The App Store Is More Than a Checkout
Apple’s App Store is the subject of this series—not simply as a place to download an app, but as a gateway that can shape how a developer reaches, serves, and charges the people who use that app. This opening asks why dependence on that gateway cannot be measured by the commission alone. The aim is to give readers a working model for judging whether an alternative route to customers is genuinely contestable: can a developer communicate with users, offer a different way to pay, support the resulting relationship, and do so without the alternative being quietly made unattractive?
That question matters because the App Store sits at the meeting point of several relationships. Apple provides the distribution environment and controls important parts of the experience. Developers supply apps and digital goods or services. End-users choose what to use and buy. Payment providers may process transactions outside Apple’s system. Regulators decide whether the terms governing these interactions leave enough room for competition. A change at one point can therefore affect the others. A restriction on a link may also be a restriction on a price, a refund process, a source of customer information, or a rival’s ability to compete.
The Competition and Markets Authority’s June 2026 consultation on a proposed Steering conduct requirement uses this wider frame. Its proposal is provisional, but its reasoning makes the underlying issue visible: a platform opening is meaningful only when people can use it in practice.
A gateway changes the outside option
An ordinary retailer is one route to a customer. A mobile app marketplace can be more consequential because it is tied to the operating system and to the device on which the app runs. The CMA describes Apple’s App Store as a “vital gateway” for native apps—applications written to run on a particular mobile operating system. Businesses in areas as varied as transport, retail, finance, fitness, gaming, and financial technology use such apps as part of their digital offering. For them, the question is not just whether Apple provides a convenient shop. It is whether access to a large and distinct group of mobile users depends on accepting Apple’s terms.
The consultation reports the CMA’s earlier Strategic Market Status findings that developers distributing digital content and services need Apple’s Mobile Platform to reach a large and distinct user base. It also says Apple’s policies prohibit alternatives to its App Store and that Apple faces very limited competition when competing for content providers. Those are findings reported inside a later consultation, not a complete reproduction of the earlier decision, so they should be read with that qualification. Even so, they describe the basic bargaining problem: a developer may be able to imagine another website or payment processor, yet still be unable to reach enough iPhone and iPad users without Apple’s gateway.
The scale indicators explain why that matters. For the United Kingdom in 2024, the CMA gives official ranges of roughly 1–2 million apps on the App Store, 0–1 million developers distributing through it, and 20–30 million users downloading a native app each month. It also places annual UK spending on digital products and services in a redacted range between zero and five billion pounds. These are not precise public counts; the brackets and redactions are part of the evidence. They are still enough to show why a rule affecting the App Store can have consequences beyond an individual contract.
Scale changes a developer’s outside option. If a business can leave a channel and reach its customers elsewhere at little cost, the channel’s demands face a natural limit. If leaving means losing access to a large, distinct user base, the developer’s apparent freedom is weaker. The business may accept terms it would reject in a more competitive setting, not because every term is equally valuable, but because the alternative is costly in reach, visibility, or continuity. End-users are part of this dependency too. They may prefer an app because friends, colleagues, or services they already use are there. Their presence makes the platform more valuable to developers, while the range of apps makes the device ecosystem more valuable to users.
This is why “just leave the App Store” is not a complete answer to a dispute over its rules. It treats distribution as separable from the rest of the product relationship. For a mobile business, distribution can be the condition that makes the customer relationship possible in the first place.
The price is not the whole dependency
The most visible complaint is the commission. The CMA says Apple charges a headline commission of 30% for payments for digital goods and services, and reports that its average commission remains close to that headline rate. A charge of that size can affect prices, investment, and the ability of a business to compete. But the commission is only the part that appears most clearly on a financial statement.
For digital goods and services, the CMA says developers generally cannot do two things inside their App Store apps: use a payment system other than Apple’s In-App Purchase, or provide a button, link, or information directing users to an offer available elsewhere. These restrictions connect money to communication. A developer cannot simply decide to offer a cheaper subscription on its website and tell an iPhone user where to find it. Nor can it ordinarily choose a payment processor that better fits its existing infrastructure while keeping the app as the point of contact.
