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EU DSA Trader Status for App Developers: What to Declare

By Support URL Generator Team · Published

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The EU Digital Services Act treats almost anyone who earns money from an EU user as a "trader" — and a trader must put a real name, street address, phone number and email on the public store listing. This hits paid apps, apps with in-app purchases or subscriptions, and free apps that show ads or exist to promote a business. Both Apple and Google enforce it, and Apple has already pulled apps from the EU over it. Set up a support page and contact URL EU users can actually reach →

What the DSA "trader" rule actually is

The relevant text is Articles 30 and 31 of Regulation (EU) 2022/2065, the Digital Services Act, under the heading "traceability of traders." Any online platform that lets consumers conclude distance contracts with traders has to collect a defined set of identifying information from each trader, make best efforts to check it, and display it so consumers can see who they are buying from. The App Store and Google Play are exactly that kind of platform, so the obligation flows through them to you. The DSA has applied to all platforms of this type since February 17, 2024.

"Trader" is defined in Article 3(f) as "any natural or legal person, irrespective of whether a private or public entity, who is acting, including through a person acting in his or her name or on his or her behalf, for purposes relating to his or her trade, business, craft or profession." The opposite category is a genuine non-trader: a hobbyist or individual with no commercial purpose and no monetisation of any kind.

This is background on a regulation, not legal advice. If your situation is close to the line, get advice from someone qualified in EU consumer law.

Are you a trader?

For most people reading this the answer is yes. You are almost certainly a trader if any of the following is true:

  • The app has a purchase price, or any in-app purchase, subscription, or consumable.
  • The app shows ads through AdMob, AppLovin, Unity, Meta Audience Network, or any other network.
  • You earn affiliate or referral revenue through the app.
  • The app is published under a company, or it functions as a funnel to a paid product or service.

You are more likely a non-trader only if the app is genuinely non-commercial: no price, no ads, no in-app purchases, no business behind it. A free app with a single banner ad is still a trader app. Apple asks every account to declare a status even if you do not ship to the EU, so you cannot skip the question by geofencing.

The Apple timeline and the 2025 mass removal

Apple added the trader field to App Store Connect on October 16, 2024, and from that date trader information was required to submit new apps and app updates in the EU. Apple set a hard deadline of February 17, 2025 to declare a status and pass verification.

Starting February 18, 2025, apps without a verified trader status were removed from the App Store across all 27 EU member states. New submissions and updates for those apps were blocked, and EU users could no longer download or update them. App-intelligence firm Appfigures counted more than 135,000 apps disappearing from EU storefronts within roughly 30 hours — the largest single removal event in the store's history. Apps came back once the developer completed and verified the declaration. The same rule now applies to every new submission, so a missing declaration is a permanent block, not a one-time sweep.

Google Play's version

Google Play carries the same obligation. You declare trader status in Play Console under your payments profile and account details, supply the contact information, and Google verifies it. Non-compliant apps are not distributed to users in the European Economic Area. Google did not run a single dramatic purge like Apple's, but it enforces on submission and through periodic account checks, and the end state for a non-declared trader app is the same: no EU distribution. Microsoft and other stores that host paid content have equivalent flows.

What you must provide

The required fields differ slightly for an individual versus a registered organisation.

FieldIndividual developerOrganization
Legal nameYour full legal nameRegistered legal entity name
AddressHome address, or a P.O. Box / mailbox with proof you are associated with itAddress tied to your D-U-N-S Number
PhoneA working phone numberA working phone number
EmailA monitored email addressA monitored email address
D-U-N-S NumberNot applicableRequired; must be current
Trader registration numberIf you have one (commercial or trade register)If applicable in your jurisdiction
CertificationA statement that the app complies with applicable EU lawSame

Apple verifies the email and phone with a two-factor style check and reviews documentation for the name and address. For an alternate address such as a P.O. Box, Apple asks for a document — a bill or receipt — tying you to that address.

It becomes public

This is the part that surprises people. The name, address, phone number and email you submit are shown to EU users on your store listing — in the App Store's information section for the app and in Google Play's "about the developer" / contact area. It is not a private field held by the platform for dispute resolution; publication is the point of Article 30. When the requirement landed in October 2024 there was a loud reaction from solo developers who did not want a home address and personal phone number visible on every product page.

Options to limit personal exposure

None of these hide the information from the public. They let you publish a business identity instead of your household one.

  • P.O. Box or commercial mail-receiving agency. Apple explicitly permits a P.O. Box for individuals when you supply a document associating you with it. This is the most common fix for indie developers.
  • Virtual office address. A registered business address service gives you a real street address that is not your home.
  • Form a company. An LLC, Ltd, GmbH or similar lets you publish the company's registered office, and you get a D-U-N-S Number for the organisation account.
  • Dedicated contact channels. A VoIP business line and a role address such as support@yourapp.com instead of your personal mobile and email.

What does not work: leaving the fields blank, inventing an address, or selecting non-trader while the app is monetised. The platform is required to act on information that is "inaccurate, incomplete or not up to date."

False or missing declarations

A missing declaration removes the app from the EU and blocks updates until you fix it. A false declaration — claiming non-trader while running ads or in-app purchases, or supplying an address that does not check out — obliges the platform under Article 30(2) and (3) to request corrections and, failing that, to suspend the listing. Apple and Google can remove the app and suspend the developer account. Separately, misrepresenting your identity to consumers can create exposure under member-state consumer-protection law. Keep the details current: update them in the store when you move or change your phone or email.

What to do now

1. Decide trader vs non-trader honestly.
   Any price, IAP, subscription, ads, or business purpose = trader.
2. Individuals: open a P.O. Box or mailbox service; keep a bill or
   receipt that ties you to the address for verification.
3. Organizations: confirm your D-U-N-S Number is active and the
   address on it is correct (dnb.com).
4. Set up a monitored support email (support@yourapp.com) and a
   business phone line.
5. App Store Connect: Business section -> trader status -> complete
   all fields -> submit for verification.
6. Play Console: payments profile / account details -> trader status.
7. Clear the email and phone verification prompts.
8. Put the SAME name, address, phone and email on your in-app
   support page, your contact URL, and your privacy policy so the
   three match what the store displays.
9. Re-check the declaration after any address, phone, or email change.

Where this connects to your other store obligations

Store-verified identity is a direction of travel, not a one-off. Google's Android developer verification programme extends identity checks to every Android app, including sideloaded ones, and Apple has required a D-U-N-S Number for organisation accounts for years. The app store age verification laws push the same pattern into age signals. Your public contact point is now a compliance surface: the support page generator gives EU users a working way to reach you, and the privacy policy page generator keeps the identifying details you publish consistent across your policy and your listing. This article is practical guidance, not legal advice.

Related

Read Android developer verification 2026 for the identity-check deadline, app store age verification laws for the 2026 state map, Apple's Guideline 4.3(b) crackdown for what "looking like a real business" now means, the Google Play Data safety form walkthrough, and use the account deletion page generator and privacy policy page generator to keep your published contact details in sync.

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