Your legal duties
paying real money is your responsibility.
When the wallet is on, you pay real money to people. Depending on your country and theirs that brings obligations the software cannot fulfil for you. This page lists the areas to check. It is not legal advice: consult a lawyer where you operate.
01Read this first
These docs describe what the code does. They cannot tell you which laws apply to you. Rules on payouts, rewards, identity checks, tax and consumer protection differ by country and change over time. Before you switch the wallet on, get advice from a lawyer (and a tax adviser) in the countries where you operate and where your users live.
The console says the same in the Wallet & payouts section: "You pay real money to users, so the legal duties are yours" (admin/src/manifest40.ts).
02Identity checks (KYC) and anti-money laundering (AML)
Paying out money can make you subject to identity-verification and anti-money-laundering rules, sanctions screening, and in some places licensing for money transmission or payment services, depending on amounts, methods and countries.
- The app does not verify identities. A "verified" account in this app only means a Google or Apple sign-in or a verified e-mail. That is not KYC.
- The country is self-declared. Payout country limits use the country the user picks; they are not a location or sanctions check.
- Use the tools the app gives you to stay within what you can check: low daily and monthly limits, review of every request, freezing accounts, and the fraud flags (Fraud signals and limits).
- Crypto payouts can carry extra obligations in many countries. If you are unsure, leave the crypto method off.
03Tax
Where applicable, payouts can be taxable income for users and may create reporting or withholding duties for you. Your own revenue from ad networks and offerwall providers is taxable for you. Keep records: the console's Business page, payoutEvents and the payout requests are a starting point, not tax reports.
04PayPal's terms
If you use PayPal, you must follow PayPal's User Agreement, its Acceptable Use Policy and the terms for Payouts, which is a feature for approved business accounts. PayPal can limit or close accounts that break them. Read them on PayPal's website for your country before you go live (PayPal setup).
05Consumer law and fair terms
Users who complete offers to earn cash rely on your promise to pay. Consumer law in many countries requires clear, fair terms. Publish payout terms that state at least:
- that cash comes only from completed partner offers and surveys (and grants), and that points have no cash value,
- the user share or how rewards are set, the hold period and why it exists,
- that providers can reverse completions and what happens then, including a negative balance,
- the minimums, fees, limits, countries, processing times and the review of every request,
- when you may reject or freeze, and how users can complain,
- what happens to the wallet when the account is deleted or the service ends.
Keep the in-app wallet notice consistent with them (console → Wallet & payouts → Wallet notice shown in the app).
06Update your terms and privacy policy
- Terms: add the payout terms above; link them from console → Legal.
- Privacy policy: the app now stores payout destinations (PayPal e-mail, crypto address, bank details such as account holder and IBAN), the declared country, a hash of the destination to detect reuse, payout history and device signals used for fraud checks. Say why, for how long, and who receives it (PayPal for PayPal payouts, your bank, your gift-card supplier).
- Retention: account deletion keeps wallet and payout records (Where the data lives). State how long you keep them and on what basis.
- Store forms: update the Google Play Data safety form and Apple's App Privacy answers.
07Store and ad policies
AdMob, Google Play and the App Store have their own rules on rewards and cash: Platform rules.
08Checklist before the wallet goes on
- Legal and tax advice obtained for your countries and your users' countries
- Payout terms published and linked from the app
- Privacy policy, Data safety and App Privacy updated for payout data
- PayPal (if used) account approved for Payouts, terms read
- Limits and review routine set; someone checks the Payouts page daily
- Funds available to pay what you owe users (Business page)