RTFP

Apple’s App Review team is responsible for taking decisions on whether to restrict or remove apps published on the App Store. The App Review team evaluates all new apps and app updates to ensure compliance with the App Review Guidelines. If necessary, the App Review team will work with the App Store Legal team to resolve legal issues that arise in the content moderation process. Where an issue cannot be resolved by the App Review team or the App Store Legal team, the matter will be escalated to the Executive Review Board (ERB). The ERB is composed of senior leaders who have ultimate decision-making responsibility regarding access for apps to the App Store. App ratings and reviews, including developers’ responses to reviews, are moderated by the Trust and Safety Operations team. Concerns regarding app ratings and reviews raised using the ‘Report a Concern’ function are initially reviewed by the AppleCare team (which is trained by the Trust and Safety Operations team). Where necessary, due to the nature of the content identified, the AppleCare team escalates content to the Trust and Safety Operations team. The Trust and Safety Operations team will, if necessary, work with Apple’s Global Security Investigations team for further action, which may include alerting law enforcement. The team responsible for content moderation of Apple Ads is the Apple Ads Policy team. The Apple Ads Policy team works closely with all teams in the Apple Ads business (including product, policy and marketing teams). When necessary, it also works with the Apple legal teams, particularly the Apple Ads Legal team. The Apple Ads Policy team reports into the Apple Ads Product and Operations team, which in turn reports into Apple Ads leadership.

Apple has a number of metrics in place to measure exposure to illegal or incompatible content during the reporting period. The methods that Apple uses to detect illegal or incompatible content and their resulting actions are summarised in the response to question 1 above. Apple has in place the following metrics which track users’ exposure to illegal or incompatible content: 1. Total number of downloads of apps that were removed during the reporting period : 135,262,149 2. Total number of impressions for ads that were removed after publication during the reporting period because they contained illegal or incompatible content: 7,205,214 3. Total number of reviews removed after publication during the reporting period: 1,087,552. This represents 9.6% of all reviews removed during this period. The remainder were removed before publication. These figures are all specific to EU storefronts.

Apple employs the following methodologies to compute the number of human resources dedicated to content moderation: - App Review team: the number of employees who perform content moderation on apps. - Trust and Safety Operations team: the number of employees who work on trust and safety issues for at least 50% of their time. - Ad Certification Team: the number of employees who performed content moderation on ads. - IP Disputes Team: the number of employees who performed content moderation in connection with IP disputes. All figures are calculated as of the final date of the reporting period (in this case December 31, 2025). These figures are added up to compute the total number of human resources dedicated to content moderation.

Apple has rigorous recruitment procedures in place to ensure that all staff dedicated to content moderation have appropriate qualifications. App Review team candidates are also subject to language aptitude testing as part of their application process or are tested on their language skills in interview. If necessary and appropriate, candidates are asked to demonstrate their understanding and knowledge of relevant cultures and cultural sensitivities.

Apple does not use fully automated means for moderating apps, Apple Ads or ratings and reviews on the App Store. All content moderation (namely all content moderation that results in content being removed or a user account being terminated or restricted) is subject to human review or is based on determinations made by a human reviewer.

Apple is continually developing and improving the automated tools that it uses to assist with its own initiative content moderation. Apple uses automated tools developed to detect malware or bait-and-switch apps that change their functionality after approval by App Review. It also employs automated tools that scan user reviews of published apps to identify concerns raised by consumers that may indicate that apps contain content incompatible with applicable law or terms and conditions. These tools are continually trained and enhanced to address new and emerging threats and to factor in learning from human-based decision-making. Any apps flagged as potentially problematic by these automated tools are escalated to human App Review specialists. These specialists then determine whether the apps violate App Store terms and conditions and, if so, what action to take — for example, app removal. No such actions are taken solely on the basis of automated tools. Similarly, Apple uses some automated tools to assist with moderating Apple Ads, but final decisions regarding content moderation are taken by humans. Apple also uses a combination of automated and human review to moderate ratings, reviews and developer responses. Automated tools are used to flag reviews with potential concerns for human moderators to consider. In other instances, human reviewers detect or are alerted by developers and customers to published reviews that contain new patterns of illegal content or content that doesn’t comply with the AMS Terms and Conditions. In these circumstances, human reviewers may run automated queries to detect and remove other published reviews that contain such content. Because these actions are only taken by human reviewers or based on decisions made by human reviewers, considerations of the accuracy or error rate of such automated tools do not arise or are inapposite.

As set out above at question 4, the main safeguard Apple applies to its use of automated tools is human review. No content moderation decision which results in content removal or user account termination or restriction is made using solely automated means.

