French Encryption Import Compliance

gistfile1.md

Starting in the first week of July, apps that meet the following criteria are required to comply with French Encryption Laws/Regulations if you intend to distribute your app in France.

This requirement applies to apps that use, access, implement, or incorporate:

1. Any encryption algorithm that is yet to be standardized by international standard bodies such as IEEE, IETF, ISO, ITU, ETSI, 3GPP, TIA, etc. or not otherwise published; or
2. Standard (e.g., AES, DES, 3DES, RSA) encryption algorithm(s) instead of or in addition to accessing or using the encryption in iOS and/or Mac OS X

Apple will require you to upload a copy of your approved French declaration when you submit your app to the App Store. Relevant French encryption regulations can be found at:

• http://www.legifrance.gouv.fr/affichTexte.do?cidTexte=LEGITEXT000005789847&dateTexte=#LEGIARTI000006421577
• http://www.ssi.gouv.fr/archive/fr/reglementation/regl_crypto.html
• http://www.ssi.gouv.fr/site_article195.html
• http://www.ssi.gouv.fr/site_article197.html

Regards, Apple Export Compliance

Links are outdated

@bcipolli I have found this one by googling: https://www.ssi.gouv.fr/uploads/2015/03/ANNEXE-I.pdf

The official French link is broken too in there website.

When inspecting their website I see the the link points to `/uploads/2014/11/crypto_declaration-demande_autorisation_operations_annexe1_v2.pdf``

While my first link is from 2015

I'm not 100% sure my link is the proper one but it seems to be. I have contacted them by the way

If i read the law correctly, this only applies to encryption that are not stricly for Authentification or Integrity Check (e.g. Https)

@Arnaud-Albrecht But it still requires me to provide a document here, does anyone know how this has to look? I explicitly checked that we are only using default encryption algorithms like rsa, etc.

sorry french guys, my app will not going to be available on iOS.

+1 need help with this.

Quick heads up for anyone still referencing this — even basic stuff like HTTPS, CryptoKit, Keychain, or APNs counts as encryption under French law now.

I ran into this recently your app might need to file even if you're just using standard iOS networking.

Ended up building a tool to automate the paperwork if anyone needs it: NovaStore

The link doesn't work. Would Appreciate if you could make it available! Thanks

Hi everyone.

I've found the form on https://cyber.gouv.fr/sites/default/files/2022-09/crypto_form_fourniture_prestation_annexe2%5B1%5D.pdf.

From my understanding, submitting the form to the French Government is possible via the following mail: controle@ssi.gouv.fr, although sending via post is recommended (see https://cyber.gouv.fr/controle-reglementaire-sur-la-cryptographie-les-formulaires).

Finally, Apple only requires the completed form, not the acknowledgement.

Edit: this is how debian.org completed their French encryption declaration: https://www.debian.org/legal/debian-lenny-crypto-declaration.pdf.

Thanks! that helped!

My App is Available in France! check it out...Super useful for Mac...
https://apps.apple.com/us/app/tess-ai/id6746819605?mt=12

Hi everyone.

I've found the form on https://cyber.gouv.fr/sites/default/files/2022-09/crypto_form_fourniture_prestation_annexe2%5B1%5D.pdf.

From my understanding, submitting the form to the French Government is possible via the following mail: controle@ssi.gouv.fr, although sending via post is recommended (see https://cyber.gouv.fr/controle-reglementaire-sur-la-cryptographie-les-formulaires).

Finally, Apple only requires the completed form, not the acknowledgement.

Edit: this is how debian.org completed their French encryption declaration: https://www.debian.org/legal/debian-lenny-crypto-declaration.pdf.

hi! can i ask what " Finally, Apple only requires the completed form, not the acknowledgement." means exactly ? I only need to fill out the form and submit it on app store connect ? Is there no need to send it to the french bureacracy through the controle@ssi.gouv.fr email adress? thank you very much!

My App is Available in France! check it out...Super useful for Mac... https://apps.apple.com/us/app/tess-ai/id6746819605?mt=12

can you please tell me what you need to do exactly! would be much appreciated! from what i udnerstodd, fill the doc at "https://cyber.gouv.fr/sites/default/files/2022-09/crypto_form_fourniture_prestation_annexe2%5B1%5D.pdf", then send it to that one french email adress, wait for their approval, then submit it on app store connect ?

thank you very much!

Do we especially need a company to submit the form ?

I think so. I had to incorporate anyways.. so I used that. I haven’t got any acknowledgement from French government for 2 years !