Why is Roblox Allowed on the App Store?

Game Pass and Stadia, smh

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Matthew Ball shared a thought-provoking idea with Twitter this week - Roblox isn't compliant with Apple guidelines. In fact, a closer examination of the Roblox platform itself shows multiple conflicts, including unapproved games, independent codebases, legal infringements, etc.

Another person succinctly sums up this thought in a recent Hacker News post:

“The Roblox iOS app is entirely populated with non-Apple approved user created games. It also streams/downloads (non-Apple reviewed) code on demand. This seems to be against a number of App Store policies. Maybe Apple is OK with all of this when they get their 30% cut as they do with Roblox because it uses Apple's in-app purchases?” — ddarinm

If there is a clear infringement of App Store policy, why does Roblox technically comply when so many other gaming services do not? Could it be favoritism or … competition ? For context, Apple has a fraught history with other Big Tech companies and App Store compliance. The laundry list includes everything you’d expect

  • FB Gaming App removes gaming functionality on iOS to comply with regulation. Link

  • Apple blocks Microsoft’s xCloud from iOS release, citing that each game needs to be posted individually. Link

  • Epic and Apple enter legal battle over direct payments on in-app purchases in Fortnite. Link

Ball raises an interesting point because Apple’s reasons for barring apps on the App Store can often feel pointed against a few select players. Overall, the guidelines can be murky, a catch-all for those who don’t comply. And as we’ll discuss, it’s unclear whether or not Roblox violates their guidelines, but it also feels probable that they do.

We’re not legal experts, but figured it could be useful to compile a few resources we researched while searching for a clearer answer. Aside from Epic’s public tussle over the 30% app tax, Facebook, Microsoft, and Google (Stadia) violate the guidelines for their gaming apps because they chafe against Apple’s Remote Desktop Clients clause.

4.2.7 Remote Desktop Clients: If your remote desktop app acts as a mirror of specific software or services rather than a generic mirror of the host device, it must comply with the following:

  • (a) The app must only connect to a user-owned host device that is a personal computer or dedicated game console owned by the user, and both the host device and client must be connected on a local and LAN-based network.

  • (b) Any software or services appearing in the client are fully executed on the host device, rendered on the screen of the host device, and may not use APIs or platform features beyond what is required to stream the Remote Desktop.

  • (c) All account creation and management must be initiated from the host device.

  • (d) The UI appearing on the client does not resemble an iOS or App Store view, does not provide a store-like interface, or include the ability to browse, select, or purchase software not already owned or licensed by the user. For the sake of clarity, transactions taking place within mirrored software do not need to use in-app purchase, provided the transactions are processed on the host device.

  • (e) Thin clients for cloud-based apps are not appropriate for the App Store.

Here, unlike xCloud and Stadia for example, Roblox complies with section (c) in that it allows for users to sign-up for an account on mobile. Importantly, it also allows for users to buy Robux (the virtual currency) and subscribe to Roblox Premium (their subscription membership) through the mobile app. These are favorable conditions in the eyes of Apple; however, it’s unclear — considering that cloud-based platforms require data centers — how Roblox as well as Microsoft and Google can check off sections (a) and (e). How can it be an “approved” app when it violates these major requirements as well? Cloud-based gaming necessitates large warehouses full of servers and “thin client for cloud-based apps” aren’t kosher for Apple.

Given these conditions, it seems that Apple favors the smaller tech company [Roblox] over the larger ones [Microsoft and Google] because it overlooks these important cloud considerations. This brings us to the next relevant clause.

4.9 Streaming games Streaming games are permitted so long as they adhere to all guidelines — for example, each game update must be submitted for review, developers must provide appropriate metadata for search, games must use in-app purchase to unlock features or functionality, etc. Of course, there is always the open Internet and web browser apps to reach all users outside of the App Store.

  • 4.9.1 Each streaming game must be submitted to the App Store as an individual app so that it has an App Store product page, appears in charts and search, has user ratings and review, can be managed with ScreenTime and other parental control apps, appears on the user’s device, etc.

  • 4.9.2 Streaming game services may offer a catalog app on the App Store to help users sign up for the service and find the games on the App Store, provided that the app adheres to all guidelines, including offering users the option to pay for a subscription with in-app purchase and use Sign in with Apple. All the games included in the catalog app must link to an individual App Store product page

  • [And also]: Games offered in a streaming game service subscription must be downloaded directly from the App Store, must be designed to avoid duplicate payment by a subscriber, and should not disadvantage non-subscriber customer

How doesn’t Roblox fit into these criteria? According to sources, Roblox hosts millions of games on their platform, each with their own unique code base developed by a host of developers. Ultimately, Roblox defines itself as a game services and hosting platform rather than a company that owns its own game studios. This definition is core to how Apple perceives Roblox as an app: “Roblox games are backed by a growing suite of cloud services, including game hosting, data persistence, and virtual currency transactions. Games are made by both individuals and by teams using Roblox Groups.” Indeed, some of the largest games like Adopt Me are wholly operated and owned by independent studios like DreamCraft. To us, Roblox sounds more and more like a game streaming platform.

