Country availability statement for a crypto exchange app: the storefront map Apple needs
A country availability statement is the document that maps every App Store storefront enabled for a crypto exchange app to a legal basis, supporting evidence and Review Notes wording. It prevents the classic Guideline 3.1.5 failure: the app is available in more countries than the legal opinion explains. For Apple, the statement turns "we are authorized" into a reviewer-readable table: region → basis → attachment → excluded regions.
Why country availability matters under Guideline 3.1.5
Apple's cryptocurrency rule asks whether an exchange app has appropriate licensing and permissions in every country or region where the app is available. The important phrase is not just "licensing and permissions" — it is where the app is available. That phrase makes your App Store Connect storefront list part of the evidence file.
If all storefronts are enabled by default, the reviewer can treat every enabled country as a claim that the exchange can lawfully offer services there. A license, registration or legal opinion that covers one jurisdiction does not answer the other storefronts. The country availability statement closes that gap before the reviewer has to name it.
The mapping Apple is trying to verify
| Review question | What the statement should show | Document it points to |
|---|---|---|
| Which storefronts are enabled? | A fixed list of included countries or regions, matching App Store Connect at submission time. | Country_Availability_Statement.pdf |
| Why are those regions included? | The legal basis for each region group: licensed, registered, exempt, partner-supported, or excluded from distribution. | Legal_Opinion.pdf, sections mapped by region |
| Who operates the app? | The operating entity and developer account relationship, so the 3.1.5 "offered by the exchange itself" test is not left open. | Entity registry extract, developer account explanation |
| What is excluded? | A clear excluded-region list for countries where no defensible basis is being claimed. | Availability appendix and App Store Connect storefront screenshot |
| How should the reviewer read it? | One paragraph in Review Notes that tells the reviewer exactly which file and section answers 3.1.5. | App Review Notes |
What belongs in the statement
Template excerpt
Submission scope. This statement describes the App Store countries and regions selected for ████████, version █.█.█, submitted by ████████ Ltd..
Included storefronts. The app is made available only in the storefronts listed in Appendix A. Storefronts outside Appendix A are deselected in App Store Connect for this version.
Legal basis. The legal basis for each included region group is summarized below and analyzed in Legal_Opinion.pdf, sections 2-4. Regions without a current legal basis are excluded from distribution.
Review Notes mapping. App Review Notes should cite this file as the storefront scope document and Legal_Opinion.pdf as the region-by-region legal analysis responding to Guideline 3.1.5.
The mistakes that trigger named-country rejections
- Leaving all storefronts enabled. This turns one submission into a global legal claim. If the evidence covers only a few regions, 3.1.5 has an obvious gap.
- Letting the legal opinion and storefront list drift apart. If the opinion says "selected regions" but App Store Connect shows many more, the reviewer follows the storefront list.
- Grouping countries by business priority instead of legal basis. "Asia", "Europe" or "growth markets" is not a legal category. Group only when the basis and evidence are the same.
- Hiding exclusions. Excluding countries is not a weakness; unexplained availability is. A clean excluded-region list often reduces review surface area.
- Forgetting Review Notes. A perfect availability statement can still fail if the reviewer has to discover it inside attachments without a map.
Not sure whether your storefront list is safe? Send your rejection email and target market list. We will tell you which countries are creating 3.1.5 exposure before the next reply goes on record.
Map the storefront risk →How it fits with the legal opinion letter
The legal opinion explains the law. The country availability statement explains the scope. App Review Notes explain how to read both. When those three documents agree, the reviewer can close the 3.1.5 checklist without guessing:
- Country availability statement: where the app is and is not available.
- Legal opinion letter: why the included regions have a defensible basis.
- Entity documents: who operates the exchange and how it relates to the developer account.
- Review Notes: the one-page map that ties the attachments to Guideline 3.1.5.
Frequently asked questions
Is a country availability statement the same as a legal opinion letter?
No. The legal opinion explains the legal basis; the country availability statement defines the App Store storefront scope and maps each included region to that basis. Apple needs both to see whether the documents match the regions where the app is available.
Can limiting storefronts help a crypto exchange app pass 3.1.5?
Yes. Narrowing availability to regions with a defensible legal basis reduces the review surface area. But the narrowed list still needs to be documented and carried into Review Notes so the reviewer can see that the storefront selection is intentional.
Should excluded countries be listed in the statement?
Yes. An excluded-region list helps show that the exchange is not making a global claim. It also prevents a reviewer from assuming that omitted countries were forgotten rather than deliberately deselected in App Store Connect.
What if the app has already been cited for one country under 3.1.5(iii)?
Treat the named country as a sample, not the whole problem. The next submission should reconcile all enabled storefronts against the legal basis, because Apple can ask for documentary evidence in every country or region where the app remains available.