As set out at questions 1 and 3, Apple uses automated means to: - monitor published apps, which includes scanning apps to detect malware and potential bait and switch apps; - monitor account and advertiser actions for signs of potential misconduct relating to Apple Ads advertising; and - monitor ratings, reviews and developer responses to identify reviews that violate the law or App Store terms and conditions; this includes checking for new fraud patterns.

Apple’s own initiative content moderation applicable to the App Store is described in detail in its First, Second and Third Reports on Risk Assessment and Risk Mitigation Measures prepared by Apple to comply with its obligations under Articles 33, 34 and 35 DSA (“DSA Risk Assessments”). The DSA Risk Assessments are publicly available here: https://www.apple.com/legal/dsa/ie/. By way of a high-level summary, during the reporting period, Apple has engaged in own initiative content moderation with respect to the following when published on the App Store: 1. apps and related product page information; 2. Apple Ads; and 3. users’ ratings and reviews of apps and developers’ responses to user reviews. Published Apps Before they’re published on the App Store — that is, before becoming subject to any content moderation decisions — all apps and app updates are subject to automated review and human review. After publication, Apple uses a combination of automated tools and human review to moderate published apps. Apple is continually updating its automated processes to detect apps that exhibit malicious or other problematic behaviours after they have been made available in the App Store. These apps are then reviewed by human app reviewers to evaluate whether intervention is needed. Apps that contain illegal content or content that is incompatible with the App Review Guidelines, Apple Developer Agreement or the Apple Developer Program License Agreement will be restricted or removed. Apple Ads Apple Ads enables developers to promote apps that have already been approved by App Review. Therefore, the ads do not contain “new” content that requires content moderation. Nonetheless, before they’re published on the App Store, ads are reviewed to ensure that they comply with Apple’s Advertising Policies. Apple will moderate ads after they’re published if it becomes aware that they’re in breach of Apple’s Advertising Policies. Some automated tools are used to assist with moderating ads, but final decisions regarding content moderation are taken by humans. Ratings, Reviews and Responses from Developers Apple uses automated tools to ensure that reviews or responses that contain certain types of content — such as spam, fake reviews or profanity — are prevented from being published on the App Store. Apple also has a number of automated processes that assist with post-publication content moderation for ratings, reviews and responses. All user ratings and reviews must comply with the Submissions Guidelines in the Apple Media Services (AMS) Terms and Conditions. All developer responses must comply with the Developer Code of Conduct in the App Review Guidelines, as well as with the DPLA. Responses that do not comply can also be removed from the App Store. Any content flagged via “Report a Concern” is subject to further human review. In addition to removing apps, ads, ratings, reviews and response from developers, Apple’s content moderation can also result in a user or developer account being terminated or restricted.

As a preliminary matter, it is important to emphasise that the nature of content moderation performed by Apple on the App Store differs materially from moderation conducted on social media platforms. In contrast to moderators on social media, App Store reviewers are not routinely exposed to disturbing or traumatic content. Nonetheless, Apple takes the safety, well-being, and mental health of its content moderation personnel extremely seriously. All teams responsible for content moderation, including App Review specialists and personnel moderating Apple Ads, have access to counselling and therapy resources. Apple also maintains a dedicated, centrally administered wellness resource designed specifically to support employees who may encounter potentially traumatising material as part of their work. This resource is structured as a tiered programme, with levels of support allocated according to the needs and risk profiles of the relevant teams. It operates alongside and in addition to Apple’s standard employee wellness offerings. The Trust and Safety Operations team, which is the primary team that moderates ratings, reviews and developer responses, has access to the highest tier of support. This means that all managers and designated employees receive training on and support for vicarious trauma. Managers in the team also receive additional training on how to support, engage and identify potential mental health risks arising from content moderation.

All App Review specialists receive comprehensive training when they join the App Review team. This training is supplemented by ongoing training to ensure that specialists remain informed of new and emerging threats and issues. They have access to senior App Review specialists for guidance and can escalate issues internally, including to the App Review Board. Personnel also receive ongoing language and cultural sensitivity training and support to recognise specific issues, trends and concerns. Personnel charged with moderating published Apple Ads content receive comprehensive training when they join the team. This training is supplemented by ongoing training to ensure that personnel remain informed of new and emerging threats and issues. The personnel responsible for moderating user ratings and reviews and developer responses both before and after publication on the App Store receive comprehensive training at onboarding. This training is supplemented by ongoing training to ensure that personnel remain informed of new and emerging threats and issues.