The UK represents Europe’s largest app economy by revenue and number of developers. Against this backdrop and the ever growing role of digital assets such as mobile apps, regulators have turned increased attention to how mobile app stores operate.
On 1 April 2026, the Competition and Markets Authority (CMA) published its decision to accept commitments given by Apple and Google intended to address concerns around transparency, fair treatment of app developers and the handling of app review and ranking processes.
This update explores how and why the commitments were given, what Apple and Google have agreed to do, and what this means for businesses and developers operating in the app economy.
In October 2025, the CMA identified concerns that Apple and Google's control over app distribution could disadvantage app developers and restrict competition.
Apple and Google have committed to fair app store practices, including transparent reviews, developer data protection, clear complaints processes and protection against retaliation.
Although the CMA cannot directly enforce commitments, it can impost legally binding conduct requirements if needed.
The CMA is also examining 'steering restrictions' imposed by Apple and Google, which limit developers' ability to direct users to alternative payment methods outside apps.
For business and developers, this should lead to greater transparency, clearer app store process and stronger protections.
The Digital Markets, Competition and Consumers Act 2024, which came into force on 1 January 2025, gives the CMA new powers to regulate large digital firms with substantial and entrenched market power. Under the Act, the CMA can designate these companies as having Strategic Market Status (SMS) in relation to specific digital areas. Where a company has SMS, the CMA may impose legally binding 'Conduct Requirements', setting rules on how that company must behave within specific digital areas.
In October 2025, following extensive investigations, Apple and Google were both designated as having SMS in relation to their native app distribution platforms (the App Store and Google Play) as well as other digital areas. The CMA identified concerns that their control over app distribution could disadvantage app developers and restrict competition. The CMA therefore announced that it would consider what regulatory interventions were necessary to address these concerns.
Rather than immediately imposing formal Conduct Requirements on Apple and Google in relation to the operation of their mobile app stores, the CMA has accepted various commitments offered by Apple and Google.
In broad terms, Apple and Google have committed to:
Fair and transparent app review and ranking: reviewing and ranking apps in a fair, objective and transparent way, without unjustified discrimination or preferential treatment for their own apps.
Safeguards around developer data: protecting data collected from developers and not using it unfairly, for example to support the development of their own competing apps.
Complaints handling, reporting and monitoring: operating effective complaints mechanisms for developers, publishing clearer public information about their app store processes, and submitting detailed confidential compliance reports to the CMA.
Protection against retaliation: not retaliating against developers for raising complaints, engaging with the CMA or publicly criticising app store practices.
Unlike Conduct Requirements, the CMA cannot directly enforce commitments.
The enforceability of Conduct Requirements contrasted against the unenforceable nature of commitments is what led many consultation respondents to argue that formal Conduct Requirements should be imposed.
However, the CMA considers that accepting the commitments offers several advantages over imposing formal Conduct Requirements.
First, the commitments allow changes to be implemented more quickly and efficiently, as they avoid the need for a full conduct investigation.
Second, the CMA believes Apple and Google have sufficient incentives to comply with their commitments. That is, because the commitments introduce detailed transparency and reporting obligations and the CMA will continue to monitor their compliance, any failure to deliver on their commitments is likely to be identified. The CMA will publish regular updates on its monitoring activities and its views on compliance. An initial update is expected before the end of 2026, following receipt of the first bi annual compliance reports, which Apple and Google must submit by 30 September 2026.
Finally, the CMA retains the power to impose Conduct Requirements if the commitments prove ineffective.
Alongside accepting the commitments outlined above, the CMA called for views on various changes that Apple and Google have made (or propose to make) in relation to their app store rules in a number of jurisdictions, including the UK. In particular, the CMA is currently examining the 'steering restrictions' imposed by Apple and Google. These are rules that limit developers’ ability to direct users to alternative ways of purchasing digital content or services outside the app, such as through the developer’s own website, where transactions may not be subject to app store commission fees.
The CMA will use the evidence it receives to assess whether intervention is needed in relation to these steering rules, including whether these steering restrictions should be removed. The CMA’s response to this consultation is yet been announced. App developers and businesses operating in the app ecosystem should keep a keen eye out for the CMA’s findings and regulatory actions relating to steering restrictions.
In the short term, the commitments should lead to greater transparency, clearer processes and improved protections for app developers using the Apple App Store and Google Play. Developers may find it easier to understand how decisions about app approval and ranking are made, and should have greater confidence that their data will not be used unfairly.
As discussed above, CMA scrutiny of app ecosystems is ongoing and businesses operating in this digital sphere should continue to monitor developments closely and consider engaging with any future CMA consultations.
If you’d like advice on how any of the changes mentioned above changes might affect your business, please contact our commercial team.
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