Apple’s New “Third‑Party AI” Rule: Your 7‑Day iOS Compliance Plan for 2026

Apple updated its App Review Guidelines in November 2025 to require apps to clearly disclose when personal data will be shared with third‑party AI and to obtain explicit permission before doing so. If your iOS app sends user data to external AI APIs (OpenAI, Anthropic, Google Gemini, xAI, etc.), this change affects you—immediately.

Why it matters now: AI has gone mainstream on mobile—ChatGPT was Apple’s most downloaded U.S. app of 2025—and even browsers are turning into AI surfaces (Gemini in Chrome). If you ship AI features, you need consent flows, policy language, and kill switches that match Apple’s new bar.

This guide gives founders a practical, 7‑day plan to get compliant without derailing your roadmap.

What counts as “third‑party AI” under Apple’s rule?

Any external AI vendor that receives personal data (PD) or personal data in context (voice, photo, video, chat logs, location, identifiers).
Cloud inference that leaves the device—even if you do on‑device steps first.
Model providers embedded via SDK (e.g., speech, vision, transcription, RAG) if PD can reach their servers.

If you only run fully on‑device inference and never transmit PD off device, you’re outside the scope. The moment PD can flow to a vendor’s servers, you need disclosure and permission.

Your 7‑Day Compliance Plan

Day 1 — Map data flows and vendors

Inventory every feature that touches AI. For each one, list: data types, destination endpoints, regions, retention, and purpose.
Tag flows as on‑device, your cloud, or third‑party AI. Add screenshots of the user journey.
Create a one‑page diagram you can hand to App Review.

Tip: If your team uses browser plug‑ins or agent tooling, lock those down—see our 7‑day hardening plan after a recent extension incident: Chrome Extension Harvested AI Chats.

Day 2 — Ship just‑in‑time consent UX

Gate each AI feature behind an opt‑in screen that names the provider(s) and data types.
Use plain language: what you’ll send, why, retention basics, and a “Learn more” link.
Default to off. Respect opt‑out per feature. Offer “on‑device only” where feasible.

Sample copy (edit to fit): “To summarize this call recording, we can send your audio to [Provider] to generate notes. This may include your name and meeting context. Approve?”

Day 3 — Update your Privacy Policy

Add a Third‑Party AI section naming providers, data categories, purposes, locations, retention, and your DPO/contact.
Link to each vendor’s policy and data‑processing terms.
Describe user controls: revoke consent, delete data, and on‑device alternatives.

Also align with the broader compliance climate (see: State AGs’ chatbot scrutiny and the U.S. AI Executive Order).

Day 4 — Engineer for consent: switches, scopes, and fallbacks

Build a consent gate in your app logic: no share to vendor if not opted in.
Offer graded modes: On‑device only → Your API (pseudonymized) → Third‑party AI (full context).
Use a server‑side proxy to: strip identifiers, rotate keys, enforce egress allow‑lists, and log requests without payloads.
Add a global kill switch to disable any AI vendor at runtime if policies change or incidents occur.

Day 5 — Logging and audit readiness

Store consent events (feature, version, timestamp, provider) and surface them in‑app under “Privacy & AI.”
Log vendor calls without PD. Capture request type, route, region, and latency.
Pin TLS where supported; enforce IP allow‑lists; alert on drift from declared regions.

Bonus: create red‑team prompts and abuse tests for your AI features; our agent evals guide shows how to get started in a week.

Day 6 — App Review checklist and QA

Record 2–3 screen‑recordings: first‑run consent, settings toggle, “Learn more” page.
Ensure the consent screen appears before any data leaves the device.
Verify your age gates and parental controls if minors may use the feature.
Prepare your Review Notes with your one‑pager diagram and links to policy.

Day 7 — Ship comms that build trust

Changelog: “New controls for how your data interacts with [AI Provider].”
In‑app “Why this permission?” explainer with a 60‑second overview.
Support macros for refunds, data deletion, and consent questions.

Design patterns that help you pass review

On‑device first: Try on‑device summarization/transcription; escalate to cloud opt‑in for better accuracy.
Scoped sharing: Only send what the model needs—e.g., an audio snippet, not the entire call.
Regional routing: Let users pick U.S./EU processing; respect it end‑to‑end.
Provider clarity: Name the vendor in the UI (not just “AI”).

Edge cases founders ask about

“We only send telemetry.” If telemetry can identify a person or session context (voice clip length, device ID, location), treat it as PD and disclose.
“We pseudonymize IDs.” Great—still disclose the flow and purpose, and let users opt out of vendor processing.
“We cache prompts for quality.” Tell users how long, where, and why; give them a way to purge.
“It’s a one‑tap share sheet to an AI app.” If data leaves your app via OS share, you’re safer—but if you invoke vendor APIs directly, you own the consent.

Copy/paste templates

Settings > Privacy & AI

“Send transcripts to [Provider] to generate action items.” Off by default.
“Use [Provider] for image descriptions.” Link: Data types sent.
“Process in the U.S. only.” Note regional coverage.

Policy snippet

“We offer optional AI features powered by partners like [Provider]. With your permission, we may send audio, images, or text you select to those services solely to perform the requested task. We do not allow partners to use your content to train their models unless you opt in.”

How strict is this going to be?

Apple’s language makes two things clear: you must name the data destinations (including third‑party AI) and get affirmative permission before any sharing occurs. Treat it like camera or location prompts—just for AI data flows. Here’s the coverage that flagged the change: TechCrunch on the new guideline.

Founder checklist (print this)

List all AI features and vendors; mark data types and regions.
Ship just‑in‑time consent screens; default off.
Update Privacy Policy with a Third‑Party AI section.
Enforce consent in code; add kill switches and proxies.
Log consent and vendor calls (no PD in logs).
QA with recordings; prep Review Notes + diagram.
Publish clear release notes and in‑app explainers.

Need help doing this in a week?

HireNinja ships governed AI features fast: consent UX, vendor policy mapping, privacy‑first prompts, and server‑side proxies with kill switches. If you’re already mid‑review—or just had a rejection—book a quick triage and we’ll help you pass without neutering your product.

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