Google launches user choice billing for UK app developers

Google announced the rollout of user choice billing for UK app developers on March 28, just one day before its scheduled implementation on March 29, 2025. This expansion allows non-gaming application developers to offer alternative payment systems alongside Google Play's established billing mechanism when selling digital content and subscriptions.

The announcement follows discussions with the UK's Competition and Markets Authority (CMA), which had expressed concerns about Google's market position. In a statement released through its corporate blog, Google's Competition Counsel Myrto Tagara emphasized that the decision "reflects our commitment to engage with the Authority's process at pace."

According to Google, the implementation for UK developers will initially focus on non-gaming applications, which aligns with the company's approach in other markets where user choice billing has been introduced. The expansion to the United Kingdom makes it the eighth jurisdiction where Google offers this payment flexibility, joining a roster that includes European Economic Area countries, Australia, Brazil, Indonesia, Japan, South Africa, and the United States.

Technical implementation requirements

For developers seeking to implement alternative billing methods, Google has established specific technical frameworks that must be followed. The company requires integration with its newly developed alternative billing APIs, which automate much of the transaction reporting process.

A key component of this system is the External Transactions API, which Google has developed to track and process payments that occur outside its own billing infrastructure. Developers must report all alternative billing transactions within 24 hours of payment authorization, a significant change from previous manual reporting requirements that operated on a monthly basis.

According to the technical documentation provided by Google, developers implementing the system must use Play Billing Library version 5.2 or higher for user choice billing, or version 6.2.1 or higher for alternative billing only scenarios. The API integration streamlines the implementation of specific user experience requirements and transactional reporting protocols.

In cases where transactions are processed externally, developers must generate unique external transaction IDs for each payment event. For recurring subscription payments, they need to maintain references to the initial transaction through what Google terms the "initialExternalTransactionId" parameter. This ensures continuity in tracking customer relationships across multiple billing cycles.

Service fee adjustments

Although developers can now offer alternative billing methods, Google will continue to collect service fees on transactions processed outside its own payment system. According to information in Google's enrollment documentation, "When a consumer purchases through an alternative billing system, the standard service fee the developer pays will be reduced by 4%."

This partial reduction acknowledges that while Google is not directly processing the payment, it still provides the platform infrastructure and distribution channel for these applications. The company has consistently maintained that its service fee "has never been simply a fee for payment processing" but rather represents the broader value provided by the Android ecosystem and Google Play marketplace.

For applications with active subscription customers who began their services during previous manual reporting periods, Google requires a one-time migration process through its ExternalTransactions API. This technical step ensures that existing customer relationships can be properly tracked in the new automated system.

User experience considerations

Google has implemented specific user interface requirements for the choice screen that customers will see when making purchases. The documentation specifies that the choice screen must present users with two clear options: the developer's alternative billing system or Google Play's billing system.

According to the company's guidelines, developers offering alternative payment methods must create standardized payment method image assets that follow precise specifications: 192dp x 20dp dimensions with transparent backgrounds, containing up to five payment method cards separated by 8dp spacing.

Each payment method card must adhere to specific visual guidelines, including 32dp x 20dp dimensions with 3dp inner padding and a 1dp outline with a 2dp radius. These exacting specifications ensure visual consistency across the platform while allowing developers to display their preferred payment processors.

For subscription-based services, developers must also provide a subscription management link where customers can manage their recurring payments if they choose the alternative billing option. This requirement aims to ensure that customers maintain access to account management features regardless of which payment system they select.

Eligibility and market distinctions

The user choice billing program maintains different eligibility criteria across its participating markets. While any app type can offer alternative billing in European Economic Area countries, other regions including the United Kingdom maintain restrictions on gaming applications.

As stated in Google's enrollment documentation, eligible apps must be either "an app or game across any form factors offering user choice billing to users in the EEA; or a non-gaming mobile or tablet app with users in all other locations." This means that UK gaming applications cannot yet participate in the user choice billing system.

Google's system also draws distinctions between its "user choice billing" option, where both Google's system and alternatives are presented, and "alternative billing only" which permits developers to offer just their own payment systems without Google's option in specific markets under particular regulatory frameworks.

The documentation indicates developers must carefully configure their Play Console settings to specify which markets will receive which billing options. Changing these configurations can be managed through the alternative billing settings in the Play Console interface, with Google noting that "any updates will be effective immediately, including changes to applicable service fees."

Security and compliance requirements

Development teams implementing alternative billing systems must address specific security and compliance considerations. Google requires all payment processors to comply with the Payment Card Industry Data Security Standard (PCI-DSS) when handling credit and debit card data, a common requirement across the payment industry.

Additionally, the alternative billing system must provide robust customer support and establish processes for disputing unauthorized transactions. These requirements aim to ensure consumer protection across all payment options within the Google Play ecosystem.

For transactions in regions with variable tax structures, such as India where taxes differ by state, developers must include specific administrative area codes when reporting transactions. According to the technical documentation, Google has established a predefined list of administrative area strings that must be used when reporting transactions from these regions.

Migration deadlines

Google has been gradually shifting away from manual reporting systems for alternative billing transactions. The technical documentation notes that "manual reporting of alternative billing only and user choice billing is being sunset," signaling the company's preference for automated API-driven reporting mechanisms.

For developers with active subscriptions that began during the manual reporting era, the documentation mandates that they "migrate these subscriptions through the ExternalTransactions API prior to reporting the recurring transactions through the API."

This technical requirement involves creating a new zero-cost transaction using a special parameter called "migratedTransactionProgram" instead of normal transaction identifiers. The process allows Google to establish historical continuity for existing customer relationships while transitioning them into the new automated tracking system.

Timeline of events

• March 28, 2025: Google announces user choice billing for UK app developers
• March 29, 2025: Official implementation date for user choice billing in the UK
• Initially available for non-gaming applications only
• Requires reporting of all alternative billing transactions within 24 hours
• Service fees reduced by 4% for transactions processed through alternative billing
• Developers must integrate with Google's alternative billing APIs
• Technical specifications require standardized user interface elements
• Program expands Google's existing alternative billing frameworks to eighth global market