In recent years, developers of crypto-related and fintech mobile applications have increasingly encountered a familiar response during the App Store review process: a request from Apple App Store asking for a legal opinion letter under local law.

This request often comes as a surprise – particularly for developers operating non-custodial wallet applications, decentralized swap interfaces, or software that merely facilitates user interaction with public blockchains. Many assume that the absence of custody, execution, or brokerage activity should be sufficient to pass review without further legal scrutiny.

However, Apple’s review practice reflects a different reality: technical compliance alone is no longer enough. Where an app touches areas that may intersect with financial regulation, Apple increasingly requires independent legal confirmation, specific to the jurisdiction of release. For apps distributed in Türkiye, this requirement has become especially common.

Why Apple Requests Legal Opinion Letters

Apple’s App Store Review Guidelines are global in scope, yet Apple applies them through a jurisdiction-specific risk lens. When an application potentially implicates financial services, digital assets, or payment-adjacent functionality, Apple must assess not only whether the app complies with its own guidelines, but also whether distribution of the app could expose Apple to regulatory or enforcement risk in the relevant country.

Apple is not a regulator, nor does it conduct legal analysis under national law. Instead, it manages this risk by requesting external legal opinions, typically asking developers to demonstrate that:

• the app does not constitute a regulated activity under local law, or
• the app operates lawfully without requiring a licence or authorisation.

Importantly, Apple does not rely on developers’ self-characterisations. Statements such as “we are not an exchange” or “we do not hold private keys” are viewed as technical assertions, not legal conclusions.

From Apple’s perspective, only a lawyer qualified in the relevant jurisdiction can confirm whether those technical features translate into a lawful, unregulated activity under domestic law.

Why Türkiye Is Treated as a High-Sensitivity Jurisdiction

Türkiye occupies a distinctive position in Apple’s compliance assessment. While Türkiye does not yet have a fully implemented and comprehensive crypto-licensing regime, it has:

• an active enforcement culture in financial and criminal law,
• strong AML and financial crime controls,
• and an evolving regulatory approach to crypto-asset-related activities.

In practice, this creates legal grey zones rather than clear safe harbours. Activities that may be treated as pure software services in some jurisdictions can, in Türkiye, raise questions around:

• payment services,
• intermediary activity,
• unauthorised financial services,
• or even criminal liability in extreme cases.

Apple’s response to this uncertainty is predictable: when in doubt, request a legal opinion. As a result, Türkiye is frequently categorised – implicitly – as a jurisdiction where Apple requires explicit legal reassurance before approving certain app functionalities.

App Types Commonly Affected by Apple’s Legal Opinion Requests

Based on recent App Store review practice, the following categories of applications are most likely to receive a legal opinion request in Türkiye:

Non-Custodial Crypto Wallets: Even where:

• private keys remain solely on the user’s device,
• no assets are ever held by the app provider,
• and transactions are signed locally,

Apple often asks whether such wallets could still be characterised as a regulated crypto-asset service under Turkish law.

Wallets with Swap or Bridge Interfaces: Apps that include:

• token swap functionality,
• DEX aggregation,
• routing or quoting via third-party protocols,

are scrutinised closely, particularly where a fee model is involved.

Apps Integrating Third-Party Protocols: Even if execution occurs fully on-chain, Apple assesses whether:

• the app operator could be seen as an intermediary,
• the integration creates de facto brokerage activity,
• or the app participates economically in the transaction flow.

FinTech and Payment-Adjacent Applications: Apps that touch:

• digital payments,
• account-like balances,
• or transactional value flows

are also common targets for legal opinion requests. In all these cases, the decisive issue is not what the app claims to be, but how its functionality is legally classified under Turkish law.

What Apple Is Actually Asking for in a Legal Opinion Letter

When Apple requests a legal opinion letter for App Store review in Türkiye, the request is often framed in broad terms. However, in practice, Apple is seeking clear answers to a limited set of legal questions, not a general memo on crypto regulation. At its core, Apple wants confirmation that:

• The app does not provide a regulated service under Turkish law, or
• If it does, the developer holds the necessary licence or authorisation.

For non-custodial wallet and swap-interface applications, the first scenario is typically relevant. Apple expects the legal opinion to address, in plain and unequivocal terms, whether the app’s functionality could be characterised as:

• custody of crypto assets,
• payment services or electronic money activity,
• brokerage, exchange operation, or order execution,
• intermediary or agent activity in financial transactions.

Crucially, Apple does not want conditional or speculative language. Phrases such as “arguably”, “may be considered”, or “in principle” often trigger follow-up questions or prolonged review cycles. From Apple’s perspective, a legal opinion should end with a definitive legal conclusion, even if that conclusion is subject to clearly stated assumptions and limitations.

How a Türkiye-Focused Legal Assessment is Structured

A legal opinion prepared for Apple App Store review is not a general academic analysis. It is a purpose-built document, structured to translate technical facts into legal classification under Turkish law. A well-prepared opinion typically proceeds in three layers:

Technical Assumptions (as Legal Facts): The opinion relies on a technical verification or representation letter provided by the app developer. These representations are treated as factual assumptions and usually include statements such as:

• private keys are generated and stored exclusively on the user’s device,
• the app provider has no access to user assets,
• transactions are signed by the user and executed on-chain,
• third-party protocols are used solely for routing or quotation,
• the app does not execute transactions on its own backend.

The lawyer does not audit code. Instead, the legal assessment is expressly conditional upon the accuracy of these representations.

Legal Qualification Under Turkish Law: Using those technical assumptions, the opinion then analyses whether the app’s activities fall within the scope of:

• payment services or electronic money under Law No. 6493,
• regulated financial or intermediary activity,
• custody or asset management services,
• other forms of regulated or prohibited conduct.

