Compliance Briefing — Apple enforces App Tracking Transparency with iOS 14.5 rollout

Executive briefing: Apple began enforcing App Tracking Transparency (ATT) with iOS 14.5 on 26 April 2021. Any app that wishes to track users across apps and websites for advertising or data broker use must obtain explicit user permission through the ATT prompt. The enforcement reshapes ad personalization, attribution, and third-party SDK usage for every iOS publisher and ad network.

Privacy, product, marketing, legal, and engineering teams must keep ATT compliance baked into release pipelines: prepare consent UX, audit SDK behavior, configure SKAdNetwork measurement, and document data-sharing claims for App Store review. Use the pillar hub, the governance guide, and cross-references to the SEC Regulation SP incident-readiness brief and RBI IT governance deadline brief for aligned controls.

Core enforcement rules

• Tracking definition: Accessing the IDFA or combining user or device data from your app with data from other companies for targeted ads, measurement, or data broker use counts as tracking and requires opt-in.
• Prompt requirement: Apps must show Apple’s ATT system prompt before initiating tracking; pre-prompts are allowed but cannot coerce or gate access to functionality.
• Data-use disclosures: App Store privacy nutrition labels must accurately describe data collection and sharing practices; mismatches risk rejection.
• SDK accountability: Publishers are responsible for third-party SDK behavior; unvetted tracking code can trigger App Store review findings even if the publisher did not intend to track.
• Measurement: SKAdNetwork is the sanctioned framework for aggregated attribution without user-level data. Fingerprinting and device graphing to circumvent ATT violate App Store policy.

Stakeholder responsibilities

Measurement and revenue adaptation

• SKAdNetwork tuning: Map conversion values to the highest-value post-install actions (e.g., subscription trial start, add-to-cart) within Apple’s 0–63 window; design timers to capture meaningful signals before the postback locks.
• On-device personalization: Shift from user-level tracking to on-device or contextual models that do not combine data across apps; communicate the privacy benefits to users to improve opt-in rates.
• Probabilistic modeling: Use aggregated measurement within Apple’s policy boundaries; avoid device fingerprinting or IP-based stitching that can be interpreted as circumventing ATT.
• Server-to-server events: Ensure events sent to ad partners do not include identifiers that enable cross-app linkage without consent.

Consent UX patterns that pass review

Release checklist

• Confirm ATT prompt triggers before any tracking SDK or IDFA call; test both “Allow” and “Ask App Not to Track” paths.
• Update the privacy nutrition label with accurate data categories (contact info, identifiers, location, usage, diagnostics) and whether they are linked to the user.
• Maintain a SDK inventory with version, purpose, data collected, and network endpoints; remove SDKs that fingerprint or share identifiers without consent.
• Document data flows for analytics, ads, and crash reporting; ensure consent flags propagate to backend services.
• Validate SKAdNetwork configuration: ad network IDs, conversion-value schema, postback receiver, and lock-window timers.
• Retain evidence (screenshots, test logs, App Store submission notes) for potential Apple inquiries or regulatory reviews.

Risk controls and monitoring

• Code review gates: Block merges for new SDKs without privacy review; scan for direct IDFA access or device fingerprinting APIs.
• Network monitoring: Restrict egress domains; alert on unapproved endpoints or payloads containing device identifiers.
• Runtime safeguards: Feature-flag any tracking-dependent functionality so it can be disabled remotely if Apple flags behavior.
• Incident response: Prepare a runbook for responding to App Store review notices, including rollback steps, communication templates, and data-deletion workflows.

Metrics that matter

Sustainment through iOS updates

Apple continues to tighten privacy expectations (e.g., Privacy Manifests, Required Reason APIs). Maintain a rolling backlog to:

• Update SDK manifests and reason strings as Apple adds protected APIs.
• Re-run privacy testing on every iOS beta; monitor console logs for ATT or reason-code violations.
• Refresh consent copy and experiments each quarter to keep opt-in rates healthy without coercion.
• Train marketing and product teams on the limits of probabilistic attribution and the risks of fingerprinting workarounds.

Teams that treat ATT as an ongoing operating discipline, not a one-time migration, reduce review friction and preserve trusted user relationships.