UK DMCC, six months on: what Apple and Google's commitments changed

Direct answer — What has actually changed for game publishers in the UK six months into Apple and Google’s DMCC commitments? Less than the headlines suggested. The commitments that took effect on 1 April 2026 cover app review, app store ranking, use of developer data and, for Apple only, a channel to request interoperable access to iOS features; they do not touch commissions, payments or third-party stores. The changes that would move money, a steering conduct requirement for Apple and Google and possible NFC access on iOS, were still at consultation stage on 8 October 2026, with the CMA saying a decision would come “later this year”.

When the UK’s Competition and Markets Authority (CMA) designated Apple and Google in October 2025, many publishers filed the UK next to the EU and Japan as the third jurisdiction forcing open mobile distribution. Six months after the first measures went live, that filing needs correcting. This piece separates the three layers people keep blending (designation, voluntary commitments, conduct requirements) and says plainly what a studio selling to UK players can use today.

Designation, commitments, conduct requirements: what is actually in force?

Only the commitments are live, and they are procedural.

• Designation (22 October 2025). The CMA confirmed that Apple and Google each hold strategic market status (SMS) in their mobile platforms, which it says “cover operating systems, app distribution, browsers and browser engines on smartphones and tablets.” The CMA was explicit that designation “is not a finding of wrongdoing and does not introduce any immediate requirements.”
• Commitments (in effect since 1 April 2026). Instead of imposing rules, the CMA accepted voluntary commitments from both firms. It consulted on them between 10 February and 3 March 2026 and received 53 responses, and it acknowledged that “most respondents disagreed with the proposed introduction of commitments” rather than binding rules. It went ahead anyway, calling them “the swiftest and most pragmatic means” to deliver results, and decided “not to prioritise CRs in this area at this time.”
• Conduct requirements (proposed, not imposed). On 30 June 2026 the CMA published proposed steering conduct requirements for both Apple and Google. That consultation closed on 28 July 2026 and responses were published on 14 August 2026. As of this writing, the Apple case page lists no decision after that date.

For a UK-facing game studio: since April you have better process guarantees and the same commercial terms.

What the commitments give a game studio in practice

Faster, more accountable app review and a documented right to complain. That is useful for live-ops teams. It does nothing for margin.

On Apple, the commitments put a few operationally relevant promises in writing. Apple “will seek to provide a rejection or approval decision for 90% of app submissions within 24 hours,” will explain how a rejected submission breaches the guidelines, and lets developers “appeal that decision as a matter of right to the App Review Board.” It keeps an expedited review route explicitly covering “updates to patch a critical bug or where the app’s purpose is tied to a specific event, such as game competitions or live-streamed experiences.” Apple also commits to give approximately one week’s advance notice of major changes to the search inputs used for apps on the UK App Store storefront, and to run a dedicated complaints channel for UK developers.

On Google, the commitments mostly codify existing Play practice: review against published policy by a team separate from Google’s first-party app teams, an explanation for every rejection, an internal appeal, and better visibility for independent mediation through the Centre for Effective Dispute Resolution (CEDR).

For a game studio, the value is narrow but real: a hotfix during a live event or a rejected build before a featured launch now has a documented escalation path and, on Apple, a stated turnaround target.

What the commitments do not cover matters more. There is nothing in them about commission rates, payment processors, link-outs, sideloading or third-party app stores. If your interest in the UK regime was commercial, the April package was never the part that mattered. Weighing how UK reach fits into a broader multi-store plan is the kind of question we work through on our distribution practice.

The interoperability channel, and why NFC is a separate track

Apple’s interoperability commitment is a request process, not a right of access. Since April, developers whose Apple Developer Program membership is registered in the UK can submit interoperability requests through a dedicated web questionnaire. Apple “will endeavour to provide developers with an update on the status of their requests within four weeks,” and to answer status queries on eligible requests within two weeks. But it assesses requests against criteria that include “alignment with Apple’s platform priorities,” implementation cost and impact on its intellectual property, and receiving a request “will not create any obligation or expectation that Apple will commit to building a specific requested feature.” A studio whose developer account is registered outside the UK cannot use this channel.

NFC is frequently described as part of the April deal. It is not. The CMA’s April response said it was “working to understand how best to open up access to the functionality on Apple smartphones – the NFC chip – to enable third-party competitors to Apple Wallet.” On 30 June 2026 it published a separate call for evidence on NFC access on iOS, with views due by 21 July 2026, covering “the technical method by which NFC access should be provided” and “the price charged for such access.” For most game studios it is a watching brief, not a roadmap item.

Steering: the part that would actually move money

The proposed steering conduct requirement is the first UK measure that would change game economics, and it is not yet in force. The CMA’s June announcement put the current position bluntly: steering “is currently banned by Apple and restricted by Google in the UK.”

