Can Agencies Run Apple Ads for French Companies?
Apple’s France specific Sapin Law restriction explained for agencies, app owners, account admins and user acquisition teams

The normal agency setup for Apple Ads is straightforward:

Client owns the app
→ Agency links the client’s App Store Connect account
→ Agency manages campaigns from its agency account

That setup can work across many markets.

France is different.

When the app belongs to a company that is registered, established, or otherwise located in France, Apple restricts an agency, agent, or representative from undertaking the campaign for that client on the France App Store.

This is not a bidding issue, an App Store Connect linking error, or a payment problem. It is a country-specific eligibility rule connected to French media-buying law.

The Rule in Plain English

An outside agency cannot use its own Apple Ads account to run a France App Store campaign for an app owned by a French company.

Apple’s help documentation summarizes the requirement like this: the advertiser that owns the app must also own the Apple Ads account used to promote it in France.

The practical conclusion is:

French app owner
+ Agency-owned Apple Ads account
+ France App Store campaign
= Not eligible under Apple’s published rule

This can surprise agencies because Apple normally supports agency accounts and linking to client App Store Connect accounts. The standard technical connection does not override the France-specific restriction.

Why France Has a Different Rule

Apple cites French laws known collectively as the Sapin Law:

• Law No. 93-122 of January 29, 1993, commonly called Sapin I.
• Law No. 2016-1691 of December 9, 2016, commonly called Sapin II.

The broad purpose described by Apple is to make media buying more transparent.

Apple’s country-specific terms translate that legal framework into a platform rule. When a party is acting as an agent, it may not undertake a campaign on behalf of or for the benefit of a French advertiser on the France App Store.

The key point for app marketers is not the history of the legislation. It is the account structure Apple requires today.

What Apple Considers a French Company

Apple’s definition is broader than “incorporated in France.”

For this rule, a French company can be a company that is:

• Registered in France.
• Established in France.
• Otherwise located in France.

That means a company incorporated elsewhere may still need careful review when it has a French office, branch, establishment, or meaningful legal presence.

Do not decide based only on the address used for the advertising credit card. Check the legal owner of the app and the company’s actual relationship with France.

When the status is unclear, ask the client’s legal or finance team and confirm the setup with Apple Ads support.

What Counts as Acting as an Agent?

In practical marketing terms, you are likely acting as an agent or representative when your company runs campaigns for a client’s app and the client receives the benefit.

Common examples include:

• A performance marketing agency managing Apple Ads for a client.
• A freelance media buyer using an account that belongs to the freelancer or consultancy.
• A holding company or external partner operating campaigns for a separate French legal entity.
• A reseller or intermediary buying the media and billing the French app owner.

Changing the account name or hiding the commercial relationship is not a solution. Apple’s France terms explicitly prohibit secretly acting as an agent or concealing that agency role.

The Setup That Causes the Problem

Here is the scenario most likely to fail:

App owner: French company
Apple Ads account owner: External agency
Campaign market: France
Campaign operator: Agency team

The app can be correctly linked. The ads can be approved. The payment method can be valid. Every keyword and bid can be configured properly.

The campaign can still be ineligible because eligibility is decided before performance matters.

This is why troubleshooting the campaign as a delivery problem wastes time. The issue is ownership and representation.

The Setup Apple Expects

Apple’s published help says the advertiser promoting the app in France must own both the app and the Apple Ads account.

That leads to this structure:

App owner: French company
Apple Ads account owner: Same French company
Campaign market: France
Account control: French advertiser

The French company should create and control its own Apple Ads account, link it to the App Store Connect account that owns the app, complete billing and legal details, and make the required France declarations truthfully.

Because Apple also says an agent is not eligible to run the campaign on behalf of the French company, do not assume that moving agency users into the client account automatically solves the restriction. Apple’s public wording does not provide enough detail to promise that every delegated-access model is acceptable.

The safe operating model is for the French advertiser to remain the actual campaign operator and decision-maker inside Apple Ads. The agency can provide work outside the platform, such as:

• Campaign structure and keyword plans.
• Bid and budget recommendations.
• Custom Product Page strategy.
• Reporting templates and analysis.
• Creative testing plans.
• Weekly optimization instructions.

