The UK Competition and Markets Authority this week accepted voluntary promises from Apple and Google to improve app store transparency, opting not to impose binding enforcement rules despite years of investigation documenting how the tech giants control access to millions of British consumers.

The decision means Apple and Google will police their own behavior through self-reporting and public attestations rather than face mandatory conduct requirements that could have forced structural changes to their mobile ecosystems. Thousands of UK app developers remain dependent on the App Store and Google Play Store as gatekeepers determining which applications reach iPhone, iPad, and Android users.

The regulator's approach has drawn immediate criticism from competition lawyers who argue the tech platforms secured preferential treatment unavailable to smaller firms facing antitrust scrutiny. According to the CMA's call for evidence published February 10, 2026, the commitments "merely codify review processes that already exist, and provide more transparency around them."

Apple and Google each submitted separate proposals on February 5, 2026, addressing four areas where the CMA identified competition concerns: how apps get reviewed for approval, how apps rank in store search results, how developer data gets used, and how developers can request access to iPhone and iPad functionality. The proposals would take effect April 1, 2026, relying primarily on enhanced transparency reporting rather than operational changes.

Google's 24-page proposal and Apple's 14-page document outline procedural safeguards including public attestations of fair treatment, annual transparency reports, and complaint mechanisms for developers. Neither company agreed to limit its discretion over which apps receive distribution approval or how search algorithms rank competing applications.

The approach contrasts sharply with the CMA's investigation record spanning 856 pages of documents since 2022 identifying substantial competition concerns in mobile ecosystems.

The decision represents a shift from the regulatory approach the CMA previously deployed when it designated Google with Strategic Market Status on September 30, 2025, following an investigation that documented Google's 90 percent market share in UK search queries. That designation resulted from detailed findings about substantial barriers to entry and concentrated market power in general search services.

Competition lawyer Thomas Höppner questioned the CMA's enforcement strategy in LinkedIn commentary dated February 10, 2026. "To encourage Apple and Google to keep their soft promises, the CMA added: 'We will move quickly to bring forward conduct requirements if these commitments are not adhered to,'" Höppner wrote. "I somehow doubt this 'warning' will impress."

The proposals arrive amid intense global regulatory scrutiny of mobile platform operators. A UK tribunal ruled on October 23, 2025 that Apple abused its dominant position through App Store restrictions and 30 percent commission rates. Google faced similar intervention when a federal judge ordered the company on October 7, 2024 to allow third-party app stores access to the Google Play catalog following Epic Games' successful antitrust litigation.

App review commitments maintain platform discretion

Both companies committed to conducting app reviews based on published policies without self-preferencing their own applications. Apple pledged to provide rejection or approval decisions for 90 percent of app submissions within 24 hours, while Google stated it reviews "millions of apps and app updates globally each month, with a recent average review time of less than one day."

The transparency measures include requirements to notify developers about guideline changes. Apple committed to announce material changes to review guidelines "on the same day such changes become effective," while Google offered "reasonable notice, allowing them sufficient time to make necessary changes." Google's proposal includes "reasonable grace periods for developers to bring their apps into compliance following a policy change."

Both platforms promised to explain rejection decisions and provide appeal mechanisms. Apple committed to "maintain safeguards for developers in connection with any app removal decisions, including the Platform-to-Business complaints handling mechanism." Google committed to "provide an independent alternative dispute resolution process that will be available for UK developers, in line with the retained Platform-to-Business Regulation."

The commitments preserve substantial platform discretion over which apps receive distribution approval. Apple's proposal states the App Review function will operate "within Apple" while maintaining independence from teams responsible for Apple's apps and services. The formulation raises questions about operational separation given the internal reporting structure.

Ranking algorithms remain opaque despite disclosure promises

App store search ranking has emerged as a critical factor determining developer success. Both companies committed to operating ranking systems in "a fair, objective and transparent manner" while declining to disclose specific algorithmic weightings that would enable developers to optimize their applications effectively.

Apple committed to ensuring its search algorithm "prioritises user engagement, app quality and delivering users the most relevant results, and does not self-preference Apple's own first-party apps." The company promised to provide approximately one week advance notice for major changes to search algorithm inputs that would render public guidance outdated.

Google stated its ranking operates based on three criteria: user relevance, app quality, and user experience. The proposal commits to "provide UK developers with reasonable notice, allowing them sufficient time to make necessary changes, regarding policy updates and material changes relating to Play's app ranking."

Neither company agreed to disclose the relative weighting of ranking factors or the specific signals their algorithms evaluate. The proposals acknowledge that "specific ranking algorithms must remain confidential to guard against the risk of manipulation and ranking abuse."

Both platforms offered analytics tools enabling developers to measure search performance. Apple committed to "provide analytics tools that allow developers to measure and track their search performance," while Google promised "a powerful suite of testing and analytics tools in the Play Console."

Data safeguards rely on internal compliance systems

The companies committed to protecting third-party developer data from use in their own app development, relying on internal access controls and employee training rather than technical separation of data systems.

