Steering the Conversation: The CMA Mobilizes Against Apple and Google Mobile Platforms

The Competition and Markets Authority (CMA) is pressing forward in regulating the UK’s mobile ecosystem under its new digital markets regulatory powers. On 30 June 2026, the CMA opened a consultation for proposed Steering Conduct Requirements (Steering CRs) for Apple and Google under the Digital Markets, Competition and Consumers Act 2024 (DMCCA). A parallel call for evidence on developer access to Near Field Communication (NFC) functionality on Apple’s iOS was also issued.

Background: Designation and Voluntary Commitments

The DMCCA established a bespoke regime allowing the CMA to designate firms with “strategic market status” (SMS) in respect of a digital activity. The designation allows for the CMA to impose bespoke conduct requirements where proportionate and in line with the statutory objectives of: (i) fair dealing, (ii) open choices, and (iii) trust and transparency. On 22 October 2025, both Apple and Google were designated as having SMS by the CMA in respect of their mobile platforms, the App Store and Play Store respectively. The designations resulted in an initial wave of voluntary commitments from Apple and Google, which took effect on 1 April 2026. Additionally, three conduct requirements were also imposed in relation to Google’s search and search advertising services. The current proposals build on this foundation with the latest consultation marking the first set of proposed conduct requirements addressing the mobile platforms themselves.

Proposed Steering Conduct Requirements

The CMA has proposed the introduction of Steering CRs. Steering is the ability for app developers to engage directly with its customers to promote offers and transactions outside of the app store platforms. Steering is currently banned by Apple and restricted by Google in the UK on the App Store and Play Store respectively. The Steering CRs would seek to ease these restrictions, by preventing Apple and Google from restricting or preventing app developers from communicating directly with end-users or redirecting end-users off app stores to external websites to complete further transactions. Additionally, under the proposed Steering CRs any fees Apple and Google would charge for steering would be required to be fair and reasonable in accordance with the principles set out by the CMA. The CMA noted that it expected the proposed changes reducing steering fees and restrictions, would lead to increased developer revenues resulting in lower prices for customer and increased reinvestment for the developers themselves therefore supporting future innovation.

NFC Access and Pricing

The CMA also issued a call for evidence in relation to concerns regarding NFC access on the Apple iOS mobile operating system. NFC is a short-range wireless technology that allows for data exchange between devices and underpins the contactless payments and digital wallets ecosystem. The CMA found that Apple’s control of access to both the software and hardware with respect to NFC on its devices to be restrictive and that Apple’s fees and terms have prevented developers from accessing NFC functionality. The CMA is therefore seeking to design a potential requirement to open up NFC access for developers with the view that this will lead to increased innovation, investment and growth within the UK economy. To facilitate this, the CMA is seeking views from the market on two design elements in particular: (i) the technical method by which NFC access should be provided and (ii) how Apple should set prices for such NFC access.

This reflects the CMA’s earlier engagement with Apple, UK fintechs, financial services firms and regulators on the importance of NFC access for competition in the digital wallets sector.

Looking Ahead: Why This Matters

The CMA noted that these proposed measures are designed to bring down prices and spur UK tech innovation, noting that app store terms including steering, are also under scrutiny in a number of other jurisdictions, including the EU, the US, Brazil, India, Australia, and Japan. The CMA will consider the feedback received and decide whether to impose any new requirements later this year.

The UK’s app economy represents Europe’s largest by both revenue and developer count, generating an estimated 1.5% of UK GDP and providing approximately 400,000 jobs. The adoption of these Steering CRs would allow developers to direct customers to off-platform offers and payment options, at potentially materially lower costs than current app store charges and effectively reshaping the current landscape of the app store market. Similarly, the potential increased NFC access and subsequent increased competition in the digital wallets sector may likely lead to follow-on commercial consequences for fintechs, banks and payment providers.

Looking Ahead: What Should Businesses Do

These proposed changes and developments are likely to be relevant to businesses dependent on mobile platforms and NFC access including app developers, fintechs and payment providers. Affected businesses should consider whether to engage with the consultation process and ensure to stay up to date with the CMA’s considerations and process. Buisnesses wishing to get ahead of the proposed changes should seek to review and even begin modelling how these proposed changes might change their distribution, pricing, and payment strategies and wider business model, so that they are positioned to capitalize quickly if these proposed changes are imposed.

Key Takeaways

On 30 June 2026, the CMA opened a consultation on proposed steering conduct requirements for Apple and Google’s mobile platforms under the DMCCA, following their SMS designations in October 2025.
The proposed steering conduct requirements would ease restrictions on directing customers off-platform, including implementing principles to keep steering fees fair, reasonable and lower than current app store charges.
A parallel call for evidence has been issued seeking views on developer access to NFC functionality on iOS operating system, including views on the technical method of access and the price charged for access.
The proposed conduct requirements for the mobile platforms seek to build on earlier commitments from both Apple and Google that took effect on 1 April 2026.