First DMCCA 2024 commitments: Apple, Google and platform regulation in practice
In short: The CMA has accepted the first voluntary commitments under the Digital Markets, Competition and Consumers Act 2024, from Apple and Google in respect of aspects of their UK mobile platforms. The commitments cover app review, app ranking, data use and iOS interoperability. They are voluntary and not directly enforceable, but the CMA has said it is well placed to move swiftly to impose conduct requirements if they are not observed. They signal how the new digital markets regime will operate in practice.
The CMA has accepted the first voluntary commitments under the Digital Markets, Competition and Consumers Act 2024 (DMCCA 2024). Apple and Google have each given voluntary commitments in respect of aspects of their UK mobile platforms, covering app review, app ranking, data use and iOS interoperability. The commitments were accepted on 1 April 2026 and were published in the CMA’s Find Digital Markets Measures register on 23 April 2026. For the fintechs, telcos and platform-dependent businesses building on iOS and Android, this is not academic competition law. It sets the terms on which they deal with the two largest mobile platform operators in the United Kingdom. It also marks the point at which DMCCA 2024 starts to bear on UK digital transactions in practice.
How the DMCCA 2024 commitments mechanism works
Part 1 of the DMCCA 2024 came into force on 1 January 2025 (S.I. 2024/1226), creating a new ex ante competition regime for digital activities. For background on the regulator, see our explainer on what the CMA does. Section 2 of the Act lets the CMA designate an undertaking as having Strategic Market Status (SMS) where the CMA finds it has substantial and entrenched market power and a position of strategic significance in respect of a digital activity linked to the United Kingdom. On 22 October 2025 the CMA designated both Apple and Google as having SMS in respect of their mobile platforms, covering mobile operating systems, native app distribution, and mobile browsers and browser engines.
Once designated, the CMA can either impose conduct requirements on the firm under section 19, prescribing how the firm must behave in respect of the relevant digital activity, or accept commitments. Section 36 lets the CMA accept a commitment from an undertaking subject to a conduct investigation. Section 56 lets it accept commitments in connection with a Pro-Competition Intervention. Both routes produce binding obligations. The Apple and Google commitments were given under neither: the CMA has said they were not given in response to any action in a Pro-Competition Intervention investigation or for any breach of conduct requirements. They were offered voluntarily, and the CMA has explained the legal basis for its approach by reference to its functions under section 19 (the power to impose conduct requirements) and section 25 (the duty to keep under review whether to impose them), in deciding not to prioritise conduct requirements in the areas the commitments cover. The CMA accepts that the main drawback of commitments compared with conduct requirements is the lack of direct enforcement in the event of non-compliance.
What the Apple and Google commitments cover
The Apple commitments address app review, app ranking and the use of app data, in common with Google’s, and add interoperability. On app review, they ensure that App Store review is conducted on a fair, objective and transparent basis and does not discriminate against apps that compete with Apple’s own. On interoperability, they focus on enabling third-party developers to request interoperable access to features and functionality within iOS and iPadOS, with an articulated process for how those requests are handled and resolved. The interoperability commitment is the live development to watch, because it could materially change what third-party hardware and software can do on iOS.
The Google commitments cover three themes: app review on Google Play, app ranking on Google Play, and the use of data Google collects through its mobile platform. All three themes mirror Apple’s. The data-use commitment addresses how Google deploys data flowing through its mobile platform, in particular where that data could give Google’s own services an advantage over third parties. In each case the commitments are accompanied by monitoring and reporting obligations,and the CMA has said it is well placed to move swiftly to impose conduct requirements if the commitments are not observed or prove ineffective.
The commitments are not the same instrument as conduct requirements. Conduct requirements come from the regulator and prescribe what the firm must do; commitments are offered by the firm and accepted by the regulator. Conduct requirements are legally binding; these commitments are not directly enforceable. But commitments tend to reflect what the firm agreed to do after iteration with the CMA, and they leave open the path to formal conduct requirements if the commitments do not deliver the outcomes the regulator was looking for.
| Feature | Conduct requirements (s.19) | Apple and Google commitments (voluntary) |
|---|---|---|
| Source | CMA-imposed | Firm-offered, CMA-accepted |
| Negotiation | Limited (consultation) | Iterative with the firm |
| Binding effect | Yes, on publication | No direct enforcement |
| Enforcement | Conduct investigation; penalties | Monitoring and reporting; move to conduct requirements |
| Flexibility | Lower; rule-like | Higher; outcome-focused |
| Speed to deploy | Slower | Faster |
What this means for fintechs, telcos and digital M&A
For fintechs, the App Store payment rules and developer terms have been a flashpoint for years. The Apple and Google commitments do not, on a quick read, settle the in-app payment question that has generated so much friction in other jurisdictions. They focus on review and ranking fairness and, in Apple’s case, interoperability. Fintechs distributing through iOS and Google Play are likely to see the underlying commercial terms evolve, but on a slower timetable than some have hoped. Where firms are negotiating new app distribution and partnership agreements with the platforms, the commitments are useful reference points on dispute handling and timelines, even where they do not change the core commercial bargain. For practitioners working through the platform terms, see our platform terms and policies guidance.
For telcos, the commitments matter for app distribution of operator services such as eSIM, RCS, Wi-Fi calling apps and hub apps. App review timelines, app ranking, pre-installation and default settings all affect how visible operator-branded apps are to consumers and how a multi-device proposition can integrate with iOS and Android. Apple’s interoperability commitment is the development to watch: if it operates as a workable mechanism for third-party access to iOS features, telcos with cross-device propositions will use it.
For acquirers and lenders to UK digital businesses, the DMCCA 2024 has also reshaped the merger control framework. Part 2 of the Act amended the Enterprise Act 2002 to introduce a new acquirer-foothold test that combines a 33% UK share of supply with £350 million UK turnover for the acquiring enterprise, alongside the existing turnover and share of supply tests. SMS-designated firms must also notify the CMA of in-scope transactions through the SMS-firm mergers reporting regime. A small-merger safe harbour applies where each party’s UK turnover is below £10 million. Regulatory due diligence on digital deals has changed shape, and the SMS designation question now sits alongside the conventional Phase 1 and Phase 2 merger control analysis. See our regulatory due diligence page.
Viewpoint
The DMCCA 2024 is early in operation, and these first commitments matter because they show how the CMA intends to use its toolkit. The choice to accept commitments rather than impose conduct requirements is consistent with the consultative tone the CMA has set in its published statements on the digital markets workstream. It is also pragmatic: commitments are easier to evolve, faster to put in place, and commit the firm to outcomes negotiated with it rather than rules drafted around it. The risk for the regime is that commitments are softer than conduct requirements would have been and that compliance monitoring is harder. The next test is whether the Apple and Google commitments deliver the developer-fairness and interoperability outcomes the SMS investigations identified. If they do not, the CMA can revert to conduct requirements under section 19. The parallel transactions track, set out in the CMA’s digital markets competition regime guidance and the SMS-firm mergers reporting guidance (CMA195), will be where the next 12 to 24 months of practitioner work concentrates.
For advice on SMS-designation risk in digital M&A, on the regulatory diligence position for buyers and lenders to digital businesses, or on platform-dependent commercial relationships in fintech and telecoms, contact Rob Bratby at Bratby Law.
