CMA Issues Proposed NFC Access Conduct Requirement for Apple's Mobile Platform Under New Digital Markets Powers
The Competition and Markets Authority has published a consultation setting out its proposed near field communication (NFC) access conduct requirement for Apple's mobile platform, alongside a provisional assessment of the requirement's effectiveness and proportionality. The consultation follows a separate CMA call for evidence on issues relating to NFC access on iOS. Both documents form part of the CMA's broader programme of work across mobile platforms, aimed at promoting innovation, investment and growth in UK mobile ecosystems.
Why this matters
The CMA's move to impose NFC access conduct requirements on Apple extends its new Digital Markets, Competition and Consumers Act powers, which the CMA first used against a designated strategic market participant in June 2026 with binding conduct requirements on Google's search business, to Apple's mobile platform. Requiring Apple to open NFC access directly targets Apple Pay's dominance in mobile payments, with implications for banks, fintechs and payment processors across the UK. The proportionality assessment embedded in the consultation is the statutory gateway before any binding requirement can take effect, making the outcome a bellwether for how aggressively the CMA will wield its new ex ante toolkit. The why-now trigger is the CMA completing its evidence-gathering phase and moving to formal proposals.
On the Ground
Competition and regulatory counsel will be fielding instructions from Apple, rival payment platforms and banks seeking to influence the consultation response. Tech and payments clients will need advice on the scope of any access obligation and its interaction with data protection and financial regulation. Trainees would be tasked with reviewing the consultation document, mapping the statutory proportionality test against the CMA's provisional findings, and drafting a summary of the key questions for a partner.
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“What legal test does the CMA have to satisfy before it can impose an NFC access requirement on Apple, and how might Apple push back?”
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