Google Play treats money as a regulated category, not an ordinary one. If your app lends, helps someone lend, or advises on money, the Google Play Financial Services policy applies to you — and in 2026 there are two separate obligations running in parallel: the financial features declaration that every published app must file in Play Console, and the licensing and disclosure rules that a personal loan app must satisfy in each country it targets.

This is a working checklist for the second one, written for teams that are preparing a submission rather than arguing about it afterwards. It covers the metadata you must publish (maximum APR, repayment window, a representative total-cost example), the eight permissions Google forbids loan and credit apps from requesting, the country-by-country licences that have to be uploaded with your declaration (India, Indonesia, the Philippines, Nigeria, Kenya, Pakistan, Thailand and the United States), how earned wage access is treated differently from a personal loan, and the review patterns that most often end in a rejection. One warning up front, because it decides most cases: Google must be able to establish a connection between your developer account and the licence holder. Everything else in this article is easier to fix than that.

1. Two obligations, and most teams plan for only one

Google split the work deliberately. The declaration is a Play Console form on the App content page (Policy and programs → App content), and it is a condition of staying published — not a launch-day extra. The policy rules are what the form is checked against: metadata disclosures, prohibited permissions, country licensing.

Read the scope carefully, because it is wider than most developers assume:

Pick your category accurately. Declaring "Loan facilitator" when you are really a direct lender — or the reverse — changes which documents you owe, and a mismatch between the declaration and the store listing is one of the fastest ways to a policy strike.

2. What a loan app must publish in its own metadata

Personal loans are defined broadly: money lent from a person, organisation or entity to a consumer on a non-recurring basis, not to finance a fixed asset or education. Payday loans, peer-to-peer loans and title loans sit inside the definition; mortgages, car loans and revolving credit lines like credit cards sit outside it.

Any app that provides personal loans — direct lender, lead generator, or connector to third-party lenders — must set the App category to "Finance" and disclose, in the app metadata:

  1. Minimum and maximum repayment period. A user must be able to see, before downloading, how long they have to repay.
  2. Maximum Annual Percentage Rate (APR) — ordinarily the interest rate plus fees and other costs expressed over a year, or an equivalent rate calculated consistently with local law.
  3. A representative example of the total cost of the loan, including principal and all applicable fees. Not a range, not "starting from" — a worked example.
  4. A privacy policy that comprehensively discloses the access, collection, use and sharing of personal and sensitive user data, within the limits the policy sets.

And one hard prohibition: apps that promote personal loans requiring repayment in full in 60 days or less from the date the loan is issued are not allowed. Google calls these short-term personal loans, and no amount of disclosure makes them acceptable.

The description is where policy review reads first. If your listing answers "how much, how long, what does it really cost" in plain numbers, you have removed the most common reason a loan app is sent back — and given users the information the policy exists to force into the open.

3. The United States: a 36% ceiling and a TILA-consistent number

In the United States, Google does not allow apps for personal loans where the APR is 36% or higher, and the maximum APR displayed must be calculated consistently with the Truth in Lending Act (TILA). The rule reaches direct lenders, lead generators and everyone who connects consumers with third-party lenders, so an aggressive affiliate funnel is not an escape route.

Practical consequence: your compliance team's APR figure and the number in your store listing must be the same number, computed the same way. If your in-app disclosure shows a TILA APR and your listing shows a nominal interest rate, the listing is the one under review.

4. Eight permissions loan and credit apps may not request

This is the section that quietly disqualifies the most builds. Personal loan apps, apps whose primary purpose is facilitating access to personal loans or lines of credit, accessory loan or credit apps (loan calculators, loan guides), and earned wage access apps are prohibited from accessing sensitive data such as photos and contacts. The banned permissions are explicit:

The reasoning is not cosmetic. Contact-list harvesting and photo access are the classic tools of predatory collection practices, and the policy removes them by default rather than case by case. Two details matter for engineering: the prohibition covers accessory apps, so a calculator bundled by the same team is not exempt, and permissions that a third-party SDK merges into the merged manifest still count. Audit the merged manifest, not the source manifest.

