Crypto Referrals, Airdrops and Points: What App Store Guideline 3.1.5 Actually Allows

Most crypto growth teams treat referrals, airdrops, points and quests as one bucket called "rewards". The rulebooks do not. A referral pays an existing user for bringing in a new one. An airdrop sends tokens to wallets, with or without conditions. A points program awards a non-transferable off-chain balance. A quest pays for a defined action.

The gatekeepers stack. Apple decides what happens inside an iOS app, Google Play inside an Android app, and regulators decide what you may say to a consumer whatever the stores allow. Clearing two of three is normal. The interactive stack below runs your own mechanic and market through all three at once.

Guideline 3.1.5 covers cryptocurrencies in five sub-points. Only the fifth deals with rewards, but compliance documents cite the wrong ones, so all five appear below verbatim, (iv) abridged to its operative clause.

Apple numbers these sub-points in roman, so there is no Guideline 3.1.5(b). Guideline 3.1.5(v) binds "cryptocurrency apps", not every app: a consumer fintech running refer-a-friend is arguing a different rule, while a wallet running the identical program sits inside this one.

Guideline 3.1.5(v) bans paying "currency for completing tasks". It does not say who may be paid, whether rewarding the sender of an invitation differs from rewarding the person who receives it. Apple never published that line. A rejection message drew it.

In an App Review rejection message posted by a developer to the Apple Developer Forums in February 2021 (thread 674832, "Referral programs rejected 3.2.2"), the reviewer wrote:

The developer attributed the rejection to Guideline 3.2.2 in his thread title, though the quoted message cites no guideline number, and no Apple staff member replied.

The operational rule inside that message is one line: reward the sender, not the recipient. The reviewer's stated reason is chart manipulation, paying the recipient pays for the download, and downloads drive ranking. It is a rejection message, not published policy, so treat it as evidence of how review has been applied, not a rule you can cite.

Apple has not answered the obvious follow-up. Thread 693770, posted November 2021, asks why Coinbase can run "a button on the home screen of their app saying 'Get $10'" if 3.1.5(v) means what it says. A second developer asked the same in February 2022. No Apple-badged reply was posted.

One adjacent rule is published. Guideline 3.2.2(x) says apps "must not force users to rate the app, review the app, download other apps, or other store-related actions in order to access functionality". That is about compulsion; it does not rescue a crypto referral, because 3.1.5(v) bans the payment.

Across the 19 Google Play Developer Program Policy pages reviewed for this article, including User Ratings, Reviews and Installs; App Promotion; Spam; Payments; Ads; Subscriptions; and Deceptive Behavior, there is no rule governing refer-a-friend programs or rewards for inviting other users. "Referral" appears once, in the Spam policy's affiliate rule against apps "whose primary purpose is to drive referral traffic to a website", about apps built to funnel sign-ups elsewhere, not about inviting a friend into your own app. That finding is scoped to those 19 pages, not to Google's whole policy centre.

What Play does prohibit is specific. Its User Ratings, Reviews, and Installs policy bars "incentivized reviews and ratings, or incentivizing users to install other apps as the app's main functionality", and adds: "Don't offer rewards or incentives for ratings or reviews." A June 2017 Android Developers Blog post defines it: an action is incentivized "if a user is offered money, goods, or the equivalent in exchange for the action, be it a rating, review or install".

The Blockchain-based Content policy requires apps that "enable users to earn Tokenized Digital Assets" to declare this on the Financial features declaration form in Play Console, and states: "You may not promote or glamorize any potential earning from playing or trading activities." Most airdrop banner copy fails it.

What kills a quest campaign on Android is the Real-Money Gambling, Games, and Contests policy, under Gamified Loyalty Programs, for game apps. Loyalty rewards tied to a qualifying monetary transaction "may only be awarded and redeemed on a fixed ratio basis", with redemptive value that "may not be wagered, awarded or exponentiated by game performance or chance-based outcomes". A random token payout sits outside that ratio.