This begs the question on why the games aren’t individually screened and assessed by Apple. Scrolling through their platform, there seems to be a variety of glaring copyright infringements. At the time of this writing, viral Roblox game “Amongst Us” had 22.4k concurrent players with 24.7M lifetime visitors. What game is that based off of? Hmm, we wonder. Many games are famous for riffing and modding on older concepts (e.g DOTA vs. LoL), but how can such a clear infringement bypass the App Store guidelines and the Roblox terms of service?

5.2.1 Generally: Don’t use protected third-party material such as trademarks, copyrighted works, or patented ideas in your app without permission, and don’t include misleading, false, or copycat representations, names, or metadata in your app bundle or developer name. Apps should be submitted by the person or legal entity that owns or has licensed the intellectual property and other relevant rights.

To Roblox’s credit, they’re publicly tackling copyright infringement head on. The company recently partnered with Monstercat to provide developers a collection of legal, copyright-free music to use in their games. Considering the Twitch conundrum with DMCA, this feels like a proactive move.

So, how does Roblox continue to be on the App Sore despite being in violation of multiple clauses? Perhaps it’s that they collaborate closely with Apple to ensure all product and game development updates are in strict compliance with Apple’s own policy. In a response to Apple’s decision on xCloud, Microsoft notes that “All games available in the Xbox Game Pass catalog are rated for content by independent industry ratings bodies such as the ESRB and regional equivalents.” Apple does not approve of these independent ratings. It follows, then, that Roblox’s guidelines are somehow compliant with Apple’s, which through some special agreement, gives Roblox games automatic approval from Apple. Our assumption is that Roblox circumvents the ESRB rating bodies to work closely with the Apple team to ensure that all games/assets fit in with the Apple mold.

We can already see this special relationship play out in a variety of ways. One example is that Roblox prices its Premium subscriptions and in-app Robux (the Roblox currency) the same as it does online. So long as Roblox allows their virtual currency to be bought in both capacities — and importantly doesn’t tell people to buy it on a non-Apple platform — Apple won’t necessarily care. Contrast this with Spotify, which has users paying a higher price on mobile than on the web. Netflix is similar in that it only allows users to sign up via the web. To this end, the Reader App clause in the App Store guidelines states that subscriptions and content purchased on other operating systems can be carried over to iOS.

3.1.3(a) “Reader” Apps: Apps may allow a user to access previously purchased content or content subscriptions (specifically: magazines, newspapers, books, audio, music, and video). Reader apps may offer account creation for free tiers, and account management functionality for existing customers.

Perusing the Roblox Developer Hub, we see that Roblox has more favorable terms around the app tax. This is consistent with other larger companies that negotiate for a lower fee on the App Store.

Presumably, Roblox’s terms are even more favorable than 24.5% since they generated $1 billion dollars on mobile alone this past year, but the main point is that Roblox has chosen the “friends not enemies” route to their relationship with Apple. Perhaps this is the 200 IQ play of Roblox. In developing their relationship with Apple, they’ve found ways to bypass their tax. One such example is their gift cards program.

Tied with incentives and extra Robux, consumers are likely to buy gift cards to reload their Robux balance. Gift cards cannot be redeemed on Roblox apps, only on the browser, so they inherently avoid the app tax. Notably, Roblox also owns the entire end-to-end ecosystem on their platform.

Because Roblox operates the entire environment, it can measure behaviors at the user level but only make performance data available to the advertiser at the campaign level. — Eric Benjamin Steufert in Roblox Is The Next Big Games Advertising Platform

Their ecosystem is certainly an aspect that Roblox is already thinking of, but the implications are far-reaching. Advertisements are paid for in Robux by the developer to promote their game. By paying in Robux, this means that Apple will never see any profits from advertising on Roblox because they’re entirely paid for on a virtual currency that’s already been exchanged, and now, transacted against. Roblox will cycle Robux as much as possible through its system to maximize profit potential.

The point here is that Roblox is playing both sides of the game. It’s probable that they do violate the App Store games bundling/game streaming guidelines to some degree, but their relationship with Apple keeps in the green. To this end, they’re compliant with Apple’s policies insofar that account creation and payments adhere to the iOS guidelines. They also won’t be penalized since they’re following the right steps by iOS standards. But taken a step further, Roblox is creatively figuring out ways around the app tax on iOS. Apple has presumably driven at least $245 million dollars from Roblox (assuming 50/50 split on mobile revenue Android + iOS on $2billion lifetime revenue). The reality is likely much different.

TL;DR to Ball’s Tweet:

  • Individual Game Submission Outside Roblox: Assuming studios and sole proprietors comply with Roblox’s terms of service, then they’re probably good to go with Apple? Key word is probably.

  • Bundling Unapproved Games: Still unclear as Apple requires each game to be independently reviewed for Xbox/Stadia and listed as a separate entity. Perhaps the Roblox app is just a “catalog” (in the words of the streaming game clause).

  • Use of Digital Currency Not Bought on iOS: Roblox is likely exempt from payment restrictions due to Apple’s Reader App clause.

  • Roblox is a dope platform for games and independent studios. With this post, our hope was to share a few resources to help shed light on recent thoughts re: Roblox and the App Store


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