Apple Has Again Extended the Deadline to Meet New In-App Purchase and Account Deletion Requirements to June 30, 2022.
In 2020, Apple, as a result of the COVID-19 pandemic, deferred compliance with App Store Review Guideline 3.1. This requires apps offering paid online group services to do so via in-app purchase. Apple has extended the deadline again to June 30, 2022. The troublesome requirement for some app makers has been Guideline 3.1.3(d).
3.1.3(d) Person-to-Person Services: If your app enables the purchase of real-time person-to-person services between two individuals (for example tutoring students, medical consultations, real estate tours, or fitness training), you may use purchase methods other than in-app purchase to collect those payments. One-to-few and one-to-many real-time services must use in-app purchase.
Another extension has been provided for App Store Review Guideline 5.1.1. Many developers are having difficulty meeting the original deadline of January 31, 2022, due to the complexity of implementation. This new provision is designed to provide users with greater control over their personal data. It requires all apps that allow for account creation to also allow users to initiate deletion of their account from within the app. The new deadline for compliance is now June 30, 2022.
Apple’s guideline suggests you keep the following requirements in mind when updating your app:
The account deletion option should be easy to find in your app. It’s insufficient to only provide the ability to temporarily disable or deactivate an account. People should be able to delete the account along with their personal data. Apps in highly-regulated industries may need to provide additional support flows to confirm and facilitate the account deletion process. Follow applicable legal requirements for storing and retaining user account information. This includes complying with local laws in different countries or regions. As always, check with your legal counsel.
Of course I fully agree with all of these suggestions. This is the kind of thing that my new firm at Losey.law routinely does for a number of developers.