The Competition and Markets Authority (CMA) has published the consultation responses it received in connection with its proposed steering conduct requirement for Apple's mobile platform, following the consultation that ran from 30 June 2026 to 28 July 2026. The published responses include submissions from Apple itself (a 33-page PDF), Epic, the Coalition for App Fairness, the Coalition for Open Digital Ecosystems, the Computer and Communications Industry Association (CCIA), the Association for Competitive Technology (ACT), the Chamber of Progress, the Consumer Choice Centre, the Developers Alliance, Associated Newspapers Ltd, Checkmyfile, the Black Hole Index, and several anonymous respondents, among others. The proposed requirement relates to the ability of app developers to steer users towards alternative payment mechanisms and purchase options outside the App Store, an issue at the heart of platform competition debates across the UK, EU, and US. The CMA designated Apple with strategic market status in mobile platforms in October 2025 under the Digital Markets, Competition and Consumers Act, and is now using those powers to set conduct requirements. The consultation is a formal step in that process, and the publication of responses signals that the CMA is now in the analysis phase before any final determination. Apple's 33-page response and Epic's submission are among the most substantive, reflecting the commercially significant stakes for app developers dependent on iOS distribution. The breadth of respondents, spanning publishers, consumer groups, developer associations, and the platform itself, illustrates the wide commercial and regulatory interest in how the CMA exercises its new digital markets powers.
Why this matters
The CMA is consulting on parallel steering requirements for Apple and Google, having designated both with strategic market status in mobile platforms in October 2025, so each procedural step here sets the pattern for how conduct requirements will be framed across the mobile ecosystem. The volume and diversity of consultation responses confirms that the proposed requirement has significant commercial stakes: app developers, publishers, and platform intermediaries all have material interests in whether and how Apple may be required to allow steering to off-platform payments. The outcome will directly affect the business model of every app distributed through the App Store in the UK and will signal how aggressively the CMA intends to use its new toolkit against other designated firms.
On the Ground
The matter generates substantial work across competition law, regulatory compliance, and technology law practices. Firms advising Apple will be preparing detailed regulatory submissions and likely planning for any challenge to a final conduct requirement. Firms acting for app developers or trade bodies will be monitoring the process closely and advising clients on how a favourable outcome could reshape their commercial terms. A trainee would assist with regulatory notification drafting, summarising consultation responses submitted by key parties, preparing compliance gap analysis memos comparing the proposed requirement against Apple's current App Store terms, and coordinating submissions with any parallel EU or US proceedings.
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“What powers does the CMA have under the UK digital markets regime to regulate platform conduct, and what might Apple argue in response to a proposed steering conduct requirement?”
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