From Rule to Reality: Enforcement Across Ecosystems
Apple’s App Store steering dispute shows why a regulatory decision is not the same thing as a changed market. The European Union has already reported an enforcement action over Apple’s steering restrictions, while the UK Competition and Markets Authority has proposed a more detailed conduct requirement that remains provisional in the material available here. This chapter compares what those approaches do, then asks how alternative distribution, defaults, interoperability, non-discrimination, and measurement determine whether a legal opening changes Apple’s relationship with developers and end-users.
The comparison is useful only if unlike things are kept separate. The EU Commission’s annual report, dated 21 May 2026, describes actions taken during 2025 and continuing compliance work. The CMA’s document, dated 30 June 2026, is a consultation about a proposed UK remedy. One records an enforcement decision and an ongoing assessment; the other sets out a provisional design before a final decision. Neither source supplies a definitive long-run evaluation of steering’s effect on prices, innovation, or consumer welfare.
What the EU opening changed—and what it did not settle
Article 5(4) of the Digital Markets Act requires gatekeepers to allow developers to communicate with end-users, promote offers free of charge, steer users to offers, and conclude contracts outside the gatekeeper’s app store. In the Commission’s account, this changed the formal relationship between an app developer and the app store. Before gatekeepers had to comply with the DMA on 7 March 2024, the report says this route was not available in the same way.
The Commission reports that on 23 April 2025 it found Apple non-compliant with Article 5(4). It examined Apple’s original business terms, new business terms, and new music-streaming business terms, and concluded that restrictions meant developers could not fully benefit from alternative distribution channels outside the App Store. The Commission also said consumers could not fully benefit from alternative and cheaper offers because Apple prevented developers from directly informing them about those offers. It fined Apple EUR 500 million and ordered Apple to remove the technical and commercial restrictions, discontinue the non-compliant conduct, and avoid conduct with an equivalent object or effect.
Those are significant institutional steps. They identify communication and contracting outside the store as part of the competitive problem, not as an optional courtesy from the platform. They also show that enforcement can attach a financial consequence and a change-of-conduct order to a steering restriction. But the annual report does not present the fine as the end of the story. It says Apple and Alphabet were making changes to their app-store terms, while the Commission continued assessing whether those measures were sufficient to comply effectively and engaging with third parties.
That continuing assessment matters because a gatekeeper can comply with the visible part of a rule while leaving the underlying incentive structure largely intact. An external offer may be legally permitted but carry a fee that reduces its appeal. A link may exist but be less visible or more burdensome than IAP. Developers may have a right to communicate but still lack enough control over the user journey to make an alternative commercially viable. The EU report and the CMA consultation point to the same general lesson from different positions: legal access must be translated into user and developer behavior before it becomes competitive pressure.
The EU account also includes a related preliminary finding about alternative app distribution under Article 6(4). The Commission says gatekeepers must enable alternative distribution channels on their operating systems to reduce the dependency of business users and end-users. It reports a preliminary finding that Apple’s terms for developers wanting to provide third-party app stores or offer apps through them included a Core Technology Fee, strict eligibility requirements, and an overly burdensome or confusing installation process for users. The case remained ongoing as of March 2026.