PrivateCloudComputeLanguageModel returns rateLimited immediately while availability is available and quota is belowLimit

Hello Apple engineers and developers,

I am testing PrivateCloudComputeLanguageModel in an iOS reading app.

Environment:

  • Device: iPhone 16e purchased outside mainland China
  • OS: iOS 27.0.1 (24A446)
  • Our developer team has been approved for PCC access.
  • The app signature and embedded provisioning profile both contain:
    com.apple.developer.private-cloud-compute = true

The app makes one short, foreground, non-streaming request without automatic retry or structured generation:

“Translate this sentence into Simplified Chinese: The stars are beautiful tonight. Return only the translation.”

Immediately before the request:

  • model availability: .available
  • quotaUsage.status: .belowLimit
  • isApproachingLimit: false
  • isLimitReached: false
  • resetDate: nil

Nevertheless, the request fails after approximately 0.11–0.14 seconds with:

FoundationModels.LanguageModelError.rateLimited

No response content is generated. The error does not provide a reset time or additional metadata.

I tested both Apple Development and Ad Hoc builds. Both resulted in the same rate-limit message in the app UI. Changing the app’s bundle identifier did not change the result. Enabling a VPN also did not change the displayed message; I did not verify whether PCC traffic was routed through the VPN.

On October 13, 2026, at approximately 19:04 China Standard Time (UTC+8), I also ran Apple’s Shortcuts app on the same iPhone and selected “Use Model” with Cloud. It showed “Too many requests. Please try again later.” and generated no response.

I repeated the test after switching the device’s primary iCloud account to an account configured for the US region. The device was physically located in mainland China during these tests.

Could you please clarify:

  1. Can account, region, device, or service-side eligibility restrictions appear as rateLimited even when the model reports .available and quotaUsage reports .belowLimit?
  2. Is any additional activation or allowlisting required beyond PCC team approval and the signed entitlement?
  3. Which logs or diagnostics can identify the cause or retry time when resetDate is nil?
  4. Is the Shortcuts Cloud result useful evidence of a device- or account-level restriction, or does Shortcuts use an independent service policy?

Thank you.