The Competition and Markets Authority has opened a consultation on proposed conduct requirements for Apple and Google that could give UK app developers greater freedom to direct customers towards payments and subscriptions outside the companies’ app store systems.
The proposed requirements sit under the UK’s digital markets competition regime and focus on steering, the ability for developers to communicate with users about off-platform payment options. The CMA said Apple currently bans steering in the UK, while Google restricts it, leaving many developers with limited scope to bypass fees charged through the two dominant mobile ecosystems.
Under the proposals, Apple and Google would still be able to charge for services they provide, but any steering fees would need to be fair and reasonable. The regulator expects those fees to be lower than current app store charges, creating scope for developers either to reduce prices or reinvest savings in product development.
Will Hayter, executive director for digital markets at the CMA, said: “We think it is important to give both app developers and users more choice about how they communicate and how they transact. This is not only because choice is inherently valuable but also because we see this as the best way to introduce some competitive pressure in a vital part of the mobile ecosystem that is otherwise sorely lacking such pressure.”
The CMA is also considering a potential requirement that would give developers access to near field communication functionality on iOS. That access would allow UK fintechs and app developers to support contactless transactions, including card-based payments through digital wallets, inside their own iOS apps.
Beyond conventional payments, the regulator said NFC access could support account-to-account payments, digital currency and stablecoin use cases, digital ID, car keys, and other non-financial applications. It is seeking views from developers on both the technical method by which NFC access should be provided and the price charged for such access.
The steering consultation runs until 5pm on 28 July 2026, while responses on the possible NFC requirement must be submitted by 5pm on 21 July. The CMA will then decide whether to impose new requirements later this year.
The consultation follows the CMA’s October 2025 designation of Apple and Google as having strategic market status in the provision of their mobile platforms. Google has also announced new global terms and conditions for its Play Store, including changes due to come into effect in the UK today that allow developers to steer users outside the Play Store subject to restrictions.
Mobile operating systems now sit between companies and customers across payments, retail, subscriptions, banking, ticketing, transport, digital identity, health services, media, and enterprise software. When access rules, payment routes, and customer communication are controlled by a small number of platform operators, commercial dependency can reach into pricing, margins, product design, and the data available to improve services.
Subscription companies could see customer acquisition economics change if off-platform payment routes become more practical. Developers would have more room to offer bundles, discounts, or direct account management, while customers could gain clearer visibility over alternative payment options. The value of those freedoms will depend on how any permitted steering works in practice, including the design of user prompts, disclosure requirements, payment safety, and refund handling.
For fintechs, NFC access is a more structural question. Apple’s control of contactless functionality on iPhones has long shaped the mobile wallet market because contactless interaction is not only a payment feature. It also supports authentication, loyalty, ticketing, identity, access control, and customer engagement inside physical and digital environments.
The trust issues are already visible in adjacent areas of digital commerce. AI shopping agents face a payment trust barrier as customers weigh convenience against uncertainty over who holds responsibility for purchases, disputes, and data. App store steering and mobile wallet access sit within the same wider question of who controls the customer relationship when transactions move through intermediated platforms.
The proposals also test the UK’s post-Brexit digital competition regime. Rather than applying a static set of obligations across all designated platforms, the CMA is trying to set conduct requirements that respond to specific market features. That approach gives the regulator flexibility, but it also demands precision. The rules must be strong enough to change market behaviour without creating avoidable security risks, fragmented user journeys, or uncertainty for developers.
Platform fees are likely to be the most contested part of the consultation. If fees remain close to current app store commissions, steering may alter little beyond disclosure. If they fall materially, developers could gain more bargaining power and stronger incentives to build direct customer relationships. Platforms, meanwhile, are likely to argue that they invest heavily in distribution, trust, fraud prevention, developer tools, and payment infrastructure.
Implementation will be shaped by detail rather than headline principle. Customers may still prefer app store payment routes if direct alternatives feel cumbersome or less protected. Developers may hesitate to move payments outside platform systems if they lack the operational capacity to manage fraud, chargebacks, refunds, compliance, and customer support. Smaller developers, in particular, will need low-friction options if the proposed freedoms are to have commercial value.
The consultation gives UK technology, fintech, and app companies a short window to influence how competition is introduced into mobile ecosystems. The outcome will show whether the digital markets regime can move from designation to operational change in parts of the economy where platform rules have become core business infrastructure.
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