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How to submit an app to Apple’s App Store when it uses encryption

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Re: How to submit an app to Apple’s App Store when it uses encryption

#11
post #3

Earlier quoted context omitted.

Are you sure HTTPS counts? That seems insane to me.

Back when I was doing hobbyist iOS development (2009-ish) I asked Apple developer support about this, and they said it does. Worst part is it doesn't matter if you use a built-in system library like NSURLSession. Simply accessing an HTTPS URL from inside your app triggers this requirement. Some people say the paperwork is easy to fill out yourself, but I was a college student and the legalese scared the crap out of m…

That cannot possibly be true. I guarantee you virtually every REST app in the store uses HTTPS and none of them went through all of this. In the latest version of iOS you can't even load HTTP by default and must use HTTPS unless you put a special exception in your Info.plist. Everybody uses HTTPS, and nobody has to go through any of this.

So either you asked the wrong question, misinterpreted the answer, or you simply talked to someone who didn't understand your question or otherwise just didn't know themselves.

Re: How to submit an app to Apple’s App Store when it uses encryption

#12
Not everything that "just uses HTTPS" necessarily needs ERN. Here's "note 4" which exempts a lot of apps: http://www.bis.doc.gov/index.php/policy-guidance/encryption/...

A big part of our app was "sending, receiving, and storing information", so we weren't sure this exemption would apply to us. So, we did the ERN anyway, and it took a couple of days calendar time, and a couple of hours of working time, IIRC.

By the way, nowhere does it say that using HTTPS is fine if you just use Apple's APIs and frameworks. I don't think it's relevant here.

Re: How to submit an app to Apple’s App Store when it uses encryption

#13
post #4
post #2

Last year I learned that to publish an app in the App Store or Mac App Store, if it uses encryption of any kind and yes, HTTPS and SSL count, you need an Encryption Registration (ERN) from the US Bureau of Industry (BIS). Some people claim it's fine to lie to Apple, claim no use of encryption and get in the app store. I'd rather do it the right way. When I started the process of getting the ERN, I quickly notice it w…

Were you using the built in web capabilities or embedding a library to handle the encryption? In theory Apple's methods for accessing HTTPS should be safe while embedding OpenSSL would not be (unless you linked to a shared object they deployed).

I don't think it matters where the encryption capability comes from.

The iTunes Connect FAQ says: “If your app uses, accesses, implements or incorporates industry standard encryption algorithms other than those listed as exemptions under question 2, you need to submit for an ERN authorization. Examples of standard encryption are: AES, SSL, https.”

There are a lot of exemptions, but only using Apple's HTTPS is not one.

Re: How to submit an app to Apple’s App Store when it uses encryption

#14
post #11

Earlier quoted context omitted.

Back when I was doing hobbyist iOS development (2009-ish) I asked Apple developer support about this, and they said it does. Worst part is it doesn't matter if you use a built-in system library like NSURLSession. Simply accessing an HTTPS URL from inside your app triggers this requirement. Some people say the paperwork is easy to fill out yourself, but I was a college student and the legalese scared the crap out of m…

That cannot possibly be true. I guarantee you virtually every REST app in the store uses HTTPS and none of them went through all of this. In the latest version of iOS you can't even load HTTP by default and must use HTTPS unless you put a special exception in your Info.plist. Everybody uses HTTPS, and nobody has to go through any of this. So either you asked the wrong question, misinterpreted the answer, or you simpl…

Thank you! It is definitely a misinterpretation. Apple makes https mandatory now and there is no way every developer would have to go through this process.

Re: How to submit an app to Apple’s App Store when it uses encryption

#15
post #2

Last year I learned that to publish an app in the App Store or Mac App Store, if it uses encryption of any kind and yes, HTTPS and SSL count, you need an Encryption Registration (ERN) from the US Bureau of Industry (BIS). Some people claim it's fine to lie to Apple, claim no use of encryption and get in the app store. I'd rather do it the right way. When I started the process of getting the ERN, I quickly notice it w…

I'm far from an expert on this area, but I know there are exemptions many apps can qualify for. The most notable of these is that the encryption is limited to authentication [1].

[1]: http://stackoverflow.com/questions/2135081/does-my-applicati...

