Want to list your Web3 application on the Apple/Google App Store? First, get through these hurdles!

Attention all Web3App project parties: In 2025, Apple and Google are "tightening" their listing policies for Web3 applications. The main point is very straightforward — Apple side: Features with trading/investment attributes can only be opened in countries/regions where licenses are held, and such Apps should, in principle, be submitted by financial institutions. Google Play side: Exchanges/custodial wallets are licensed one by one according to the target country; although non-custodial wallets are not within the scope of this special policy, they are still subject to local regulations and may be required to provide additional materials; the countdown to entering the EU market has begun, starting from 2026-07-01, only CASP authorization under the MiCA system will be recognized. Do not overlook process details: all Apps must declare financial functions; any involvement with tokenized digital assets/NFTs must be transparently disclosed and cannot have a "guaranteed profit/high yield" narrative, and compliance materials may be requested at any time during the review. Today, this article will discuss four things from a practical perspective: (1) Summary of the key points of the latest listing rules from Apple/Google; (2) Which scenarios require a license and when a legal opinion may be requested; (3) Compliance strategies for listing different Web3 applications; (4) The "three-piece set" we can deliver for listing. The "red line and yellow line" of the two major stores 1.Apple (App Store Review Guidelines) 3.1.5 Cryptocurrency Terms: Wallet: Can be used for virtual currency storage, but must be submitted by the organization developers; Mining: Device-side mining is prohibited; Exchange: Can only be provided in countries/regions with the appropriate licenses; ICO/Futures/Securities-like: Must come from banks/brokerages/FCMs or other approved financial institutions, and comply with the law. 3.2.1(viii): Financial transaction/investment/wealth management Apps must be submitted by the financial institution executing the service, and must have the necessary licenses in the listing area. The official page was last updated on 2025-06-09. 2.Google Play (Policies and Reporting) "Cryptocurrency Exchanges and Software Wallets" Policy: Non-custodial wallets: not within the scope of this special policy (still subject to the local method); Process: Declared in the Financial Function Declaration in the Play Console; If the target country is on the list, the system will send you a regional form asking you to fill in/upload local license or registration information; Non-compliant to remove the country's targeting; EU: From 2026-07-01, only MiCA CASP authorization will be accepted; France and Germany had transitional arrangements before that. Blockchain content and NFTs: The existence and use of "tokenized digital assets" must be transparently disclosed; Do not advocate "making money"; NFT lottery/gambling is restricted; Google may require additional compliance documentation to demonstrate compliance in your target region. Financial features declaration; All listed apps must complete this declaration; If "Crypto Wallet/Exchange/NFT, etc.", you need to disclose each item according to the guidelines and may upload licenses/supporting evidence. When is a "license" absolutely necessary? When might a "legal opinion letter" be required? (1) High certainty scenarios that require a license From the implementation of each provision to practical experience, the following situation is basically equivalent to "first look at the license, then talk about the listing": Matching/Exchange/ATS, Custodial Wallet, Fiat Deposit/Withdrawal/Exchange, Securities/Derivatives/Yield Functions. Apple clearly requires that exchange functions be open only in licensed regions; Google verifies licenses for "exchange/custodial wallet" by country/region, and those that do not comply must be taken offline in that country. Below are Google's policies.

(2) The gray area where there is a high probability of being asked for supplementary materials/opinion letters Whether "it is mandatory to submit a lawyer's opinion letter" is not a rigid requirement that is consistently applied by both parties. However, in the following gray areas, the review team often requests "additional documents" to prove your legality in a certain region: Non-custodial wallet but with overlays: fiat on-ramp, yield display, brokerage aggregation, cross-border advertising placement. NFT/tokenized content triggers transparent disclosure and involves value games. Practical experience: store audits or compliance modules may require legal opinions/compliance explanations to substantiate "not triggering/held/with exemption," especially towards sensitive jurisdictions and financial promotion scenarios. Google policies also specify that additional information or documentation may be requested. In the above communication scenario, a legal opinion letter issued by a lawyer (providing conditional conclusions on "whether a license is triggered / whether an exemption applies / which regions are open") is widely accepted as a form of material. Different product forms of "listing strategies"

