Cannot pass App review with new account deletion requirements.

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Level 1

5 points

Cannot pass App review with new account deletion requirements.

Hello, community!

Each attempt to check the application ends in rejection with the same response.

Starting June 30, 2022, apps submitted to the App Store that support account creation must also let users initiate deletion of their account within the app.

(Offering account deletion in your app - Support - Apple Developer)

We have a bank app that operates in a highly regulated environment and immediate deletion of accounts and all data is not always possible.

The app has a button, which initiates a message to our Customer Support team to delete the account.

However, we can't just delete a bank account by tapping the button, users may have opened accounts and cards with funds.

We tried to explain it to Apple, but the same answer:

- Your app only offers to deactivate the account. Temporarily deactivating accounts is not sufficient to meet the account deletion requirement.

The process for initiating account deletion must provide a consistent, transparent experience for App Store users.

What can we do? Who has had a similar experience? Maybe we don't understand the new rules correctly?

iPhone 12

Posted on Jul 10, 2022 11:48 PM

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Answer 1

Top-ranking reply

-Bubba-

Level 6

10,974 points

Jul 11, 2022 12:30 AM in response to baladai

I found this in the FAQ of the article you linked-

Can I direct users to a customer service flow to complete account deletion?

It depends. Apps in highly regulated industries, as described in App Store Review Guideline 5.1.1(ix), may use additional customer service flows to confirm and facilitate the account deletion process. Apps not operating in highly regulated industries should not require people to make a phone call, send an email, or go through other support flows.

In your question, you stated that your app "operates in a highly regulated environment". It would seem that either this needs to be declared, or your app doesn't meet the additional criteria in the App Store Review Guideline 5.1.1(ix).

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Answer 2

baladai Author

Level 1

5 points

Jul 11, 2022 1:47 AM in response to -Bubba-

Thanks for your answer, our response included the text:

"...When a user clicks on the button, we initiate a message to our Customer Support team and they initiate the closure internally and guide the user through the process. The button triggers a manual process because FINOM operates in a highly regulated environment and immediate deletion of accounts and all data is not always possible. This scenario is described in your documentation: Deadline for in-app purchase and account deletion requirements extended - Latest News - Apple Developer

"Apps in highly-regulated industries may need to provide additional support flows to confirm and facilitate the account deletion process."

..."

I think this answer satisfies Guideline 5.1.1(v)

About your mention of paragraph (ix)- thanks, I will research it and try to include this in the next answer. But i think it won't be helpful because they refer to the paragraph 5.1.1(v), not 5.1.1(ix):

(v) Account Sign-In: If your app doesn’t include significant account-based features, let people use it without a login. If your app supports account creation, you must also offer account deletion within the app.

...

(ix) Apps that provide services in highly-regulated fields (such as banking and financial services, healthcare, gambling, legal cannabis use, and air travel) or that require sensitive user information should be submitted by a legal entity that provides the services, and not by an individual developer. Apps that facilitate the legal sale of cannabis must be geo-restricted to the corresponding legal jurisdiction.

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Answer 3

Jul 11, 2022 8:43 PM in response to baladai

Our App was rejected by Apple for the same reason.

Unfortunately we are a regulated FinTech company and cannot/would have a difficult time supporting such a feature. We responded to the rejection but haven't heard back from the App Review team in over 36 hours.

Maybe others are having this issue as well?

The rollout of these App Store policy changes doesn't seem well thought out. How were apps that operate in "highly regulated industries" with real legal constraints to implementing the "Account Deletion" feature supposed to tell Apple about this ahead of time?

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Answer 4

baladai Author

Level 1

5 points

Jul 12, 2022 6:29 AM in response to northernCardinal

Hi! We wrote another (4th!) answer with a full description, but got another rejection with the text:

"Can you please cite the specific laws (and point to the specific portion) that apply to why you are not able to delete an account from within the app."

I really don't understand why I have to prove that we can't just delete a bank account by the only button tapping. Apple makes up rules that are far from reality and demands to follow them. Or maybe the reviewers don't fully understand the new rules.

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Cannot pass App review with new account deletion requirements.

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