Apple updated its App Review Guidelines on November 13, 2025, requiring apps to disclose and obtain explicit user consent before sending personal data to third party AI. The change addresses mounting concerns about AI privacy and transparency, and it will affect mobile services across an installed base of roughly 1.8 billion Apple devices and an App Store that hosts about 2 million apps.

Background: Why Apple is tightening data flows to third party AI

Third party AI refers to externally hosted machine learning models and services that apps call for tasks such as natural language processing, image analysis, or personalized recommendations. The main privacy issue is clear: sending personally identifiable information or sensitive content to external models can expose users to retention, reuse, or model memorization unless developers apply privacy by design and clear disclosures.

Apple made this policy change amid growing scrutiny of how AI platforms are trained and how they handle inputs. Regulators and consumer advocates have raised concerns about unintended data retention, weak vendor compliance, and lack of meaningful user control. For Apple, which positions platform control and privacy at the center of its brand, stronger app review guidelines are a way to assert data governance and push for greater transparency.

Key findings and details

• Disclosure and user consent requirement: Apps may not share users personal data with third party AI unless they clearly disclose the practice and obtain explicit user consent through a consent UI or similar flow. This ensures users know when their inputs leave the app and how those inputs may be used.
• Developer impact: Teams must audit data flows, map where user data is sent, update privacy policy language, and implement consent UIs and logging to demonstrate compliance. This may require engineering work and legal review.
• Potential disruption: Services that rely on backend third party AI for core functionality could face interruptions or the need to rework architecture if they cannot meet the new disclosure and consent requirements quickly.
• Platform enforcement and regulatory ripple effects: Observers see the update as a signal that platform owners will enforce app privacy requirements more strictly. Similar rules from regulators and other app stores could follow, increasing pressure on vendor AI compliance and contractual terms.
• Timing and scale: Apple announced the change on November 13, 2025. Given the App Store scale, auditing and compliance will be a major effort for many developers.

Plain language note: explicit user consent means an affirmative, informed choice by the user for example a toggle or clear agreement that explains what data is shared who receives it and for what purpose rather than implied or prechecked options.

Implications for businesses and developers

• More compliance work: Developers must perform data mapping for AI inputs and outputs run privacy impact assessments and add consent tracking. These steps reflect best practices in AI governance and can help avoid privacy enforcement actions.
• Pressure on third party AI providers: Model vendors will face requests for clearer guarantees about data handling retention and training practices. Negotiations will focus on vendor compliance clauses and verifiable privacy enhancing technologies.
• Trust versus friction: Requiring explicit consent boosts user trust but adds friction. Products that used seamless behind the scenes AI may need to redesign onboarding or build layered transparency to surface consent without harming user experience.
• Business strategy: Smaller developers may favor on device models or managed platforms that advertise privacy guarantees while larger firms absorb compliance cost. Tokenized consent and revocable consent patterns are likely to gain interest as ways to balance control and convenience.
• Regulatory and market trends: Apple setting this standard could influence app store policy and broader regulatory frameworks. Companies should expect more spot checks on privacy policies and consent banners and plan preemptive privacy audits.

Practical steps for product teams

Businesses that embed AI into customer experiences should treat this update as an urgent operational task. Recommended actions include:

• Map data flows and identify which inputs are sent to third party AI
• Update privacy policies and produce clear in app disclosures that explain purpose recipients and retention
• Implement a consent UI that records explicit user consent and supports revocation
• Ask AI vendors for written commitments on data handling and whether inputs will be used to train models
• Explore privacy enhancing technologies and on device model options to reduce data sharing risk

Conclusion

Apple new App Review Guidelines mark a decisive step toward stricter platform level control of how apps use external AI. For developers and product managers the immediate priorities are to audit third party calls update privacy notices and add explicit consent mechanisms. In the broader market this move underscores a trend where AI privacy transparency and user consent become baseline expectations and where teams that combine strong privacy guarantees with smooth user experience are likely to win trust and competitive advantage.