Apple will change the way it asks users for permission to use personal data for advertising across almost all EU markets after Germany’s competition authority concluded that its existing consent process treated third-party apps less favourably than Apple’s own services.
The Bundeskartellamt has accepted commitments requiring changes to Apple’s App Tracking Transparency framework and related consent prompts, giving the company four months to introduce the revised arrangements.
Under the settlement, consent requests presented by Apple and third-party developers will need to follow a more neutral format. Germany’s regulator found that differences in wording, visual presentation, and the sequence of choices could make users more likely to consent to data processing by Apple than by other businesses operating on its devices.
Third-party app providers will also receive greater scope to coordinate Apple’s system-level consent prompt with their own data protection messages. The change is intended to reduce overlapping consent requests and give developers more room to explain why they are asking users for permission.
Although the case was brought in Germany, the commitments are set to apply across almost all EU markets, extending their effect far beyond a conventional national competition decision.
Apple introduced App Tracking Transparency, commonly known as ATT, in 2021. It requires apps to obtain explicit permission before tracking users across applications and websites owned by other companies, giving users more direct control over how their data is used while disrupting established advertising and attribution practices across the mobile economy.
Advertisers and app developers have long relied on cross-service data to determine whether an advert resulted in a download, purchase, or other action. Since ATT was introduced, many have increased their reliance on first-party data, contextual advertising, aggregated measurement, and other methods that depend less heavily on individual identifiers.
The German investigation focused on whether Apple was subject to comparable constraints inside its own ecosystem. Proceedings opened in 2022 under German competition rules applying to companies considered to have paramount cross-market significance, alongside European competition law.
Rather than removing ATT or changing the underlying requirement for user consent, the settlement addresses the design of the process and whether a platform owner can apply privacy rules in a way that gives its own services an advantage.
That question has become increasingly prominent in European technology regulation. Large digital platforms are expected to protect personal data and maintain secure operating environments, while competition authorities are examining whether control over operating systems, app stores, and advertising infrastructure can also be used to favour platform-owned products.
Advertising technology has been particularly exposed to those changes. Mobile measurement became more complex after ATT was introduced, while publishers, retailers, and consumer brands increased investment in logged-in environments and customer data collected directly through their own services.
Consent architecture therefore influences more than the wording of a pop-up notification. It can affect the amount of data available to advertising businesses, the quality of campaign measurement, and the relative strength of platform-owned advertising products compared with independent providers.
Other European regulators have also scrutinised Apple’s tracking framework. French authorities imposed a €150m penalty in 2025 over the implementation of ATT, while Italy’s competition authority has pursued separate enforcement over privacy-related commercial practices.
Those cases form part of a broader regulatory challenge for technology companies whose privacy, security, and marketplace rules also shape competition within their ecosystems. A policy may serve a legitimate user-protection purpose while still attracting scrutiny if the platform owner benefits from exemptions or more favourable treatment.
Once the revised prompts are deployed, developers and advertisers will be watching whether consent rates change and whether better coordination between system-level and app-level messages reduces friction. Even modest changes in user behaviour can have material effects when applied across millions of devices and advertising transactions.
The effect on campaign measurement may also vary between businesses. Companies with large pools of first-party customer data are generally better placed to adapt to restricted third-party tracking than smaller app developers that depend heavily on external advertising networks for acquisition and attribution.
Apple now has four months to implement the commitments. The Bundeskartellamt will retain oversight of compliance under a settlement designed to remain in force for seven years, embedding the revised approach well beyond the immediate enforcement action.
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