# App Store Guideline 5.3: gambling, contests and lotteries

> Guideline 5.3: you run the contest, rules shown in the app. Real-money gaming needs a license, geo-restriction and a free app.

Original page: [App Store Guideline 5.3: gambling, contests and lotteries](https://devoria.fr/en/blog/app-store-guideline-5-3-gambling-contests-lotteries)
Author: [Mehdi Azizi](https://devoria.fr/en/mehdi-azizi)
Published: 2026-11-04
Content last revised: 2026-11-04


Guideline 5.3, "Gaming, Gambling, and Lotteries," covers contests, lotteries and real-money gaming. **A contest has to be run by you, with official rules shown in the app. Real money requires a license in every country, plus a geo-restricted, free app.** A game where nothing is wagered or withdrawn in real money falls outside 5.3.4, but not outside the age rating.

I publish my own iOS apps: Solys, TradaZen and Nolera are on the App Store. TradaZen is a trading simulator, so the line between game and real money affects me directly. This guide is based on Apple's official text, read on October 15, 2026, and on the App Store Connect help pages. It's not legal advice: gambling laws vary from country to country.

## What does guideline 5.3 say?

5.3 sits in section 5, "Legal," of the [App Review Guidelines](https://developer.apple.com/app-store/review/guidelines/#5.3). Its intro warns that gaming, gambling and lotteries "tend to be one of the most regulated offerings on the App Store." Apple asks you to check your legal obligations everywhere the app is available, and to plan for "extra time during the review process."

Four sub-rules follow. The rejection message usually cites the most specific one, using Apple's usual format: "Guideline 5.3.2 - Legal - Gaming, Gambling, and Lotteries."

| Sub-rule | What it requires                    |
| -------- | ----------------------------------- |
| 5.3.1    | Contest run by you                  |
| 5.3.2    | Official rules in the app           |
| 5.3.3    | Real gaming without in-app purchase |
| 5.3.4    | License, countries, free app        |

## 5.3.1 and 5.3.2: contests and sweepstakes

5.3.1 fits in one sentence: "Sweepstakes and contests must be sponsored by the developer of the app." The contest or sweepstakes has to be organized and backed by the app's developer, meaning you or your company.

5.3.2 covers the format: "Official rules for sweepstakes, contests, and raffles must be presented in the app and make clear that Apple is not a sponsor or involved in the activity in any manner." The official rules for contests, sweepstakes and raffles must be shown in the app. They state clearly that Apple is neither a sponsor nor involved in any way.

**The rules are read inside the app, and the Apple statement is spelled out in full.** A bare link to a page on your website leaves doubt about "presented in the app." The safest option: a "Rules" screen opened from the contest, with the Apple sentence at the top.

The clause I'd use, to adapt and have a lawyer review:

```text
This contest is organized by [Company name].
Apple is not a sponsor of this contest and is not
involved in it in any way.

Ce concours est organisé par [Nom de la société].
Apple n'est pas sponsor de ce concours et n'y est
associé d'aucune manière.
```

The rest of the rules (dates, prizes, eligibility, drawing) falls under the law of each country where the app is offered.

## 5.3.3: no in-app purchase for real-money gaming

"Apps may not use in-app purchase to purchase credit or currency for use in conjunction with real money gaming of any kind." An app can't sell, through in-app purchase, credits or currency used to play for real money, whatever the form of the game.

That's the opposite of the usual rule. For digital content, [guideline 3.1.1](https://devoria.fr/en/blog/guideline-3-1-1-in-app-purchase-required) requires Apple's in-app purchase, game currencies included. **As soon as the currency touches real money, in-app purchase becomes forbidden.**

## 5.3.4: real money and lotteries

5.3.4 targets real-money gaming, like sports betting, poker, casino games or horse racing, and lotteries. It sets three conditions: the app "must have necessary licensing and permissions in the locations where the app is used, must be geo-restricted to those locations, and must be free on the App Store."

