You're right, looks like Apple has a form for it if you public an app in the app store that supports encryption other than what is provided by Apple. I see post

You're right, looks like Apple has a form for it if you public an app in the app store that supports encryption other than what is provided by Apple. I see posts from app developers complaining about it and debating whether to check the "none" box or just leave France out. Presumably Google does the same. Now that I know, I'm actually surprised that Telegram would not have filed that form given its size. How could they have gotten it through Apple's review without doing it?