On 16 October 2026 Apple published updated App Review Guidelines and a second note strengthening them against two things: nonconsensual intimate imagery, and “bait-and-switch” apps. Both matter to anyone commissioning an iOS app, and the second is easy to trip over by accident.
What Apple says changed
- Rule 2.5.19 (new) clarifies the policy on hidden, dormant or undocumented features. Apps must not misrepresent what they do during App Review and then change after approval, for example by adding features that were not in the submitted version. Apps found doing this can be removed from the App Store and from the Apple Developer Program.
- Rule 1.2 now explicitly covers nonconsensual intimate imagery, including imagery generated with AI tools. Apps must proactively prevent and remove it. Apps that host user-generated content must filter objectionable material, offer a way to report it, and let users block abusive accounts.
- Rule 2.3.14 (new) covers creative assets. Apple’s announcement does not describe the requirements, so read the guideline text itself.
- Rule 3.1.1(a) was tidied: links may be provided to a permitted destination.
Translations of the guidelines follow within a month. Apple did not give a separate effective date; the guidelines are live as published.
Why this catches fast-moving teams
Teams that ship quickly, particularly with AI coding tools, often switch features on after launch: a remote-config flag, a server-side toggle, a new AI feature behind a login. If that feature was not in the build Apple reviewed, it is exactly what 2.5.19 describes. The penalty is not a rejected update. It is losing the developer account.
So what
Ask your supplier three things. Is everything the app can do disclosed in the review submission, including features that are switched off today? If the app lets users generate or upload images or text, what moderation and reporting is built in? And who owns the Apple Developer account, you or them? That last one decides who carries the risk if the account is ever threatened.
We build and submit iOS and Android apps with the release notes and review disclosures treated as part of the product, not an afterthought. If you are planning an app and want it to clear review first time, start a project.