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Crypto exchange App Review evidence pack: the documents Apple needs before resubmission

By CexPass · App Store submission compliance for crypto exchanges · 30+ exchanges served

DIRECT ANSWER

A crypto exchange App Review evidence pack is the complete file that turns a rejection into a controlled resubmission. It usually contains a legal opinion letter, country availability statement, entity documents, reviewer-readable App Review Notes, demo account instructions, and — when needed — a 4.3 differentiation memo and 5.1.2 privacy data-flow audit. The point is not to upload more PDFs. The point is to answer each Apple guideline with the exact document the reviewer can verify.

Why a "pack" beats a single document

Most failed resubmissions send one strong document into a weak file. A legal opinion may be useful, but if it does not match the storefront list, App Review Notes or entity account, the reviewer still has open questions. A privacy label may be updated, but if the KYC SDK still contradicts it, 5.1.2 remains open. A 4.3 reply may show differentiation, but it does not answer whether the exchange may operate in each region.

The pack works because it assigns one job to each document and then makes those documents agree.

The evidence matrix

Apple concernWhat the reviewer needs to verifyEvidence pack item
3.1.5 licensing / permissionsThe exchange has a defensible legal basis in every enabled App Store region.Legal opinion letter + country availability statement
3.1.5 operator testThe app is offered by the exchange itself, not an unrelated third party.Entity registry extract, developer account explanation, operator memo
4.3 duplicate / template appThe app is a distinct exchange product, not another white-label clone.Differentiation memo, feature matrix, metadata rewrite, demo route
5.1.2 privacy / data usePrivacy label, SDK behavior, KYC data, tracking and sharing match the real app.Privacy label worksheet, SDK inventory, data-flow map, ATT note
Reviewer readabilityThe reviewer can find every answer without interpreting a legal memo.App Review Notes, attachment index, demo account instructions

Minimum pack contents

Reviewer-ready file8 items
1 · Rejection diagnosis memoExact guideline citations, Resolution Center history, and the decision: reply, appeal, or controlled resubmission.
2 · Legal opinion letterCounsel-reviewed analysis of the operator, business model, regions and legal basis.
3 · Country availability statementThe App Store storefront list mapped to legal basis and excluded countries.
4 · Entity evidenceRegistry extract, developer account relationship, brand/operator explanation and supporting corporate documents.
5 · App Review NotesThe one-page reviewer map: operator, regions, legal basis, demo account and attachments.
6 · Demo account fileCredentials, KYC-approved state, region access notes and reviewer path through the app.
7 · Differentiation memoOnly when 4.3 is present or likely: unique features, audience, metadata and UI/product deltas.
8 · Privacy evidenceOnly when 5.1.2 or privacy label risk is present: SDK inventory, data-flow map and privacy label updates.

Template excerpt: attachment index

Attachment_Index.pdf — excerptTEMPLATE

File 01 — Legal_Opinion.pdf. Region-by-region analysis responding to Guideline 3.1.5 licensing and permissions.

File 02 — Country_Availability_Statement.pdf. Enabled storefronts, excluded storefronts and legal basis mapping for this app version.

File 03 — Entity_Documents.pdf. Operator registry extract and developer account relationship explanation.

File 04 — App_Review_Notes.txt. Reviewer-facing summary and demo account instructions.

Conditional files. Differentiation_Memo.pdf for Guideline 4.3; Privacy_Label_Worksheet.pdf and SDK_Inventory.pdf for Guideline 5.1.2.

The index prevents reviewers from treating the submission as a pile of unrelated PDFs.

What makes the pack fail

Already have documents but still getting rejected? Send the rejection email and your attachment list. We will identify whether the gap is legal scope, storefront scope, Review Notes, 4.3 differentiation or privacy evidence.

Audit the evidence pack →

30-day controlled resubmission path

How CexPass structures the file~30 days
Day 1-3 · Rejection readSeparate 3.1.5, 4.3, 5.1.2 and appeal/resubmission questions.
Day 4-14 · Legal scope and availabilityLegal opinion and country availability statement align the operator, regions and documents.
Day 15-22 · Review Notes and conditional evidenceReviewer notes, 4.3 differentiation and 5.1.2 privacy evidence are added where needed.
Day 23-30 · Controlled resubmissionEvery reviewer follow-up is answered from the same file, not improvised in the Resolution Center.

Frequently asked questions

Is a legal opinion letter enough for a crypto exchange App Store rejection?

Usually no. A legal opinion is one core document, but Apple also needs to see the storefront scope, entity relationship, Review Notes and sometimes 4.3 or 5.1.2 evidence. The pack matters because every document answers a different reviewer question.

What should be attached in App Store Connect after a 3.1.5 rejection?

At minimum: a legal opinion letter, country availability statement, entity documents, rewritten App Review Notes and working demo account instructions. If the rejection also cites 4.3 or 5.1.2, add differentiation and privacy evidence before resubmitting.

Can the evidence pack include multiple legal opinions?

Yes. Some submissions use one umbrella opinion; others use coordinated local-counsel analysis for region groups. What matters for App Review is that the opinion scope matches the enabled storefronts and is summarized clearly in Review Notes.

Should I appeal before building the evidence pack?

Only if Apple clearly misread evidence that was already submitted. If documents were missing, unmapped or inconsistent, an appeal usually delays the fix. Build the evidence pack and resubmit with a clean reviewer map.

Related guides

Sources
Last updated: 2026-07-05 · CexPass

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