CMA steering conduct requirements: the price of access to Apple and Google’s mobile platforms
In short: CMA steering conduct requirements, proposed on 30 June 2026, would stop Apple banning, and Google restricting, the way UK app developers point their own customers to cheaper off-platform payment. A separate call for evidence asks how third parties should reach the iPhone’s contactless chip. Both close in late July 2026.
A UK app developer that wants to bill its own customers directly, and a fintech that wants its app to behave like a contactless card, have both spent years locked out by the two firms that control the mobile platforms. On 30 June 2026 the Competition and Markets Authority (CMA) proposed to change that. It is consulting on draft rules that would let developers steer customers off Apple’s and Google’s app stores, and it has opened a separate inquiry into opening the iPhone’s contactless hardware to other firms. The key open question is the price.
What the CMA has proposed, and when
- The CMA designated Apple and Google with strategic market status in their mobile platforms on 22 October 2025, the first SMS designations under the Digital Markets, Competition and Consumers Act 2024. Source: CMA, 22 October 2025.
- On 30 June 2026 the CMA proposed a steering conduct requirement on each firm; the consultation closes on 28 July 2026. Source: CMA Apple case page.
- The CMA opened a call for evidence on NFC access on iOS, closing on 21 July 2026, asking only two questions: the technical method and the price. Source: CMA call for evidence.
- The CMA expects any steering fee to be lower than current app store charges, with the saving passed to UK customers or reinvested by developers. Source: CMA, 30 June 2026.
| Workstream | Stage on 30 June 2026 | Closes |
|---|---|---|
| Steering (Apple and Google) | Consultation on a proposed section 19 conduct requirement | 28 July 2026 |
| NFC access on iOS (Apple) | Call for evidence on design: method and price | 21 July 2026 |
How the UK SMS regime reached this point
The CMA designated Apple and Google with strategic market status (SMS) in their mobile platforms on 22 October 2025, the first designations under Part 1 of the Digital Markets, Competition and Consumers Act 2024. Apple’s covers iOS, iPadOS, the App Store and Safari; Google’s covers Android, the Play Store and Chrome. Designation is only the gateway. The operative tools are conduct requirements under section 19, which tell a designated firm how it must, or must not, behave. A conduct requirement has to be proportionate to one of three statutory objectives: fair dealing, open choices, and trust and transparency. It must also be a permitted type under section 20, which expressly includes a requirement to trade on fair and reasonable terms. The CMA must consult before it imposes one, and a breach can draw a penalty of up to 10 per cent of global turnover.
The CMA accepted commitments from both firms on app review, app ranking and a process for developers to request interoperable access to iOS features in April 2026. It then imposed three conduct requirements on Google search in June 2026, the firm’s first behavioural rules on the search business. The mobile-platform consultation published on 30 June 2026 is the next step, and it goes to the heart of how the two firms make money from apps.
What the CMA steering conduct requirements would change
Steering is the freedom for a developer to tell its own users about cheaper ways to buy. Apple bans it; Google restricts it. The proposed conduct requirement would lift those constraints in the UK: a developer could point a customer to its own website or to an alternative payment method, instead of channelling every purchase through the platform’s in-app payment system and paying the commission attached to it. Google moved first on its own account: on 24 June 2026 it announced new global Play Store terms, effective in the UK from 30 June 2026, that allow steering and separate its service fee from a billing fee. The CMA will assess those changes in the next phase.
The fee is what decides how much the steering right is worth. Apple and Google may still charge a fee where developers steer customers away, and both will argue that it should reflect the value of the platform rather than its cost. The CMA has been direct about the expected outcome: Will Hayter, its executive director for digital markets, described an “evidence-led framework involving due reference to both cost and value“, with the result expected to fall below current app store charges. A steering freedom priced close to the old commission delivers very little. The proportionality test in section 19, and the consumer-benefit duty in section 19(10), are what the CMA will use to hold the fee down; they are also what Apple and Google will test.
NFC access on iOS: what the call for evidence asks
The second workstream is narrower but, for payments, more striking. Apple has reserved the iPhone’s near field communication (NFC) chip, the hardware that makes a phone tap to pay, to its own wallet. The CMA’s call for evidence asks two questions only: the technical method by which other developers should get NFC access, and the price of that access. Open it, and a UK fintech could offer contactless card payments, account-to-account transfers, digital identity or car keys from within its own iOS app, without Apple Pay as the gatekeeper.
