduct did not violate federal antitrust law but issued an injunction requiring Apple to permit developers to include a single external purchase link. Apple's subsequent compliance with that injunction became the subject of contempt proceedings in 2025, when the court found Apple had engineered its implementation — specifically a 27 percent commission on external purchases — to make the relief practically worthless.

Google's Developer Policy Center took a formally different posture after the December 2023 jury verdict in Epic v. Google, where jurors in San Francisco found Google had illegally maintained its monopoly in the Android app-distribution market. Judge James Donato's remedies order required Google to open its billing systems to third-party alternatives and to permit competing stores to be distributed through the Play Store itself — structural changes that go well beyond anything Apple has been ordered to implement. Google has contested the injunction on appeal.

Under the Digital Markets Act, the European Commission designated both Apple and Google as gatekeepers and imposed obligations that required each company to revise its published policies for EU users. Apple's March 2024 DMA compliance package introduced alternative app marketplaces, Apple's own notarisation requirement, and the Core Technology Fee — a €0.50 per-install charge on installs beyond one million annually — all of which are now embedded in a separate addendum to the standard guidelines that applies only within the European Economic Area. The Commission fined Apple €500 million in April 2025 for failing to meet its DMA obligations on steering, making the guidelines addendum itself the object of an enforcement record.

What Treating Them as Text Reveals

Read as policy documents rather than developer instructions, the guidelines share a common legal vulnerability: they are unilaterally amended by the platform, with changes taking effect on a schedule the platform sets, binding developers who have already built businesses on the previous version. The 30 percent commission is the most cited example, but the 15 percent Small Business Programme tier was introduced by the same mechanism — announced, implemented, and later replicated by Google without any negotiation with the developer community. Courts and regulators on three continents have now concluded that this structure of unilateral private rule-making, at the scale these platforms operate, warrants public law scrutiny. The guidelines did not invite that scrutiny; they produced it.