1. Non-custodial wallet / Pure on-chain tools Strategy: Emphasize the factual statement of "not holding funds/private keys"; only open in countries/regions with clear compliance; complete financial function declaration in Play Console and blockchain transparent disclosure; avoid any wording of "profit/investment commitments."
2. Custody/Fiat Deposit and Withdrawal/Broker Strategy: Launch first in regions with licenses/registration or clear exemptions, gradually open up other regions using geofencing and differentiated versions; prepare license proof/registration number/cooperation institution qualifications and (if necessary) legal opinions; for Apple, priority should be given to submissions from licensed entity developer accounts.
3. Exchange/ATS/Derivatives Strategy: Plan ahead for multi-jurisdictional licensing paths (such as EU MiCA CASP, US FinCEN MSB + state MTL/banking licenses, etc.) and implement regional switches and functional differentiation at the store end. The EU notes that starting from 2026-07-01, only MiCA will be recognized. 4.NFT/tokenized digital assets Strategy: Check and disclose tokenized digital assets in the Play Console; do not drive traffic with a "making money" narrative; if there are uncertain value elements like card draws/blind boxes/ wagering, it is basically not allowed. What can we do for you ("listing three-piece set") As a lawyer deeply involved in the Web3 industry, what can we do for the listing of your APP: The first step is diagnosis. We will use a compliance matrix of "Function × Jurisdiction × Store" to align your specific functions (whether custodial, whether matching, whether fiat/profit) with the target countries one by one, resulting in the four quadrants of "listing/required certification/needs to be fenced/not recommended." Output includes: "compliance version" copy with store strategy (listing regions and gray rhythm), metadata and screenshots, draft for financial function declaration and blockchain disclosure. These materials are for review reading as well as for internal product/operation execution. The second step is the legal opinion. For key legal domains, we conduct qualitative analysis based on facts and assumptions (functional boundaries, capital flows, KYC/AML processes, open regions) to answer three practical questions: whether a license is triggered, whether distribution in stores is possible, and what disclosures and restrictions are needed. The conclusion adopts a "conditional compliance" wording (for example: listing only in country A/meeting process B/under the premise of closing function C), and clearly reserves and specifies the scope of application to avoid misuse or extensive interpretation. When review communication requires "supporting documents," the legal opinion letter is one of the main materials. The third step is the compliance document package. This is a "toolbox" for implementing compliance in operations: ToS, Privacy (including cross-border and data residency), risk disclosure and prohibited areas, KYC/AML & CFT and sanctions screening SOP, client asset segregation and refund complaint mechanisms, key/custody and incident response, advertising and financial promotion compliance guidelines. For Google, we will prepare the licenses/registration numbers and qualifications of the partners required for the localized forms; for Apple, we will calibrate the submission entity and functional description to reduce the repetitions of "inconsistent entity" and "unclear functional description." Conclusion Please treat the listing as a "compliance project" rather than a "game of chance." Unclear functional boundaries, mismatched licenses and deployment regions, and incomplete supporting materials will all directly hinder the review process. It is recommended that you align these four aspects at once—Function → License/Registration → Store Declaration → Supporting Materials. First, launch in countries where it can comply with regulations, and then steadily expand according to the matrix. What we can do is to make this map concrete: diagnosis and matrix (can/cannot/how to open), legal opinion letter (conclusion + conditions + disclosure), document package and listing guidance (implementing requirements into the documentation and backend configuration). Compliance is a continuous action, and version updates and expansion areas need to be re-evaluated. If your Web3 application encounters issues with listing, please feel free to contact Attorney Mankun.

Original author: Lawyer Shao Jiadian