If your app implements account creation, then it will likely be taken down unless either your app removes create-account support or the API and your app implement delete-account support, as a user would reasonably expect that you're able to delete the accounts that you create.
If you do not implement account creation, then you're unlikely to be held responsible for account deletion, as a user would reasonably understand that your app is not responsible for creation or deletion of accounts.
EDIT: Elsethread, someone asked "What if I create accounts on the blockchain?", and since it's possible you'll come around to that idea next — the app would have to interact directly with the blockchain, so you'd probably get rejected for a whole array of reasons, such as but not limited to that you're storing account data on the blockchain. And I wouldn't envy you trying to explain why you shouldn't be continuously fined for GDPR violation in the EU, either.
> And I wouldn't envy you trying to explain why you shouldn't be continuously fined for GDPR violation in the EU, either
This is kind of a bizarre thought to me. You think anyone who provides software that - without involving any services hosted by that person - should be liable for what users do with this software? If this were to hold up in court (which I'm confident it wouldn't), then open-source software would be done.
Or is this a problem of terminology? In the scuttlebutt case, there is no actual "account" - just a key. Maybe one should simply replace the string "Create account" (if there is such a string) with "Generate key/identity".
I don't see why that would be any different. If it was, then companies who find enough value in not providing a deletion option could pay someone to submit an app on their behalf. There's no way for Apple to know whether or not an app submitted by a third party is actually full independent of the service.
Or just stop buying Apple devices? That way the duopoly can shift from iOS/Android to Android/<Linux phones, or some other open alternative>.
I realize many people are heavily invested in the Apple ecosystem, especially since Apple encourages that with the proprietary integrations between their different devices, but there's a point when one should realize they have a choice. It's a walled garden not a prison.