1. **A license in every location of use.** Apple's page on [information for a complete review](https://developer.apple.com/help/app-review/before-submitting-for-review/complete-review) asks for "the applicable gambling or lottery license for each storefront where your app is available." So, one license per storefront.
2. **A geo-restricted app.** In App Store Connect, [availability by country](https://developer.apple.com/help/app-store-connect/manage-your-apps-availability/manage-availability-for-your-app-on-the-app-store) limits the storefronts where the app can be downloaded. The text also mentions the locations where the app "is used": operators usually add a location check inside the app.
3. **A free app.** The app itself isn't sold on the App Store.

The rule adds one ban and one definition. Illegal gambling aids, like card counters, are rejected. A lottery, for its part, combines three elements: "consideration, chance, and a prize." Something given in return (a stake, a purchase), chance, and a prize. **The way I read it, with no consideration, your sweepstakes isn't a lottery under 5.3.4: it falls under 5.3.1 and 5.3.2.**

Two more pointers round out 5.3.4. [Section 5.1.1 (ix)](https://developer.apple.com/app-store/review/guidelines/#5.1.1) requires apps in highly regulated fields, gambling included, to be submitted by a legal entity that provides the service, "and not by an individual developer." In France, the gambling regulator is the [Autorité nationale des jeux](https://anj.fr/), which publishes the list of licensed operators.

Each country can add its own requirements. In Brazil, for example, Apple's page on [age ratings](https://developer.apple.com/help/app-store-connect/reference/app-information/age-ratings-values-and-definitions) states that a fixed-odds betting app must hold a license from the Secretariat of Prizes and Bets (SPA).

## Virtual currency, loot boxes and simulation: where the line is

The same age rating page gives the clearest test. "Gambling" there means wagering real money "or in-game currency that may be exchanged for real money." "Simulated Gambling" means wagering without real money, with a currency that can't be exchanged for money. **The question isn't your game's theme: it's whether there's a way out to real money.**

A fake currency that can't be withdrawn, resold, or used to win any prize stays simulated gambling. That doesn't put your game outside the rules:

- **The age rating.** In Apple's table, gambling and frequent simulated gambling sit at the 18+ tier, infrequent simulated gambling at 13+, and paid loot boxes at 9+.
- **Paid loot boxes.** [Guideline 3.1.1](https://developer.apple.com/app-store/review/guidelines/#3.1.1) requires "loot boxes" to disclose the odds of receiving each type of item before purchase.
- **Purchased currency.** Also under 3.1.1, credits and currencies bought through in-app purchase don't expire.

The way I read it, a box you open without paying anything doesn't fit Apple's definition, which talks about random items "for purchase." Showing its odds is still good practice.

In TradaZen, I built the shop's mystery box with that logic. It opens with gems earned by playing, which can't be bought with money, and its card shows the odds for each item family before you open it.

## Simulators: trading, poker or betting with no money

TradaZen is a trading simulator: a real chart at a real date, with what came next hidden. You pick Long or Short, and the market reveals what it actually did. The app's legal screen says it in one sentence: "No real money is at stake." Accounts are fake, nothing is deposited or withdrawn. The app's story is in the [TradaZen case study](https://devoria.fr/en/blog/tradazen-case-study-launching-iphone-app).

For a simulator, three habits:

- **No bridge to real money.** No withdrawals, no cash prizes, no marketplace to resell the currency or items.
- **No promise of winnings.** A trading simulator isn't investment advice: say so in the app. If it placed real orders, it would be a financial service, another regulated field covered by 5.1.1 (ix).
- **Review notes that say it.** The reviewer shouldn't have to guess.

The notes template I'd use, to adapt:

```text
Hello App Review team,

[App name] is a [trading / poker] simulator for practice
and entertainment.
- No real money is deposited, wagered or withdrawn.
- The virtual currency cannot be exchanged for money or prizes.
- Random rewards show their odds before opening: [screen].
- Age rating answers include simulated gambling: [level].

Best regards,
[Your name]
```

Keep only the lines that are true for the build you submit. Honesty toward Apple is a rule in its own right, set by [guideline 5.6, the Developer Code of Conduct](https://developer.apple.com/app-store/review/guidelines/#5.6).

