UK App Store Steering: How the CMA Could End Apple and Google’s 30% Toll

What the CMA Actually Proposed on 30 June 2026

For years, an app developer selling a subscription through Apple’s App Store or Google’s Play Store had one option for taking payment: the platform’s own billing system, cut for cut. Apple banned any mention of cheaper alternatives inside the app. Google allowed a narrower version of the same restriction. That arrangement is now the direct target of UK regulation.

On 30 June 2026, the CMA announced a consultation on new requirements for Apple and Google’s mobile platforms, proposing what it calls a “Steering” conduct requirement for both companies’ mobile platforms. In the CMA’s own language, the goal is to secure “the ability for app developers to engage directly with their users outside Apple and Google’s app stores” — meaning a developer could point a customer to its own website, or to a separate payment page, instead of routing every purchase through the platform’s in-app billing.

The move follows the CMA’s designation of Apple and Google as holding “strategic market status” (SMS) in their respective mobile platforms — a final decision issued on 22 October 2025, confirmed on Apple’s mobile platform case page and its Google equivalent, under the Digital Markets, Competition and Consumers Act 2024, the same law that created the CMA’s new conduct-requirement powers. The underlying concern is not new: the CMA’s 2022 mobile ecosystems market study found that Apple and Google charge close to 30% commission on in-app digital purchases, a rate the regulator concluded sits “above a competitive level,” and which persisted even after both companies introduced narrow discounts for smaller developers and subscription renewals.

Crucially, the CMA is not proposing to force fees to zero. Its stated framework is that steering fees — what Apple and Google could still charge when a developer routes a sale off-platform — must be “lower than current app store charges” and “justified through a robust, evidence-led framework,” with the savings either passed to customers or reinvested by developers. Firms that want to keep charging close to today’s rates on off-platform sales would need to defend that pricing with cost and value evidence, not just assert it.

Why Apple and Google Are Moving at Different Speeds

The two platforms are not responding identically, and the gap between them is itself a signal of how this will play out. According to Bratby Law’s analysis of the steering proposal, Google moved first and unilaterally: on 24 June 2026, six days ahead of the CMA’s consultation launch, Google announced new UK Play Store terms — effective the same day the CMA consultation opened — that allow steering and, notably, split its charge into a separate “service fee” and “billing fee.” That structure lets Google keep charging for platform services (discovery, security review, API access) even when a developer opts out of Google’s payment processing.

Apple, by contrast, currently bans steering outright in the UK and has made no equivalent unilateral move. Both companies did submit final “App Certainty” commitments to the CMA on 1 April 2026 covering app review consistency, ranking transparency, and data use — separate from the steering question — but on payments specifically, Apple is waiting for the conduct requirement to be finalized rather than pre-empting it the way Google did. As TechCrunch reported when the SMS process began, the CMA’s designation gives it standing to set rules on exactly this kind of commission and payment-routing behavior across both platforms.

The CMA is running two consultations in parallel: the steering conduct requirement closes for comment on 28 July 2026 at 5pm, and a related call for evidence on requiring Apple to open up iPhone near-field-communication (NFC) access — relevant to contactless payment apps that currently cannot use the same tap-to-pay hardware as Apple Pay — closes 21 July 2026 at 5pm. The CMA has said it expects to reach a determination on both “later this year.”

What App Developers and Product Leaders Should Do

1. Model your unit economics under a lower, cost-justified fee — not a free one

Do not build a financial plan that assumes zero platform fee once steering arrives. The CMA’s framework explicitly allows Apple and Google to keep charging for off-platform sales, just at a rate they must justify against cost and value. Run three scenarios — current ~30% commission, a mid-range steering fee (10-15%), and a near-cost recovery fee — and check which one still supports your pricing and margin before committing engineering time to a payment migration.

2. Build the off-platform payment flow now, ahead of the finalized rule

Google’s UK terms already permit steering as of 30 June 2026, so developers selling to UK Android users can start testing a linked-out payment page today rather than waiting for Apple’s side of the rule to land. Standing up a compliant web checkout, receipt reconciliation, and refund-handling flow takes real engineering time — starting after the CMA’s decision lands “later this year” means shipping months behind competitors who prepared in advance.

3. Prepare a cost-and-value submission if you plan to charge for off-platform access

If your product is a platform itself — an app store alternative, a subscription aggregator, or any business that also takes a cut when a user pays off-app — the CMA’s “evidence-led framework” cuts both ways. You will need documented cost data (support, fraud prevention, discovery, security review) to defend any fee you charge, exactly as Apple and Google will. Start collecting that evidence now rather than reconstructing it under regulatory pressure later.

4. Track jurisdiction scope before rebuilding your global payment stack

This is a UK-specific conduct requirement issued under the Digital Markets, Competition and Consumers Act 2024 — it does not automatically extend to the EU, US, or any other market, even though the EU’s Digital Markets Act has already forced comparable changes on Apple in Europe. Build your steering flow as a UK-gated feature first, both to limit scope risk while the rule is still in consultation and to avoid assuming regulatory parity across markets that have moved on different timelines and under different legal bases.

The Regulatory Question

The real fight here is not whether developers get to link out — the direction of travel on that point is now clear across the UK, the EU, and several US court rulings. The fight is over what “cost and value” means when a regulator asks a $3 trillion company to justify its own pricing with evidence rather than market power. Apple and Google built commission structures that bundle discovery, hosting, security review, and payment processing into one number; unbundling that number into a “justified” steering fee forces both companies to disclose, for the first time in a binding UK proceeding, what each piece is actually worth.

That is why Google moved first with its own service-fee/billing-fee split — it is an attempt to set the terms of the unbundling before the CMA imposes one. Apple’s wait-and-see posture carries the opposite risk: if the CMA’s final conduct requirement lands with a lower ceiling than Google’s self-imposed structure, Apple will have less room to negotiate than Google secured by moving early. Either way, once one G7-scale regulator has forced a “show your cost data” framework onto app store commissions, the template exists for every other market currently drafting its own digital markets legislation.

Frequently Asked Questions

Sources & Further Reading

• CMA consults on new requirements for Apple and Google’s mobile platforms — GOV.UK
• Apple’s mobile platform case page — GOV.UK
• Google’s mobile platform case page — GOV.UK
• CMA steering conduct requirements: app fees — Bratby Law
• CMA’s market study on mobile ecosystems: setting the tone for enforcement — Hausfeld
• UK targets Apple and Google’s mobile platforms for regulation — TechCrunch