We are planning to update our app in App Store with some cryptographic implementations included in the next release. Reading about the App Store procedures for apps with any cryptography, it requires us to file the annual self classification report to BIS and update US export compliance in iTunes store. But some parts remain unclear. Can someone who has underwent these procedures recently help here please ?

  1. The BIS site states that 'A annual self-classification report for applicable encryption commodities, software and components exported or reexported during a calendar year (January 1 through December 31) must be received by BIS and the ENC Encryption Request Coordinator no later than February 1 of the following year.'

    • Does this mean that for the app am submitting today, I can file the report anytime before Feb 1 of next year (which is almost after an year)? Do I not really need the BIS approval for the annual self classification report before I get my app to the app store ?
  2. What is the document that is needed to be uploaded in iTunes connect in place of 'Add export compliance documentation for iOS' while submitting the application? Apple FAQs says that "Apple requires a short letter stating that you understand your legal obligations to submit a year-end self classification report required by BIS."

    • Does this have any format to follow ?

    • And how does the annual self classification report that we send to BIS and the compliance document that we upload to iTunes connect gets linked here ?

  3. Earlier procedures with ERN required the key value (generated after successful registration) to be added to the plist while submitting the build with crypto changes. Say, 'ITSAppUsesNonExemptEncryption' to true and 'ITSEncryptionExportComplianceCode' with the generated key value. Does the new procedure of filing the annual self classification report will also need any such updation in the plist ?

Your Answer

By clicking “Post Your Answer”, you agree to our terms of service, privacy policy and cookie policy

Browse other questions tagged or ask your own question.