That combined restriction can change who owns the relationship after the download. The CMA records evidence from developers that Apple’s intermediary role limits choices about products, pricing structures, and distribution. It may make some forms of innovation harder, such as combining digital and physical services, coordinating support across platforms, or tailoring an offer to an individual customer. The developer may also have less access to information about the customer, less control over refunds, and less ability to help directly when something goes wrong. Apple becomes the party managing parts of a relationship that the developer created and must still maintain in the user’s eyes.
The competitive effect can extend beyond the individual developer. A business competing with an Apple first-party app may have to pay Apple’s commission while being unable to direct users to a lower-cost route or control the payment process itself. That can make the rival’s offer less flexible or less profitable. Alternative payment processors and merchant-of-record services—businesses that can take on the legal and financial responsibility for a sale—are also kept from competing for transactions that Apple routes through its own billing system.
There is an important boundary here. The CMA says its concerns in this consultation relate to digital goods and services distributed through the App Store. Apps selling physical goods and services, such as groceries or rides, operate under different terms: they can generally link to information outside the app, choose their own payment processor, and do not pay a commission. That distinction does not settle the digital-goods question, but it prevents a misleading generalization. The issue is not that every activity inside every app is governed by one identical payment rule. It is that Apple applies a more restrictive arrangement to a category in which digital content and services are sold through the app.
A developer’s dependence therefore has at least four layers. Apple can be the route to reach users; the gatekeeper of what can be said about an offer; the required intermediary for payment; and the manager of billing and parts of the post-purchase relationship. Removing only the commission would leave the other layers intact. Removing only the communication ban could leave the alternative route too expensive or difficult to operate. The cost of dependence is the way these controls reinforce one another.
What meaningful choice would require
The CMA’s proposed answer is called a Steering conduct requirement. Steering means giving an end-user information or a link inside the app that directs them to an alternative place—such as a developer’s website—to complete a transaction. The proposal would seek to let developers communicate with users, direct them to alternative purchasing mechanisms, choose payment processors, set prices and offers independently, and manage more of the direct relationship. It also identifies a possible competitive feedback effect: if developers have a credible lower-cost route, Apple may face pressure on wider App Store fees and on the quality of the services it provides.
But the important word is “credible.” A link that exists in theory may not be an alternative in practice. If it is hidden, surrounded by warnings, made slower than IAP, blocked from showing the relevant price, or subject to a fee that removes the saving, a developer may have little reason to use it and a user may have little reason to follow it. The CMA therefore treats effective steering as a question of meaningful choice for both sides of the transaction, not as a narrow permission to place a hyperlink on a screen.
That creates the central test for this series. First, can the developer reach and inform the user? Second, can the user compare the options and complete the alternative without unnecessary deterrence? Third, can the developer take responsibility for payment, refunds, support, and data in a way that is workable? Fourth, can Apple protect users from genuine security, fraud, privacy, or child-safety risks without turning those concerns into a broad tool for restoring its control? Finally, are the fees and conditions low and simple enough that developers will actually adopt the route, and can a regulator observe whether Apple is treating them fairly?
These questions do not assume that Apple contributes nothing. The company argues that the App Store provides distribution, discovery, developer tools, trust and safety, and integrated payment, and that its commission supports investment and innovation. Nor does a direct developer relationship guarantee lower prices or better support. A developer may retain additional revenue, but may use it for new features, customer service, or expansion rather than passing every saving to users. Users may value Apple’s centralised refunds or subscription management and choose to remain with IAP. The point is not to replace one automatic conclusion with another.
The point is to identify where the real judgment lies. Dependence becomes smaller only when the alternative route is visible, usable, economically worthwhile, trusted enough to use, and protected from retaliation. The next questions are therefore practical and economic: what does Apple control along the customer journey, and what would make a developer decide that steering is worth the effort?