## The table: which mechanic is allowed?

This table is my reading of Apple's text as of October 15, 2026. It doesn't replace Apple's review or a lawyer's advice.

| Mechanic                        | Allowed?       | Condition                    |
| ------------------------------- | -------------- | ---------------------------- |
| Free contest with prizes        | Yes            | Run by you, official rules   |
| Free sweepstakes                | Yes            | Run by you, official rules   |
| Paid lottery                    | With a license | License, countries, free app |
| Real sports betting             | With a license | License, countries, free app |
| Real poker or casino            | With a license | License, countries, free app |
| In-app purchase for real gaming | No             | Banned by 5.3.3              |
| Card counter                    | No             | Illegal gambling aid         |
| Casino with fake currency       | Yes            | Not convertible, age rating  |
| Paid loot box                   | Yes            | Odds shown beforehand        |
| Loot box earned by playing      | Yes            | Odds shown, recommended      |
| Currency convertible to money   | With a license | Treated as gambling          |
| Trading simulator               | Yes            | No real money                |
| Paid real-gaming app            | No             | The app must be free         |

> As soon as a stake or a win touches real money, your mechanic goes from "Yes" to "With a license."

## Preparing the review for an affected app

- Answer the age rating questionnaire without leaving anything out: gambling, simulated gambling, contests, loot boxes.
- Attach your licenses in the App Review Information section before submitting, one per storefront.
- Say in the notes where to find the rules, the odds and the location check.
- Expect a longer wait, as Apple warns. The usual benchmarks are in [App Store review time](https://devoria.fr/en/blog/app-store-review-time-how-long).

## Getting through 5.3 without back-and-forth

If Apple just rejected your app under 5.3, the [Review Kit](https://devoria.fr/en/kits/app-review) helps you find the cited rule and what it asks for, with notes templates for the reviewer. For a human look at your case, [book an hour with me](https://devoria.fr/en/coaching). The full process after a rejection is on the [app rejected by Apple](https://devoria.fr/en/expertise/app-rejected-by-apple) page.

Haven't submitted your app yet? [Take your free diagnostic](https://devoria.fr/en/diagnostic): it puts the steps in order and sends you my Apple anti-rejection checklist. For the big picture of rejection reasons, read [why Apple rejects an app](https://devoria.fr/en/blog/apple-app-rejection-real-cases).

## Frequently asked questions

### How do I fix a "Guideline 5.3.2 - Legal - Gaming, Gambling, and Lotteries" rejection?

Add your contest's official rules inside the app, reachable from the contest itself. They must say Apple is neither a sponsor nor involved. Most of the time, that means a new build. Then tell the reviewer where to find the rules.

### Is a casino app with no real money allowed?

In principle yes, if the chips can never be exchanged for money or prizes. Apple calls that simulated gambling: declare it in the age rating questionnaire. If the chips are sold, every purchase goes through Apple's in-app purchase.

### Can you sell chips through in-app purchase in a poker game?

Yes for fake chips that are only used to play in the app: in-app purchase is actually required. No for credits tied to real money, which 5.3.3 bans. It all comes down to one question: can the currency come back out as money?

### Can an individual developer publish a betting app?

In principle no. [Guideline 5.1.1](https://devoria.fr/en/blog/guideline-5-1-1-app-store-rejection), section (ix), requires gambling apps to be submitted by the legal entity that provides the service. You also need a license in every country where the app is offered.

### Do I have to show the odds for a free loot box?

The 3.1.1 rule targets random items that are sold, not a box earned by playing. I do it anyway: it's a matter of transparency, and the rule will apply as soon as the box becomes purchasable.


## Your project

[Review Kit](https://devoria.fr/en/kits/app-review): My App Store review checklist, the Apple rejections I fixed, a Google Play checklist and three Claude Code skills. $55.

[iOS & Android Kit](https://devoria.fr/en/kits/ios): Build your iPhone and Android app with Claude Code: the starter code from my apps, the path all the way to the stores, and every kit. $109.

[Diagnostic: what's between you and your iPhone app](https://devoria.fr/en/diagnostic): 7 questions, 60 seconds: find out what's really stopping you from publishing your iPhone app, get your 4-step path and the kit that fits you.