The stack tool above runs these rows interactively; the two tables below are the static record. Where Apple has published nothing and no rejection message covers the case, the verdict is unresolved.

So: it ships on Android in the US and Germany, on iOS only if the recipient reward is removed, is unresolved on the web-plus-in-app route, and is off in the UK. The design decisions below settle which of those you are actually shipping.

Clearing Apple and Google Play does not clear the law. Regulators govern what you say to a consumer, wherever you say it.

United Kingdom. COBS 4.12A.7R(1) states that a firm must not communicate or approve a financial promotion for a restricted mass market investment that offers a retail client "any monetary or non-monetary incentive". Narrow exceptions follow in 4.12A.7R(2) to (4), so it is not an unqualified blanket ban. Guidance at COBS 4.12A.8G(2) names "offering bonuses where the client refers another person" as an illustrative example, guidance, not a rule. The FCA's review of firms' preparations, published 7 September 2023 and last updated 6 February 2026, says the ban applies "even when there is no requirement to invest to gain the benefit", reaching actions such as "registration or sign-up". One thing the FCA has not done: FG23/3 does not contain the word "airdrop". The full regime is in the FCA crypto promotion regime.

European Union. MiCA Article 7(2), as reproduced in ESMA's Interactive Single Rulebook, states that where a white paper is required, "no marketing communications shall be disseminated prior to the publication of the crypto-asset white paper". An airdrop announcement is a marketing communication, so the timing bar catches it. The detail is in MiCA marketing rules for crypto brands.

United States. Two FTC rules split cleanly. 16 CFR §255.5(a), in its 2023 revision, requires a material connection between endorser and seller to be "disclosed clearly and conspicuously". 16 CFR §465.4, effective 21 October 2024, bars compensating anyone for reviews "expressing a particular sentiment, whether positive or negative", sentiment, not posting. So "post about us, get tokens" is not a §465.4 violation on its face, but the post it produces is an endorsement with a material connection, so §255.5 applies.

Apple, Google Play and the regulators all narrow the same thing: paying users to recruit users. When that loop is blocked on your largest surface, growth moves to distribution, reaching people who are not yet users, instead of paying the users you have to fetch them.

That is what crypto clipping campaigns do. Lumina Clippers runs short-form video distribution through a network of 62,900+ vetted clippers who have driven 18B+ verified views, with campaigns live in 24 to 72 hours. No reward reaches a downloader, no incentive attaches to a sign-up, and there is nothing in the mechanic for App Review to reject.

Budgeting the switch: what crypto marketing costs, and the full sequence for how to market a token launch. And once the clips are running, you can measure the distribution on-chain: trace a clip view to a funded wallet.

Apple. App Store Review Guidelines, Guidelines 3.1.1, 3.1.5 and 3.2.2. Apple Developer Forums, thread 674832, "Referral programs rejected 3.2.2", February 2021, the rejection message quoted above. Apple Developer Forums, thread 693770, "Are cryptocurrency referral programs always in violation of App Review Guideline 3.1.5(v)?", November 2021, unanswered.

Google Play. User Ratings, Reviews, and Installs policy; Spam policy, Webviews and Affiliate Spam; Blockchain-based Content policy; Real-Money Gambling, Games, and Contests policy; Android Developers Blog, "Google Play's policy on incentivized ratings, reviews, and installs", June 2017.

Regulators. FCA Handbook, COBS 4.12A; FCA, "Firms' preparations to comply with the cryptoasset financial promotions regime", published 7 September 2023, last updated 6 February 2026. ESMA Interactive Single Rulebook, MiCA Article 7. eCFR, 16 CFR §255.5; eCFR, 16 CFR §465.4, effective 21 October 2024.

Method. The platform verdicts are the guideline and policy text applied to each mechanic; the sender-vs-recipient line is one App Review rejection message, treated as evidence of review practice rather than published policy. Nothing here is legal advice. Sources checked at publication, 4 August 2026.