Guideline 3.1.2: Privacy Policy & EULA Links Fix

Your subscription app came back with "Guideline 3.1.2 - Business - Payments - Subscriptions" and a note that the submission "did not include all the required information," pointing at your privacy policy or Terms of Use (EULA) links. The frustrating part: the links are usually already in the app. This guide explains exactly where Apple looks, why "present" is not the same as "functional and in both places," and how to reply. A hosted, login-free privacy policy URL removes half the failure modes → privacy policy page generator.

This is practical guidance for developers, not legal advice.

When Guideline 3.1.2 applies

Guideline 3.1.2 governs auto-renewable in-app purchase subscriptions. If you sell any auto-renewable subscription, the requirements apply regardless of app category. They do not apply to a one-time non-consumable unlock or a consumable purchase, though those have their own rules. The current text is on Apple's site: developer.apple.com/app-store/review/guidelines. The underlying contract obligation is in Schedule 2 of the Apple Developer Program License Agreement, section 3.8(b).

The two places the links must live

Apple requires functional links to both a privacy policy and a Terms of Use (EULA) in two separate locations:

In the app binary. The links must be reachable from the app's UI. In practice reviewers expect them on or one tap from the subscription screen (the paywall), and it is common to also place them in Settings.
In the App Store Connect metadata. The privacy policy goes in the dedicated Privacy Policy URL field under App Privacy. The EULA goes either in the standard-EULA slot (if you use Apple's) or, for a custom EULA, in the EULA field under App Information — and Apple's long-standing guidance is to also put the Terms of Use link in the App Description.

A rejection happens when the links exist in one location but not the other: for example, links on the paywall but no Terms of Use link in the App Description, or a privacy policy URL in App Store Connect but no in-app link.

What "functional link" actually means

"Functional" is doing a lot of work in the rejection message. A link fails the test when it is:

Not tappable — the URL is printed as plain text the user cannot tap, instead of a real link or button.
Broken — returns a 404, times out, or is unreachable from the reviewer's region.
Gated — opens a page that requires login, a cookie-consent wall that blocks content, or a PDF that will not render.
Dead in the binary — the in-app button opens a blank web view or an app that immediately dismisses.
Wrong document — the "Terms of Use" link actually points to the privacy policy, or both point to the same page.

Test every link on device, on cellular, with a fresh install, before resubmitting.

Apple's standard EULA vs a custom one

You have two choices for the Terms of Use:

Apple's standard EULA. Link to https://www.apple.com/legal/internet-services/itunes/dev/stdeula/ from your App Description and from inside the app. You do not paste anything into the custom EULA field. This is the simplest route and reviewers accept it.
A custom EULA. You must paste the full text into the custom license agreement field in App Store Connect (developer.apple.com/help/app-store-connect/manage-app-information/provide-a-custom-license-agreement) and host it at a public URL you link from the app and the App Description. A frequent mistake: hosting a custom EULA on your site but leaving the App Store Connect field empty, so the reviewer sees no EULA in metadata.

Whichever you pick, the privacy policy is always your own document at your own URL. Generate one here: /privacy-policy-page-generator.

The required disclosure near the purchase button

Guideline 3.1.2 and Schedule 2 require that before the user subscribes, the subscription screen clearly shows all of the following, adjacent to the purchase control:

The title of the subscription and what the user gets.
The length of the subscription period (for example, one month).
The price, and the price per unit if that is not obvious (for example, "$59.99/year ($5.00/month)").
A plain statement that payment is charged to the Apple Account at confirmation of purchase.
That the subscription auto-renews unless it is turned off at least 24 hours before the end of the current period, and that the account is charged for renewal within 24 hours before the end of the period.
That the user can manage or cancel in Account Settings after purchase.
Functional links to the privacy policy and Terms of Use.

A missing renewal-terms sentence or missing per-period price triggers the same "did not include all required information" rejection, even when the legal links are fine. See Apple's subscription best practices: developer.apple.com/app-store/subscriptions.

Why reviewers flag this even when the links are there

The most common reasons a "links present" app still gets 3.1.2:

Links are in Settings but not reachable from the paywall the reviewer tested.
Terms of Use link is in the app but not in the App Description text.
Custom EULA is hosted but the App Store Connect EULA field is empty.
Privacy policy URL field in App Store Connect is blank (the team assumed the in-app link was enough).
The link opens a page that fails to load for the reviewer (region, login wall, expired certificate).
Only one of the two documents is linked; the other is missing entirely.
The renewal-terms disclosure text is absent from the subscription screen.

Pre-submission checklist

Privacy policy at a public HTTPS URL, no login, loads on cellular.
Same privacy policy URL in App Store Connect > App Privacy.
Privacy policy link tappable on the subscription screen and in Settings.
Terms of Use: either Apple's standard EULA URL or a custom EULA pasted into App Store Connect and hosted publicly.
Terms of Use link tappable on the subscription screen and in Settings.
Terms of Use link added to the App Description.
Subscription screen shows title, length, price, per-period price, auto-renew terms, and cancellation info next to the buy button.
Every link tested on a fresh install, on device.

Reviewer reply template

Hello App Review team,

Thank you for the feedback under Guideline 3.1.2.

Both required legal links are functional and present in the binary and in
the App Store Connect metadata:

Privacy Policy
  - In app: Subscription screen (below the "Subscribe" button) and
    Settings > Legal > Privacy Policy. Both are tappable links.
  - URL: https://example.com/privacy (public, no login).
  - App Store Connect: App Privacy > Privacy Policy URL field.

Terms of Use (EULA)
  - In app: Subscription screen (below the "Subscribe" button) and
    Settings > Legal > Terms of Use. Both are tappable links.
  - URL: https://www.apple.com/legal/internet-services/itunes/dev/stdeula/
    (we use Apple's standard EULA).
  - App Store Connect: linked in the App Description, final paragraph.

Subscription disclosure
  - The subscription screen states, next to the purchase button: product
    title, length (1 month / 1 year), price and price per period,
    "Payment is charged to your Apple Account at confirmation of purchase,"
    the auto-renewal and 24-hour cancellation terms, and how to manage
    the subscription in Account Settings.

Steps to reproduce: launch the app, tap "Upgrade" on the home screen,
the subscription screen with all disclosures and both links is shown.

Build: [version] ([build number])

Please let us know if any location still needs adjustment.

Guideline 3.1.2 Rejection: Privacy Policy & EULA Links "Missing" (2026)