Apple and Google have challenged proposed UK rules that would let app developers direct customers to external payment options. The dispute now centres on two practical questions: how much the platforms may charge when a sale leaves the app, and whether additional checkout screens would make those alternatives less attractive to customers.
The Competition and Markets Authority published responses from the two platform operators, app developers, payment companies and consumer groups on 14 August 2026. The submissions followed parallel consultations covering Apple’s App Store and Google’s Play Store.
The proposal concerns purchases of digital goods and services, such as subscriptions, game items and other content used inside an app. It does not cover ordinary app-based purchases of physical goods and services, including groceries, restaurant deliveries or taxi journeys.
No final rule has been imposed. The CMA has said it will decide later in 2026 whether to introduce the requirements.
The regulator designated both companies with strategic market status in mobile platforms in October 2025 after finding that they had substantial and entrenched market power. The designation was not a finding of wrongdoing, but it gave the CMA authority to consider tailored requirements.
The CMA wants external payments to work in practice
Under the proposed Apple requirement and the corresponding Google consultation, developers would be able to tell users about other purchasing options and include links that lead outside an app to complete a transaction.
This practice is known as steering. It could allow a developer to use its own checkout, select another payment processor, set different prices and deal directly with refunds and customer service.
Apple and Google could still charge a steering fee. The CMA has not proposed a fixed percentage. Instead, each platform would have to show that its fee was fair and reasonable under cost-based, value-based and administrative-simplicity principles.
The platforms could also display one neutral screen informing customers that they were leaving the integrated payment system. They would not be allowed to add warnings or steps intended to discourage the external purchase.
If the rules are adopted in their proposed form, they would take effect three months after the CMA’s final decision. Apple or Google would have to provide an implementation plan after one month, followed by compliance reports every three months.
Apple and the CMA are using different denominators
Apple’s 33-page response argues that the CMA has not established a sufficient case for intervention. The company says its commission pays for App Store distribution, developer tools, payment services, security and intellectual property.
It also says external payments could expose users to fraud, weaker privacy protection and subscription problems that Apple cannot monitor or resolve. Customers who leave Apple’s payment system may no longer have the same centralised refund, purchase-history and subscription-management services.
The CMA said its April call for information produced no robust evidence that steering in other countries had caused observed privacy or security harm. It provisionally judged that the remaining risks would be small under its proposed safeguards, while acknowledging that customers may not always be able to assess those risks accurately. That is the regulator’s assessment of the available evidence, not proof that external payments are risk-free.
Apple said the App Store facilitated more than £46.5 billion in UK billings and sales during 2025, while its commission represented less than 3.5% of that amount. It used the figure to argue that most commerce associated with App Store apps already generates no commission for Apple.
That percentage uses Apple’s broad calculation of app-related commerce. It does not describe the commission rate paid by developers selling digital content through Apple’s payment system.
An Apple-commissioned study of its 2025 ecosystem estimated $61.1 billion in UK billings and sales. Of that total, $46.4 billion came from physical goods and services, $8 billion from in-app advertising and $6.7 billion from digital goods and services.
Physical commerce therefore accounted for about three quarters of Apple’s UK total. Apple generally takes no App Store commission when someone orders clothing, food or transport through an app, and those transactions are outside the proposed steering requirement.
The CMA, by contrast, is examining the digital transactions to which Apple’s payment and commission rules apply. Its consultation says Apple has a headline commission of 30% for digital goods and services and that its average rate remains relatively close to that level.
The less-than-3.5% and near-30% figures appear to conflict, but they have different denominators. The first divides Apple’s commission by a much wider pool of commerce, most of which attracts no commission. The second concerns the transactions covered by the disputed rules.
This distinction matters because a low commission share across all app-related commerce says little about the cost faced by a game, dating service or video app that sells digital products.
Google says it has already changed its model
Google’s response to the CMA takes a different route. It argues that further intervention is unnecessary because a revised Play Store model introduced in the UK on 30 June already permits in-app links to external payments and reduces fees.
The company said developers paying fees could receive reductions of between 33% and 50%. However, the average fee and the aggregate annual saving claimed in its public submission were redacted.
Google’s published UK fee schedule shows why permission to use an external link does not remove the platform charge. Google applies a service fee whether a transaction uses Play billing, alternative billing or an external website.
For standard non-recurring digital purchases completed through an external link, the published service fee is 20%. Auto-renewing subscriptions are charged 10%. Qualifying developers can receive lower rates, while use of Google Play Billing adds a separate 5% fee.
Google also says 97% of developers distribute apps without paying a service fee. That counts developers rather than transaction value and includes businesses that do not charge for an app or sell digital products. It does not reveal the average rate paid by the smaller group whose business depends on paid digital transactions.
One additional screen could alter the economics
A developer will use an external payment route only if the total benefit exceeds the cost of setting it up. The calculation includes the remaining platform fee, payment-processing charges, fraud controls, tax handling, refunds and customer service.
It also includes lost sales when customers abandon checkout.
The CMA received developer estimates suggesting that one additional interstitial screen could produce drop-off rates ranging from about 5% to more than 60%. The regulator cautioned that developers had generally not tested the exact neutral screen in its proposal, and that the estimates came from different payment models and other contexts. The range should therefore be treated as evidence of uncertainty, not as a forecast.
PayPal nevertheless made checkout friction the central argument in its submission to the CMA. It said even one extra click can deter customers. PayPal also warned that restricting direct links to developer-controlled websites could require a customer to visit the developer’s site before moving again to a hosted payment page.
The consumer organisation Which? supports external payment links but opposes combining a side-by-side payment choice with another interstitial screen. It argues that one of those notices should be sufficient and wants steering fees based more directly on platform costs.
Epic challenges the value-based fee
Epic Games broadly supports the right to steer customers but objects to the CMA’s proposed value-based pricing principle.
In its consultation response, Epic argues that Apple should be able to recover only costs directly connected with external payment links. It says allowing the platform to price its wider contribution to the iOS ecosystem could recreate through fees the barrier that the rule is intended to remove.
Apple makes the opposite argument. It says a cost-focused calculation would let developers benefit from its technology, distribution and user base without paying for their wider contribution to a sale.
This is likely to be the hardest part of the CMA’s decision. The direct cost of providing a link may be small, but an app store supplies more than a link. At the same time, allowing the platform to set a fee based on its own estimate of that wider contribution risks leaving little room for a competing checkout provider.
A payment link can exist without creating much competition
The commercial effect of the proposed rules will depend on three costs working together: the platform’s remaining fee, the developer’s cost of handling the transaction and the proportion of customers lost during the external checkout.
A developer might save five or ten percentage points on a platform fee but gain little if payment processing, support costs and checkout abandonment absorb the difference. A lower-friction route could increase conversion, but it may leave customers less certain about who handles refunds or protects their payment information.
Lower developer costs would not automatically produce lower consumer prices either. Developers could reduce prices, invest the saving or retain it as profit. The CMA presents all three as possible outcomes, not guaranteed results.
For that reason, the useful test will not be how many apps add an external payment button. It will be whether customers complete more purchases through those links, whether developers face a lower total cost per completed sale and whether competition places downward pressure on prices or wider app-store commissions.