This stage is not about listing every statute that might conceivably apply. Rather, it is about excluding specific legal categories that would trigger licensing or authorisation requirements.

Clear, Apple-Oriented Conclusion: The opinion concludes with a concise statement confirming that, solely on the basis of the described functionalities, the app does not require a licence or authorisation under Turkish law. This conclusion is the single most important part of the document from Apple’s perspective.

Common Mistakes that Lead to Apple Rejections or Delays

In practice, many legal opinion letters submitted to Apple fail – not because the app is unlawful, but because the opinion is poorly aligned with Apple’s review expectations. Common issues include:

Overly Technical, Under-Legal Analysis: Opinions that explain how blockchain works, but never answer whether the app is legally regulated, are rarely accepted.

Generic or Recycled Legal Opinions: Apple routinely rejects:

• template opinions,
• letters not naming the specific app,
• opinions that could apply to “any wallet app”.

Apple expects an app-specific legal assessment, not a general crypto law overview.

Risky Terminology: Using marketing or industry terms such as:

• exchange,
• trading service,
• execution,
• brokerage,

even casually, can undermine the entire legal position.

Ignoring Fee Structures: Service fees, referral models, or indirect revenue streams must be addressed explicitly. Silence on fees often raises more concern than transparent disclosure.

Jurisdiction Mismatch: Legal opinions issued by lawyers unfamiliar with Turkish regulatory practice – or based on foreign-law assumptions – frequently fail to satisfy Apple’s concerns.

Why Legal Opinion Letters Must Be App-Specific and Jurisdiction-Specific

Apple does not treat legal opinion letters as a formality. Instead, they are viewed as risk allocation tools. By requiring a jurisdiction-specific opinion, Apple shifts legal responsibility away from its own review process and onto a qualified local professional. For this reason:

• the app must be identified by name,
• the functionality must be described precisely,
• the legal conclusion must be tied to Turkish law, not general principles.

A legal opinion that is accurate in substance but vague in scope often results in:

• repeated clarification requests,
• extended review timelines,
• or outright rejection.

Conversely, a well-structured, Türkiye-focused legal opinion letter frequently resolves Apple’s concerns in a single review cycle.

The Role of Turkish Counsel in the App Store Review Process

From Apple’s perspective, a legal opinion letter is only as reliable as the jurisdictional expertise behind it. This is particularly true in Türkiye, where regulatory practice often evolves through administrative interpretation, enforcement trends, and prosecutorial approach, rather than through fully settled secondary legislation. For this reason, Apple generally expects that:

• the opinion is issued by a lawyer or law firm qualified under Turkish law,
• the analysis reflects not only statutory provisions, but also regulatory practice,
• the conclusions are framed in a way that is intelligible to non-lawyer reviewers.

A Türkiye-focused legal opinion therefore requires more than formal citation of legislation. It requires an understanding of how Turkish authorities typically classify activities such as custody, intermediation, payment services, or financial facilitation – particularly in technology-driven contexts. In practice, Apple reviewers place considerable weight on whether the opinion demonstrates local legal insight, rather than abstract or comparative analysis. Opinions that merely translate foreign regulatory logic into the Turkish context often fail to address the underlying compliance concern.

Regulatory Grey Zones and the Importance of Legal Clarity

One of the most common misconceptions among app developers is that regulatory uncertainty reduces the need for legal opinions. In reality, the opposite is true. Where a jurisdiction lacks a fully codified licensing regime – such as Türkiye’s current approach to non-custodial crypto wallet software – Apple tends to adopt a more cautious stance, not a more permissive one. Legal grey zones are treated as risk indicators, prompting Apple to seek independent legal confirmation before allowing distribution. In this environment, a legal opinion letter serves two essential functions:

• It clarifies how the app’s functionality should be classified under existing law, even in the absence of bespoke regulation.
• It delineates responsibility by expressly tying the legal conclusion to specific technical assumptions.

This approach allows Apple to proceed with distribution while maintaining a defensible compliance position. For developers, it transforms regulatory ambiguity from a barrier into a manageable procedural step.

Conclusion: Legal Clarity as a Distribution Requirement, Not a Formality

Apple’s request for a legal opinion letter during App Store review should not be viewed as an exceptional or adverse development. For apps distributed in Türkiye – particularly those involving crypto assets, fintech functionality, or transaction-adjacent features – it has become a standard compliance mechanism. A properly structured legal opinion letter:

• translates technical architecture into legal classification,
• addresses Apple’s core compliance concerns directly,
• reduces the likelihood of repeated review cycles,
• and provides a clear framework for future app updates.

Most importantly, it recognises that App Store approval is no longer based solely on technical design or user experience. Legal clarity has become an integral part of the launch and distribution process. 

From a developer’s perspective, investing in a Türkiye-focused legal assessment early -rather than reacting to rejection notices – often determines whether an app reaches the market smoothly or remains stuck in review.

As regulatory expectations continue to evolve, legal opinion letters will remain a critical interface between innovative technology and jurisdiction-specific compliance. Understanding this dynamic is now an essential part of operating a globally distributed application.

At Bıçak, we regularly assist technology companies, app developers, and international teams in navigating Apple App Store review requirements for distribution in Türkiye, particularly where Apple requests a jurisdiction-specific legal opinion letter. Our work in this area focuses on translating technical application architectures into clear legal classifications under Turkish law, with an emphasis on non-custodial crypto wallets, swap and routing interfaces, and fintech-adjacent applications. This practical experience informs our approach to preparing App Store-focused legal opinions that are concise, app-specific, and aligned with Apple’s compliance expectations.