Re: How to submit an app to Apple’s App Store when it uses encryption

#16
Great guide. If you are into these sort of guides of how to deal with the US government I have written a couple for the W8-BEN-E form [1] (you need this if you have any US customers) and also for registering to do business with the US government [2]. These are biased towards Australians, but they should be helpful for others too.

1. http://www.tillett.info/2015/06/20/how-to-complete-w-8ben-e-...

2. http://www.tillett.info/2015/12/01/how-to-register-an-austra...

Re: How to submit an app to Apple’s App Store when it uses encryption

#17
post #11

Earlier quoted context omitted.

Back when I was doing hobbyist iOS development (2009-ish) I asked Apple developer support about this, and they said it does. Worst part is it doesn't matter if you use a built-in system library like NSURLSession. Simply accessing an HTTPS URL from inside your app triggers this requirement. Some people say the paperwork is easy to fill out yourself, but I was a college student and the legalese scared the crap out of m…

That cannot possibly be true. I guarantee you virtually every REST app in the store uses HTTPS and none of them went through all of this. In the latest version of iOS you can't even load HTTP by default and must use HTTPS unless you put a special exception in your Info.plist. Everybody uses HTTPS, and nobody has to go through any of this. So either you asked the wrong question, misinterpreted the answer, or you simpl…

It's quite likely they don't enforce it very well.

I specifically asked them if using NSURLConnection (the standard, built-in URL library before NSURLSession) to access a URL over HTTPS qualified under the registration requirements. They told me, in no uncertain terms, that using any cryptography, including cryptography built into the operating system, meant I needed to register if I wanted to export the app outside of the US and Canada. I promise you, I didn't misinterpret. Though as you say, it's very possible the person I spoke to was wrong, or that their interpretation of the law was overly cautious and they've changed their policies.

Re: How to submit an app to Apple’s App Store when it uses encryption

#18
post #2

Last year I learned that to publish an app in the App Store or Mac App Store, if it uses encryption of any kind and yes, HTTPS and SSL count, you need an Encryption Registration (ERN) from the US Bureau of Industry (BIS). Some people claim it's fine to lie to Apple, claim no use of encryption and get in the app store. I'd rather do it the right way. When I started the process of getting the ERN, I quickly notice it w…

I'm far from an expert on this area, but I know there are exemptions many apps can qualify for. The most notable of these is that the encryption is limited to authentication [1]. [1]: http://stackoverflow.com/questions/2135081/does-my-applicati...

I would have thought this covered https.

Re: How to submit an app to Apple’s App Store when it uses encryption

#19
post #2

Last year I learned that to publish an app in the App Store or Mac App Store, if it uses encryption of any kind and yes, HTTPS and SSL count, you need an Encryption Registration (ERN) from the US Bureau of Industry (BIS). Some people claim it's fine to lie to Apple, claim no use of encryption and get in the app store. I'd rather do it the right way. When I started the process of getting the ERN, I quickly notice it w…

I think I remember reading that if you're using Apple's APIs and frameworks (like their builtins for HTTPS) then you don't need to go through this rigmarole.

From the screen shot of Apple's app submission: "Select yes even if your app is only utilizing the encryption available in iOS or OSX."

Re: How to submit an app to Apple’s App Store when it uses encryption

#20
post #11

Earlier quoted context omitted.

Back when I was doing hobbyist iOS development (2009-ish) I asked Apple developer support about this, and they said it does. Worst part is it doesn't matter if you use a built-in system library like NSURLSession. Simply accessing an HTTPS URL from inside your app triggers this requirement. Some people say the paperwork is easy to fill out yourself, but I was a college student and the legalese scared the crap out of m…

That cannot possibly be true. I guarantee you virtually every REST app in the store uses HTTPS and none of them went through all of this. In the latest version of iOS you can't even load HTTP by default and must use HTTPS unless you put a special exception in your Info.plist. Everybody uses HTTPS, and nobody has to go through any of this. So either you asked the wrong question, misinterpreted the answer, or you simpl…

It is true. There are a lot of exemptions, and not all uses of HTTPS require export registration.

However, if your app's main purpose has anything to with information security or sending/receiving/storing information, then you probably need ERN.

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