The merchant of record for your in-app sales isn't you, it's Apple or Google, and that decides your refunds

Somewhere between your customer's thumb and your bank account sits a company that is legally the seller of your app, and it is Apple or Google, not you. That company is the merchant of record. It is the party the customer actually pays, the party named on the receipt, and the party a bank comes after when a charge is disputed. On the App Store that party is always Apple. On Google Play it is Google in some countries and you in most of the others. Which one it is decides who can issue a refund, who pays for a chargeback, and whether anyone ever asks for your side.

This one legal fact sits underneath everything that feels confusing about app refunds. It is why you cannot refund an Apple customer yourself no matter how badly you want to, why Google can pull a refund straight out of your next payout, and why there are only two moments in either store where anyone asks you for evidence. Here is who the merchant of record is on each store, and what that means for your refunds and your money.

Who the merchant of record actually is

The merchant of record is the business that sells the product to the customer and collects the payment. Legally, it is the seller of record: the entity the customer has a contract with, the name that belongs on the receipt, the party responsible for charging tax, and the party a customer or a card issuer turns to for a refund or a dispute. In a normal store, the shop on the corner is its own merchant of record. In the app economy, the store platform takes that role, and you sit behind it as the supplier.

The merchant of record is not the same as the payment processor

It is easy to blur the two, but they are different jobs. A payment processor moves the money: it takes the card number, talks to the bank, and settles the funds. The merchant of record is the legal seller behind that transaction. Google Play Billing processes every purchase on Google Play, and Apple's system processes every purchase on the App Store, but processing a card is not the same as being the seller. On Google Play the payment processor is always Google, while the merchant of record can be Google or you. That split is the whole reason this topic is confusing, and it is where the money and the liability actually live.

On Apple, you are never the merchant of record

The App Store has no country-by-country nuance here. When you accept Apple's Paid Applications Agreement, you appoint Apple and its subsidiaries as your agent, or in some regions your commissionaire, for the marketing and delivery of your app and its in-app purchases to customers. A commissionaire sells in its own name while acting on your behalf. Either way, the customer is buying from Apple. Apple sets up the transaction, collects the payment, and hands you your proceeds after its commission. You are the supplier, never the seller of record.

The refund consequence is absolute. Only Apple can refund an App Store purchase. There is no developer refund button and no refund API, so a customer who wants money back does not come to you, they file at reportaproblem.apple.com and Apple reviews and decides. Your single point of input is the CONSUMPTION_REQUEST: when a customer disputes a consumable or an auto-renewable subscription, Apple's server notification gives you 12 hours to send consumption data before Apple rules. Apple still decides. Card chargebacks are handled the same way, resolved between the cardholder's bank and Apple, with no case for you to work.

On Google Play, it depends on the buyer's country

Google Play is where the merchant of record splits in two, and the dividing line is where the buyer lives. Under section 3.4 of the Google Play Developer Distribution Agreement, Google is the merchant of record for products sold to users in a defined set of countries and territories. That set covers the European Economic Area, the United Kingdom, and a long list of nearby places such as Iceland, Norway, Liechtenstein, Monaco, Gibraltar, and the French overseas territories. For every other user, the agreement says you are the merchant of record. In plain terms, Google is the seller across the EEA and the UK, and you are the seller in the United States, Canada, Japan, Australia, and most of the world.

Here is the part that trips people up: even where you are the merchant of record, Google Play Billing still processes the payment, and Google still administers refunds. Section 3.8 of the same agreement says you authorize Google to give users refunds under the Google Play refund policies, and that Google may deduct those refunds from your payments. So on Google Play you can carry the seller's duties, the tax and the chargeback liability, while Google keeps the refund controls. A customer can self-serve a refund within 48 hours of purchase, once per app, and Google issues it and bills it back to you. After that window the request routes to you, and your one evidence channel is the 24-hour chargeback review through the orders.reviewrefund flow.

What being the merchant of record costs you in money

The seller of record is the party that owes the state its tax and the bank its disputed charge. That is where the merchant-of-record question stops being paperwork and starts showing up in your payout.

Tax follows the seller

Where a store is the merchant of record, that store determines, collects, and remits the sales tax or VAT on the purchase. Apple does this for App Store sales, and Google does it across the EEA and the UK where Google is the seller. Where you are the merchant of record on Google Play, that duty can land on you, which is why a US or Japanese sale is treated differently from a German one. The refund echo of this is simple: when a purchase is refunded, the tax handled by the seller of record unwinds with it, and only the party that collected it can reverse it.

Chargebacks now follow the seller too

This used to be theoretical on Google Play, because Google absorbed chargeback losses. It is not theoretical anymore. For orders placed after August 3, 2026, Google shifts chargeback costs onto the developer: as the merchant of record on those sales, you carry the purchase price minus Play's service fee, plus the bank's chargeback fee. Payment-industry sources put that bank fee somewhere around $15 to $25 per dispute, and it stacks on top of the lost sale. Google points developers at the same 24-hour review API as the way to fight illegitimate disputes, which makes that one evidence window the only lever you have on a cost that is now yours.

On the App Store, the math is different because you are never the seller. A card chargeback there is settled between the bank and Apple, and you never handle the case. You still feel a granted refund as a reversal of your proceeds, but the dispute mechanics, and the bank fee, sit with Apple as the merchant of record.

How to read your refunds once you know who the seller is

Knowing the merchant of record turns a messy refund feed into two clean piles. The first pile is the refunds nobody asked you about, because the seller of record decided them alone: Apple's own refund calls, Google's 48-hour self-service returns, support refunds, and voided purchases. The second pile is the two contestable flows, the 12-hour consumption request and the 24-hour chargeback review, where your evidence is a documented input before the decision.

• Judge your refund protection by the contestable pile only. A store-issued refund never had a window you could act in, so it is not a fight you lost.
• Where you are the merchant of record on Google Play, treat the chargeback column as a live cost after August 3, 2026, and answer every review inside the 24-hour window.
• On Apple, your only move is the consumption request, so send accurate delivery and usage data every time, because it is the sole input Apple accepts.
• Keep acknowledging purchases server-side. An unacknowledged purchase is refunded and revoked automatically at about 72 hours, and that is a self-inflicted refund no merchant-of-record status can excuse.

This is exactly how RefundHalt reads the store feeds. Consumption requests and chargeback reviews sit front and center with their outcomes and deadlines, and the refunds the merchant of record decided without you are recorded in their own place, so your ledger is complete without pretending you could have contested them.

The short version

The merchant of record is the legal seller of your in-app purchase, and it is the store, not you, that mostly holds that role. Apple is the merchant of record for every App Store sale, so only Apple can refund and your one input is the 12-hour consumption request. On Google Play, Google is the seller across the EEA and the UK, and you are the seller in the United States and most of the world, where you also carry the tax and, for orders after August 3, 2026, the chargeback cost. Google Play Billing still processes the payment and administers refunds either way. Once you know who the seller is on each sale, your refund feed splits cleanly into what you could never contest and the two windows where your evidence still counts.