Data residency for EU-hosted MCP and API when submitting a ChatGPT app

ChatGPT Apps SDK
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Hi everyone,

We’d like to submit a ChatGPT app to OpenAI and want to make sure our setup is compatible with OpenAI’s data residency and compliance requirements.

Our architecture is as follows:

  • Our main API is hosted in Europe (EU).

  • Our MCP server is also hosted in Europe and only uses anonymized user identifiers.

  • Some user preferences are stored in our API but will transit through our MCP. These preferences will therefore be exposed to OpenAI and can influence the model’s responses.

From what we understand, when submitting an app we currently need to configure data residency in “global” mode for the project.

Given that:

  • our data is hosted in the EU, and

  • our users are also located in Europe,

we have a few questions:

  1. Could our app submission be blocked or rejected by OpenAI because our infrastructure and users are in Europe while the project data residency is set to “global”?

  2. If there is a requirement or strong recommendation for alignment with EU residency, would hosting the MCP server outside the EU (while keeping our core API in the EU) be sufficient from OpenAI’s point of view?

  3. More broadly, is there any recommended architecture pattern for ChatGPT apps + MCP when you have EU users and EU infrastructure, but must still select “global” data residency in the Apps submission flow?

Thanks in advance for any clarification or guidance on the best-compliant setup for this scenario.