This is the part that conventional payments regulation does not reach. The Payment Services Regulations 2017, the FCA’s authorisation regime and the PSR’s scheme rules govern who may provide a payment service and how customer funds are protected. None of them gives a fintech a right of access to a smartphone’s hardware. That access has, until now, been a matter of one company’s terms and conditions. The lever that prises it open is competition law, applied by the CMA under the SMS regime, not the payments rulebook. For a payments firm planning a wallet or a tap-to-pay product, the door to the iPhone is being opened by a competition regulator, and the terms of entry will be set by the same fee logic as steering. Where a product sits across both the payments perimeter and platform access, the regulatory perimeter and market entry page sets out how the firm maps the regimes that apply before a build starts.
The same end as the EU, through different machinery
The UK is arriving where the EU already is, by a different route. The EU Digital Markets Act bars anti-steering by designated gatekeepers as a per-se rule, and its Article 6(7) requires interoperable access to hardware features such as NFC. The European Commission separately bound Apple, in Case AT.40452, to give third-party wallets free NFC access through host card emulation across the EEA for ten years. The same questions, on the same platforms, are live in the United States and Japan. The EU and UK in-app payments machinery is set out in more detail in a separate analysis on this site.
| Issue | UK (DMCC Act 2024) | EU (DMA and Article 102 TFEU) |
|---|---|---|
| Steering off-platform | Proposed section 19 conduct requirement; consultation closes 28 July 2026 | DMA anti-steering rules, in force on designated gatekeepers |
| NFC and contactless | Call for evidence on method and price; closes 21 July 2026 | DMA Article 6(7) interoperability; Apple Pay commitments (Case AT.40452), free access for ten years |
| The fee on the open gateway | Evidence-led, “fair and reasonable“, expected below current app store charges | Alternative billing permitted; platform fees contested case by case |
| Mechanism | Bespoke, consultation-gated conduct requirement | Per-se obligation enforced directly by the Commission |
Viewpoint
This is when the SMS regime stops being about designation and starts being about price. Designating Apple and Google was the straightforward part; the hard part is setting a number for access against two firms with every incentive to argue for value over cost. The binding constraint on a new wallet or billing product is rarely the headline right of access. It is the residual fee, the technical conditions attached to it, and the eligibility criteria that decide who qualifies. Those details sit inside the consultation documents, and they are where the responses due by late July should concentrate. The wider point is one the payments sector should absorb: the rules that decide whether a fintech can reach the contactless chip or bill its own customers are now being written by a competition regulator under the Digital Markets, Competition and Consumers Act 2024, alongside the FCA and PSR rulebooks rather than inside them. Firms that watch only the payments perimeter will miss where this is decided.
Frequently asked questions
What are the CMA steering conduct requirements?
They are draft rules, proposed on 30 June 2026 under section 19 of the Digital Markets, Competition and Consumers Act 2024, that would require Apple and Google to let UK app developers steer customers to off-platform payment options. The aim is to let developers bypass the platforms’ mandatory in-app payment fees. The consultation closes on 28 July 2026, and the CMA will decide later in 2026 whether to impose them.
Does the proposal mean app store fees disappear?
No. Apple and Google would still be allowed to charge a fee where developers steer customers away, but the CMA expects that fee to be set on an evidence-led basis with reference to both cost and value, and to come out lower than current app store charges. The level of the fee, not the right to steer, is what decides how much the change is worth to developers.
Who could gain NFC access on the iPhone?
The CMA’s call for evidence is aimed at developers and fintechs that want to provide contactless functions, such as card payments through their own digital wallets, from within their own iOS apps. It also flags account-to-account payments, digital currency, digital identity and car keys as uses that NFC access would support. The call for evidence closes on 21 July 2026.
How does this differ from the EU position?
The EU reaches the same outcomes through per-se obligations. The Digital Markets Act bars anti-steering and, in Article 6(7), requires interoperable access to hardware including NFC, while the European Commission has separately bound Apple to give third-party wallets free NFC access in the EEA for ten years. The UK route is a bespoke conduct requirement that the CMA must consult on before imposing, with the fee set through its own evidence-led framework.
For advice on whether your product engages the SMS regime, the payments perimeter, or both, and on responding to the CMA consultations, contact Rob Bratby at Bratby Law. Bratby Law advises app developers, fintechs and payments firms on platform access and UK payments regulation.