For direct account access or campaign execution by agency staff, get written clarification from Apple Ads support for the exact setup.

The Required Campaign Question

During campaign creation, Apple may ask:

Is the app you’re promoting owned by a French company (i.e. a company that is either registered, established or otherwise located in France)?

The correct answer depends on the app owner, not the agency location.

• French client owns the app: Yes.
• Non-French company owns the app with no French establishment: No.
• Agency is based outside France, but its client is French: Yes.
• Campaign targets France, but the app owner is a US company: No.

See Apple Ads: Is Your App Owned by a French Company? for a full decision guide.

Why a Campaign May Show as Incomplete

Apple says a France campaign can remain marked Incomplete when the required agency or French-company declarations have not been completed.

This can happen when:

• The account previously identified itself as an agent but has not answered the campaign-level France question.
• An account admin has not completed the required declaration.
• Multiple account admins need to answer before Apple updates the status.

The practical check is simple:

1. Open the Campaigns dashboard.
2. Look for Edit Campaign Settings.
3. Complete the France-related question truthfully.
4. Confirm whether every account user with the Admin role has completed any required declaration.

Completing the question can resolve an incomplete status when the campaign is otherwise eligible. It will not make an agency-owned campaign eligible when the underlying structure conflicts with Apple’s France rule.

Can an Agency Run the App in Other Countries?

The specific restriction discussed here applies to campaigns disseminated in France, including the France App Store.

That means an agency may be able to manage campaigns for the same French-owned app in other storefronts, subject to Apple’s general terms and any other country-specific requirements.

A practical international structure could look like this:

France campaign
→ French advertiser-owned account and direct operation

Other eligible markets
→ Separate review of the agency model and local terms

Do not combine France with a large list of countries and assume one account model is valid everywhere. Separating France can make eligibility, invoicing, access, and reporting easier to audit.

What Agencies Should Change in Their Onboarding

This rule is easy to catch before a campaign is built. Add these questions to the client onboarding form:

1. Which legal entity owns the app in App Store Connect?
2. Is that entity registered, established, or otherwise located in France?
3. Will campaigns target the France App Store?
4. Who owns the Apple Ads account?
5. Has Apple confirmed the proposed access model for any external agency users?

Do this before requesting access, building campaign groups, or preparing billing.

A ten-minute ownership check can prevent a campaign from being built inside the wrong account.

What Not to Do

Do not select No because the agency is outside France.

Do not select No because the advertising invoice is paid outside France.

Do not create an agency-owned account with the client’s name and treat that as client ownership.

Do not hide that the campaign is being run for a French advertiser.

Do not assume App Store Connect linking proves campaign eligibility.

These workarounds solve the screen, not the compliance problem.

A Practical Agency Workflow

For a French-owned app that needs Apple Ads in France, use this sequence:

1. Confirm the exact legal entity that owns the app.
2. Confirm that the France App Store is included in the media plan.
3. Have the French advertiser create and control the Apple Ads account.
4. Link that account to the correct App Store Connect organization.
5. Complete the agent and French-company declarations accurately.
6. Ask Apple Ads support to confirm any planned access for outside agency staff.
7. Keep a written record of the confirmed account model.
8. Build France separately from other markets when that makes ownership and reporting clearer.

This is less convenient than the standard agency-account workflow. It is still better than launching from the wrong account and discovering the restriction after the campaign is ready.

The Takeaway

Agencies can manage Apple Ads for many clients and markets, but France has a specific restriction for French-owned apps.

When a French company owns the app, an outside agency should not use its own Apple Ads account to undertake the campaign on the France App Store. Apple says the advertiser that owns the app must also own the Apple Ads account used for the France promotion.

The fix is not a different bid, a new payment method, or a new campaign.

The fix is the correct ownership and operating structure.

Sources

• Apple Ads — Countries and Regions Specific Terms
• Apple Ads Help — Solve account setup and access issues

Information checked on August 3, 2026. This article explains Apple’s published platform rules and is not legal advice.