5. Country licensing: what has to be uploaded, and to whom it must point

Where a loan app targets the countries below, Google requires proof of licensing or registration, collected through the financial features declaration. The formal requirement is stronger than "have a licence": Google must be able to establish a connection between your developer account and the document you provide, and it may request further information at any time.

Notice how each country asks for something slightly different: a list membership, a licence copy, a registration number, an approval letter, or a disclosure in the listing itself. A generic "we are licensed" paragraph in the description satisfies none of them.

6. Earned wage access is not a personal loan — but it is still declared

Google defines earned wage access (EWA) separately: the user can reach wages already earned but not yet paid, repayment runs automatically by payroll deduction or autopay linked to the bank account, a failed autopay charges no extra interest, penalties or fees, the advance is capped at wages earned in the current period, and the service charges a low flat or percentage fee rather than interest. Google's own guidance points at roughly $1–$5 per transaction, or 1–5% of the advance, as a reasonable, transparent fee.

EWA apps must set the app category to Finance and disclose repayment terms, all fees including subscription and transaction fees, and a representative total-cost example. Where the country requirements above apply to EWA to the extent applicable in that jurisdiction, they apply here too. Structuring an expensive short-term loan as "EWA" does not move it out of the personal loans rules.

7. How the declaration is actually filed

  1. Open Play Console and go to Policy and programs → App content.
  2. Under Financial features, select Start and declare every financial feature the app offers, or certify that it offers none. Select Next.
  3. If additional documentation is required, complete every row of the country table — each row expands to collect the specific document that country asks for.
  4. Save to submit. Save as draft if the paperwork is still arriving; Discard changes starts the entire form again.

Submitted information is reviewed as part of app review. Issues surface by email, in Play Console notifications and on the Policy status page (Policy and programs → Policy status) — which is the page worth checking before you appeal anything, because it names the specific declaration problem rather than the general outcome.

8. What failure looks like in practice

9. The pre-submission checklist

  1. App category set to Finance.
  2. Financial features declaration submitted — including the "none" certification if that is the accurate answer.
  3. Maximum APR stated in the listing, calculated consistently with local law (TILA for the US).
  4. Minimum and maximum repayment period stated.
  5. Representative total-cost example with principal and every fee.
  6. Privacy policy live and consistent with actual data handling.
  7. Merged manifest free of the eight prohibited permissions.
  8. Country licences uploaded per the table in section 5, each one valid and current.
  9. The link between the developer account and the licence holder documented and explainable in one sentence.
  10. Named licensed partners (NBFC, bank, DCP, DML) disclosed in the app description where the country requires it.
  11. US target markets: no APR at or above 36%, and no repayment-in-full within 60 days anywhere.
  12. A named owner inside the team for policy mail, so a request for additional documents does not sit unread past the response window.

10. Where KappS fits

KappS works on the operational side of publishing at scale: keeping developer accounts, payment profiles and store listings in a state that holds up to platform scrutiny. For financial services apps that means preparing and submitting compliant material — mapping which declarations and licences a given market requires, assembling the document set so the licence holder and the account clearly belong together, checking the store listing against the disclosure rules, and reviewing the manifest before the build ships.

What we do not do is find a way around licensing. Google's requirement is that the app be offered by an entity that is genuinely allowed to lend in that market; there is no version of the policy where a compliant-looking listing substitutes for the licence, and attempts to present one end in account termination rather than approval. The durable path is the boring one — accurate declaration, real licence, honest numbers.

Sources (Google official documentation): Play Console Help — Financial Services policy (Personal loans, Earned Wage Access, General requirements, Country specific requirements); Provide information for the Financial features declaration; Financial features declaration categories; Permissions policy; United States Truth in Lending Act (TILA) APR calculation.