Apple rejected my app under App Store Review Guideline 5 – Legal, citing local regulatory requirements in mainland China related to generative AI and deep synthesis technologies.
This rejection was not caused by a bug or implementation issue, but by regional legal compliance.
What Apple Flagged During Review
According to Apple’s review feedback, the app was associated with ChatGPT / OpenAI, which currently does not have the required permits to operate in China.
Specifically, Apple noted that:
- The app metadata referenced ChatGPT, GPT, or OpenAI
- These references appeared in places such as:
- App name
- Subtitle
- App description
- Promotional text
- Screenshots
Under local Chinese regulations, apps offering or referencing generative AI services must meet specific licensing and approval requirements.
Why This Is a Legal Issue (Not a Product One)
China has introduced increasingly strict regulations around Deep Synthesis Technologies (DST) and generative AI services.
To legally operate such services in China, providers must:
- Obtain required approvals
- Secure licenses from authorities such as the Ministry of Industry and Information Technology (MIIT)
Since ChatGPT does not currently hold these permits for operation in China, Apple requires apps associated with it to either:
- Disable the functionality for the China storefront, or
- Avoid distributing the app in mainland China altogether
Your Options as an App Developer
Apple outlined two possible paths forward:
Option 1: Remove China Distribution (Simplest)
You can choose not to distribute the app in mainland China by deselecting the China storefront in App Store Connect → Availability.
This allows:
- The app to remain available in all other regions
- No changes to core functionality or branding elsewhere
Option 2: Localize the China Version
If you want to distribute the app in China, you must:
- Remove all references to ChatGPT / OpenAI from metadata
- Disable related functionality in the China build
- Confirm these changes in the Review Notes
This option requires careful product and legal consideration.
What I Chose
In my case, the most practical solution was to remove mainland China from the app’s availability list.
This avoided:
- Fragmenting the product experience
- Maintaining separate compliance logic
- Introducing unclear user expectations in restricted regions
Product Takeaway
This rejection highlights an important reality for AI-powered products:
App Store compliance is not just about code or design—it is also about regional law and distribution strategy.
When building products that rely on generative AI or third-party platforms, distribution decisions may need to be made at the country level, not just globally.
Understanding these constraints early can prevent repeated review delays and unclear rejection cycles.
Resources
- App Store Review Guideline 5 – Legal
- App Store Connect: Managing App Availability
- Administrative Provisions on Deep Synthesis of Internet-based Information Services