All new apps and app updates will require a privacy policy in order to be submitted for distribution on the Apple App Store or through TestFlight for beta testing purposes starting October 3.
The change to the App Store Review Guidelines are detailed in section 5.1.1 Data Collection and Storage of the App Store Connect portal. Developers will soon be required to include the privacy policy link in the App Store Connect metadata field, as well as within the app in an “easily accessible manner.” Currently, the rule to require the privacy policy link only applies to apps that require a subscription so it didn’t apply to producers of completely free or paid apps without subscriptions.