On iOS, the CMA’s consultation document notes that Apple “currently charges a headline commission of 30% for payments of digital goods and services,” and that UK developers selling digital goods are generally not allowed to process payments outside In-App Purchase or to show a call to action pointing to offers elsewhere. One exception matters for games: items bought on another platform, such as a web shop, can be used in the app if they are also available as in-app purchases. That is the narrow lane UK web shops use today, and why a web shop and live-ops direct-to-consumer playbook still has to be built around it rather than around in-app links.

The draft Apple requirement would change that. Apple would be barred from preventing developers from including links that send UK users to external websites to complete purchases, from restricting “the level or form of prices” a developer shows through those links, and from adding friction beyond a single neutrally worded interstitial screen. Apple could still charge a steering fee, but only on purchases made “within a maximum of seven days” of the user reaching the external checkout, not on auto-renewals of subscriptions taken out before the user was steered, and at a level it must justify to the CMA under cost-based, value-based and administrative-simplicity principles. The CMA’s provisional view is that steering fees “must be significantly lower than current headline commission rates to ensure an effective intervention.” Notably, the draft defines covered developers by where their users are, not where the studio is based: it applies to apps “made available to, or accessed by, End-users in the United Kingdom.”

On Android, the picture is already different, because Google moved first under its own global changes. Since 30 June 2026, Google Play’s rate card in the UK charges a 10% service fee on a developer’s first $1M of annual earnings, 20% on non-recurring transactions from new installs and 25% from existing installs above that, plus a separate 5% billing fee when Google Play Billing is used. The CMA’s Google consultation says it will “assess the likely impact of these recent changes,” and notes that earlier UK alternative billing came with “important limitations,” including that “gaming developers were excluded from participating in Google’s User Choice Billing programme.” We break down the new Play tiers in our guide to Google Play’s billing choice program.

How the UK compares, and what to do now

The UK is, so far, the slowest of the three regimes on the commercial levers. The EU’s DMA opened iOS to alternative marketplaces under Apple’s own fee architecture, which we costed in what the Core Technology Fee actually costs a studio. Japan went live in December 2025 with alternative stores, payments and published fee cards, as covered in Japan’s MSCA distribution opening. The UK chose process first and payments later; on third-party stores and sideloading, the CMA said only that it would “continue to monitor international developments.” A UK plan in late 2026 still runs through the App Store and Google Play.

1. Use the process guarantees. Make sure your release managers know the Apple expedited review route and App Review Board appeal, and the Google appeal and CEDR mediation route. They cost nothing.
2. Price the Android lever now. Google’s UK rate card and billing choice are live today; the Apple equivalent is not.
3. Prepare an iOS link-out plan, but do not ship against a draft. Scope what a UK web checkout would need (account linking, pricing, refunds, tax) so you can move quickly if the steering requirement is imposed. Do not model a steering fee level: none has been set.
4. Watch the CMA’s next update. The first bi-annual compliance reports from both firms were due to the CMA by 30 September 2026, and it plans an initial monitoring update before the end of 2026. That update and the steering decision are the next signals that matter.

FAQ

Do the CMA commitments change Apple’s or Google’s commission in the UK?

No. The commitments in force since 1 April 2026 cover app review, app ranking, use of developer data and, for Apple, interoperability requests. Commission and payment terms are addressed only by the proposed steering conduct requirements, which had not been decided as of 8 October 2026. Google’s lower UK service fees since 30 June 2026 come from Google’s own rate card change, not from the commitments.

Can UK game developers link players to a web shop from an iOS app today?

Not for digital goods, under current App Store rules as described by the CMA. Items bought on the web can be used in the app if they are also sold as in-app purchases. The proposed Apple steering requirement would allow external purchase links for UK users, but it is still a proposal.

Has the first compliance reporting period closed?

Yes. Google’s first bi-annual reporting period ran from 1 April to 30 June 2026, with its first report due by 30 September 2026; Apple’s first bi-annual reports cover 1 January to 30 June 2026. Most of this reporting goes to the CMA confidentially. The CMA has said it will publish an initial update on compliance before the end of 2026.

Does the UK regime allow third-party app stores on iOS?

No. Neither the commitments nor the proposed steering requirement cover alternative app marketplaces or sideloading. The CMA has said it continues to monitor international developments on that front.

Does a studio based outside the UK benefit?

From the app review commitments, yes, in practice, since they describe how the stores review apps. Apple’s interoperability request channel is limited to developers whose Apple Developer Program account is registered in the UK. The draft steering requirement would apply to apps available to UK users, wherever the developer is based.

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If you want a clear read on how the UK fits alongside the EU, Japan and Android billing choice for your title, and which levers are worth pulling now, talk to us or see how we run multi-channel launches on our distribution page.