App Legal Launch Checklist

Minimum legal and compliance preflight before an AI-built or user-facing app gets real users.

This is not legal advice. It is an agent-side launch gate: identify risk, collect proof, and route final language to counsel before public release. The checklist is intentionally conservative because legal cleanup after launch is more expensive than a blocked deploy.

Trigger

Run this workflow before public launch, app-store submission, paid checkout, or broad beta when the product:

uses AI output in user-facing workflows
makes AI, automation, performance, professional-service, or safety claims
collects user data
ships through the App Store or Google Play
accepts payments or subscriptions
lets users post, upload, store, share, message, or search user content

If none of those apply, record that the checklist is not triggered and keep the proof with the release notes.

Required Inputs

product surfaces and screenshots
marketing copy, onboarding copy, emails, and ads
claims about AI, safety, accuracy, savings, automation, or professional substitution
data inventory, third-party SDK list, analytics/ad stack, and retention rules
privacy policy, terms of service, and acceptance UX
UGC surfaces, upload flows, report flows, and moderation policy
app-store metadata, if applicable

Four Launch Gates

Gate	Launch invariant	Proof artifact
FTC AI disclosure and claims	Do not treat "FTC AI disclosure" as a universal badge requirement. Treat it as a deception and materiality gate: if hiding AI involvement, limitations, incentives, or review/endorsement provenance would mislead a reasonable user, disclose it clearly. Substantiate AI performance and professional-service claims before publishing them. Do not create fake reviews, testimonials, or endorsements.	Copy review, claim substantiation notes, model-limitations copy, ad/influencer disclosure screenshots, review-generation policy.
Arbitration and terms	Terms must exist before payment, UGC, or account risk. Arbitration clauses are counsel-owned. If using AAA consumer arbitration, the clause needs consumer-protocol review and registry handling, and the small-claims path must remain available where required.	Counsel-reviewed ToS, versioned acceptance event, dispute-process copy, arbitration-provider fit check.
Privacy nutrition label and data map	Keep a real data inventory before writing privacy copy. Apple requires App Privacy details for new apps and updates, including third-party partner data collection. Google Play requires Data safety disclosures and a privacy policy, even when the app collects no data. Store answers must stay accurate as practices change.	Data inventory, SDK/vendor list, privacy policy URL, deletion path, Apple label draft, Google Data safety draft, screenshots after submission.
UGC liability	User content needs terms, community rules, report/remove flows, moderation, and audit logs. Section 230 can protect against publisher/speaker liability for third-party content, but it does not cover every category, including IP claims. DMCA safe-harbor posture needs a designated agent, public contact information, notice/counter-notice handling, and repeat-infringer policy when the service lets users post or store material.	Community guidelines, report flow, moderation queue, OpenAI Moderation API or equivalent guardrail, DMCA page, designated-agent registration, takedown/counter-notice process, repeat-infringer policy.

Ordered Steps

Name the triggered gates.
Collect the proof artifacts.
Mark every artifact as ready, missing, or counsel.
Block public launch on any missing gate.
Route counsel gates to a lawyer before publishing final terms.
Commit the accepted policy copy and screenshots with release notes.
Re-run the checklist whenever data practices, AI claims, UGC scope, payment flows, or app-store metadata change.

Implementation Notes

AI claims and disclosure

The FTC's useful rule of thumb is not "put an AI badge everywhere." The useful rule is "do not mislead users." AI claims need evidence, especially claims that the product can replace legal, medical, financial, security, or other professional judgment. Endorsements, influencer posts, reviews, and testimonials also need clear disclosure when a material connection or artificial provenance would affect user interpretation.

Arbitration and terms

Do not let an agent invent final legal terms. Draft issue lists and implementation hooks instead: where the ToS is linked, how the user accepts it, where versioning lives, what happens when terms change, and what event proves consent. The clause itself belongs with counsel.

Privacy labels

"Privacy nutrition label" means the store-facing privacy summary, not just a privacy policy. Apple and Google both make the developer responsible for knowing what the app and integrated third-party code collect, how data is linked, whether data is shared, and when answers need updating.

UGC liability

UGC means more than a public feed. Comments, uploads, profile bios, private messages, free-form prompts that can be shared, searchable user pages, collaborative documents, and imported media can all create user-content risk. Moderate before display when possible, log decisions, and keep an appeal/remove path that humans can operate.

Minimum Launch Packet

privacy policy
data inventory
app-store privacy labels, if applicable
terms of service
dispute-process decision
AI claim/disclosure review
UGC policy and DMCA posture, if UGC exists
moderation/reporting workflow, if UGC exists
release notes linking the accepted versions

Validation

A good run leaves a short release note:

Legal launch checklist:
- FTC AI/disclosure: ready | missing | counsel
- Arbitration/terms: ready | missing | counsel
- Privacy label/data map: ready | missing | counsel
- UGC liability: ready | missing | counsel | not triggered

If any gate is missing, ship only as private/internal preview or block the launch. If any gate is counsel, do not publish the final legal text until counsel signs off.

Timeline

2026-07-06 | Created from Kevin's legal-app checklist: FTC AI disclosure/claims, arbitration clause, privacy nutrition label, and UGC liability. The Instagram reel pointer was used as the social source for the DMCA/UGC framing; official FTC, Apple, Google Play, AAA, Section 230, and U.S. Copyright Office sources anchor the operational checklist. Source: User request, 2026-07-06; https://www.instagram.com/reel/DZs7mU3RJKE/