Telegram opens the door to a vast audience and offers distinctive features, most notably Telegram Mini Apps. These applications are hosted inside the Telegram ecosystem and benefit from Telegram’s user base. Yet they cannot operate in complete isolation from Telegram’s oversight. This transforms into requirements for developers, driven chiefly by applicable laws and by the policies of the app stores that distribute the Telegram application itself.

This Telegram Mini App Legal Guide highlights the principal obligations that Telegram imposes on developers and outlines wider legal considerations for launching and running a compliant application from day one.

Legal Obligations for Telegram Mini App Developers

Telegram is a platform provider only. Responsibility for the Mini App’s activities rests entirely with the project team. Accordingly, the application must individually comply with applicable laws. This means obvious prohibitions, such as refusing to sell weapons, drugs, or other illicit goods, but it also includes other obligations, for example, obtaining licences where a regulated activity is conducted.

Additionally, compliance is not limited to what must be avoided. Telegram expressly obliges all Mini Apps to moderate user generated content and to avoid presenting themselves as official Telegram products.

Payment Rules: Using Telegram Stars

Payment methods depend on the nature of the goods or services sold. Transactions involving physical goods may be processed through any suitable third party payment provider. By contrast, payments for digital goods and services must be settled exclusively in Telegram Stars. This restriction partially reflects the payment policies of Apple and Google.

Digital goods include subscriptions, in game currencies, extra game levels, extended playing time, and similar intangible products.

Handling Refunds and Disputes

Disputes should be addressed first between the user and the provider. If no agreement can be reached, the user may escalate the complaint to Telegram. When Telegram upholds a claim, it will refund the user and deduct the equivalent Stars from the Mini App’s balance.

Telegram provides technical tools for Mini Apps to process refunds but leaves the decision on whether to grant one to the developer. To resolve a dispute initially, every Mini App must respond to the /paysupport command in the associated bot. Projects may use an answer to this command to display a link to their terms and conditions, where the refund policy and dispute resolution procedure are set out. For a more detailed exploration of why terms and conditions are essential for the legal protection of a project, you may refer to our dedicated article.

Telegram also discourages the sale of digital items that cannot be withdrawn or suspended after a refund, because such arrangements may invite abuse.

Privacy Requirements

Developers must comply with Telegram’s privacy policy and all relevant data protection laws. Telegram supplies a standard privacy policy that applies automatically unless the developer registers an individual policy through @BotFather. The standard or individually provided policy is accessible for users on the Settings page of the bot associated with the Mini App.

Where the Mini App processes personal data in ways not determined by the standard policy, a tailored document is required by Telegram.

Specific Considerations for Web3 and Crypto Mini Apps

Telegram strongly supports the TON ecosystem, and policy changes introduced in early 2025 impose particular duties on Mini Apps that involve cryptocurrency or other Web3 functionality.

• Any Mini App that creates or distributes cryptocurrency tokens or other blockchain assets must do so exclusively on TON blockchain. It appears to concern mainly the Mini App’s own native tokens, rather than every token that might be shown.
• Wallet connections must use the TON Connect SDK. Other protocols may be used only to bridge assets from external blockchains.

Additionally, Telegram introduced new promotional rules for crypto. These rules apply not only to Mini Apps but also to associated bots, communities, and channels, and cover wallets, crypto assets, and platforms.

• It is prohibited to promote any cryptoassets that are not based on the TON blockchain.
• It is also prohibited to promote wallets that do not primarily support the TON blockchain.
• Most importantly, it is prohibited to promote or link to platforms that use or promote cryptoassets not based on TON. This restriction appears to apply broadly to most cryptocurrency exchanges. However, there is a limited exception for projects that have issued their tokens on the TON blockchain. They may provide a link to a licensed exchange where those tokens are traded.

Additional Legal Considerations

Beyond Telegram’s rules, a project should address additional legal matters, such as conduct regulatory analysis, establish appropriate corporate structure, incorporate an operating entity, define the powers of founders and directors, allocate intellectual property rights clearly, and execute agreements with team members. These steps provide a strong legal foundation for the project’s operations and can significantly enhance its credibility and attractiveness to users and potential investors.

Final Thoughts

Whether you are planning a new Mini App or enhancing the functionality of an existing one, our Aurum team offers specialised legal advice tailored to your specific stage of development, technical setup, and compliance objectives. We help you navigate evolving regulatory frameworks, platform policies, and legal risks to ensure your project is both innovative and compliant from the outset.

Please note that the guidance above reflects Telegram’s terms and policies as of May 2025. As the platform may amend its rules at any time, ongoing monitoring of Telegram’s official communications and policy changes is essential.

The information provided in this article is for general informational purposes only and does not constitute legal or regulatory advice. For specific legal guidance tailored to your business needs, we recommend consulting with a qualified legal professional.