The Focus Keyword (“Apple new guidelines AI data sharing”) is front and centre as Apple raises the bar for user privacy in the age of AI. As of November 13-14, 2025, Apple has updated its App Review Guidelines to require that apps disclose and receive explicit user permission before sharing any personal data with third-party AI services
Under the updated rule (specifically guideline 5.1.2(i)), Apple writes:
“You must clearly disclose where personal data will be shared with third parties, including with third-party AI, and obtain explicit permission before doing so.”
This is a big step: it’s the first time Apple has explicitly named “third-party AI” in its guidelines.
Why Apple Is Making This Move
1. Rapid growth of AI in apps
As apps increasingly incorporate generative AI, large-language models and machine-learning services, data flows to external AI providers are becoming more common and complex. Apple is acting to ensure that such data-sharing doesn’t happen without user awareness.
2. Privacy & trust concerns
By demanding explicit consent before personal data goes to third-party AI, Apple is reinforcing its long-standing stance on user privacy: users should know how their data is used and by whom.
3. Strategic timing
The change comes as Apple prepares for its upcoming next-gen digital assistant enhancements (rumoured for 2026) which may use AI-driven capabilities across apps.
What Developers and Apps Must Do
- Apps must clearly disclose whenever personal data is going to be shared with a third-party AI service.
- Apps must obtain explicit permission (consent) from the user before sharing that data.
- Developers should update their privacy-practices, disclosure forms and permission flows to align with the revised guidelines.
- Failure to comply means risk of app rejection from the App Store.
What This Means for Users & the Industry
For Users
- More transparency: Users will have clearer visibility when their personal information is going to an AI service outside the app.
- More control: Users get the choice to opt-out of such data sharing rather than being unaware of hidden transfers.
- Better privacy: This step reduces the risk of personal data being used in unanticipated ways by external AI systems.
For Developers & AI Providers
- Increased compliance burden: Developers need to audit which third-party AI services they use, how data flows, and update UI/UX to get permissions.
- Possible slowdown of AI-feature rollouts: Some apps might delay or redesign features that rely on external AI if the permission flow is cumbersome.
- Opportunity to build trust: Apps that handle consent and data-sharing clearly may benefit from higher user trust and improved brand reputation.
Broader Context & Background
Apple’s App Review Guidelines have long required developers to define how they use and share user data. For example, the “User Privacy and Data Use” section on Apple’s developer site sets out obligations around tracking, collecting identifiers, and linking user data.
However, until now Apple’s language didn’t specifically call out AI services as a distinct category of data-sharing with third parties. This revision signals recognition by Apple that AI workflows pose special privacy/consent risks.
The timing also coincides with rising regulatory focus globally on how AI uses personal data, as well as Apple’s own imminent push into more advanced AI features within its ecosystem.
What’s Still Unclear or Needs Watching
- Definition of “third-party AI”: The guidelines don’t fully specify exactly what qualifies as “AI”. Does it include simple machine-learning services, inference APIs, or only large-scale generative models? Some ambiguity remains.
- Enforcement mechanics: Apple states the rule, but how it will enforce it (audits, penalties, removal from App Store) remains to be seen.
- Global variation: Developers outside the U.S./Europe will need to check how these Apple rules interact with local privacy laws.
- User experience: How apps design permission flows will matter — if the consent prompts are too intrusive, it could impact adoption or user behaviour.
- Impact on AI innovation: Some smaller developers relying on external AI services may see cost or compliance burdens rise.
Conclusion
With its updated guidelines requiring apps to disclose and seek consent before sharing user data with third-party AI, Apple reinforces that privacy is central even as apps lean heavily into AI. For users, the change offers stronger protections and clearer control. For developers and AI providers, it brings new obligations — but also an opportunity: design for transparency and trust to stand out.
In the evolving world where AI features are rapidly integrated into everyday apps, Apple’s move may set a precedent for how platforms regulate data-sharing in AI ecosystems.