Apple stated it "has never sought to use the App Store, nor the data it holds by virtue of running the App Store, as a means to develop competing features and services." The proposal commits to maintaining processes including tagging developer data within Apple's data mapping framework, requiring legal review for data access requests, monitoring access through logging systems, and deploying mandatory training for relevant personnel.

Google committed to "not use non-public Play data to support the development of its first-party apps." The company's safeguarding mechanisms include strict internal data policies prohibiting inappropriate use, technical access controls that refuse data access by default, assessment of access requests by data access owners, and training for personnel responsible for granting access.

Both proposals rely on attestations and confidential reporting to the CMA rather than independent auditing of data access patterns. Apple clarified that it "does not interpret, and will not apply, Developer Program License Agreement Section 9.3 in any way that would undermine the protections and processes it has documented in these commitments."

The enforcement mechanism depends on internal compliance systems. Google stated that its data use policies "will be supported by Google's Employee Code of Conduct, which mandates strict compliance subject to disciplinary action." Neither company agreed to external verification of whether employee access to developer data occurred or how that data was subsequently used.

Apple's interoperability channel creates formal request process

Apple proposed establishing a dedicated feedback channel allowing UK developers registered in the Developer Program to request interoperable access to system and hardware functionality equivalent to what Apple services or accessories use. The commitment addresses longstanding developer concerns about arbitrary denial of access to iOS and iPadOS capabilities.

According to Apple's proposal, eligible requests "will be placed in a dedicated internal queue for timely review" by a team with "specific expertise in iOS and iPadOS interoperability and platform integrity." Apple committed to "endeavour to provide developers with an update on the status of their requests within four weeks of receiving them."

The company published substantive criteria for assessing requests including expected user and developer uptake, alignment with Apple's platform priorities, potential implementation costs, potential impact on user experience and security, and potential impact on Apple's intellectual property rights. The proposal states that receiving a request "will not create any obligation or expectation that Apple will commit to building a specific requested feature."

Apple retained discretion to refuse requests it determines ineligible, defining eligible requests as those seeking "access to equivalent system and hardware functionality used by Apple services or accessories." The company committed to inform developers if submitted requests are deemed ineligible and moved to existing feedback channels.

The CMA acknowledged that if Apple "is routinely declining interoperability requests without good reasons, this will inform our pipeline of wider work - and we could bring forward specific interoperability requirements." The regulator's monitoring approach depends on reviewing aggregated request data rather than evaluating individual denial decisions.

Transparency reporting creates monitoring framework

Both companies committed to publishing annual UK-specific transparency reports alongside confidential reporting to the CMA. The public reporting includes metrics on app review volumes, rejection rates, appeal outcomes, and complaint handling through Platform-to-Business mechanisms.

Apple's public reporting will cover app submissions reviewed, app rejections, apps approved after rejection, appeals from rejections, apps approved after appeal, App Store removals, App Store removal appeals, restorations after appeals, percentage of reviews completed within 24 hours, percentage of reviews exceeding 24 hours, and number of expedited reviews.

Google committed to publish aggregated anonymized data on app review and enforcement including submission volumes and rejection suspension rates on a bi-annual basis, overview of primary policy areas associated with app rejections and suspensions, aggregate annual number of internal complaints and appeals with proportion of decisions upheld or reversed, and information on resources and support channels available to UK developers.

The confidential reporting to the CMA includes substantially more detailed metrics. Apple will provide summary metrics relating to usage of support resources and tools, metrics verifying timely publication of developer notifications, data on Google Play Academy course completions, usage metrics for policy feedback tools, technical control metrics for those tools, metrics on frequency and timing of alternative dispute processes, and explanations of material policy changes with rationales.

Google's confidential reporting covers data verifying publication of new developer guidance, metrics on developer-facing notifications of material changes, data on Academy course activity, usage metrics for compliance tools, technical outage information, alternative dispute process timing, aggregated data on average and median app review times, total number of developer complaints and appeals with outcomes, overview of complaint types, and median time to action complaints.

The CMA committed to publish annual updates on its monitoring work while retaining authority to impose formal Conduct Requirements if developments warrant stricter intervention.

Industry response highlights enforcement skepticism

The Coalition for App Fairness submitted feedback dated February 2025 documenting concerns that Apple's and Google's app review processes lack transparency and apply arbitrarily. One stakeholder outlined having to design "entire workflows and processes to accommodate for the inconsistency of Apple's review process, which added cost and complexity to their business."

BBC's response dated February 2025 stated that changes to ranking "are made with no notice" while noting that "Apple and Google have limited incentive to make free apps prominent." The broadcaster submitted that "measures should be in place to prevent Apple and Google, as owners of their respective operating systems, from using data to which only they have access to gain an advantage in developing their first-party apps."

Dr. Jaime Gonzalo, Apps & Games professional at Google, EA, and Huawei, characterized the proposals as "underwhelming indeed" in LinkedIn commentary dated February 10, 2026. Tim Cowen, Chair of Antitrust Practice at Preiskel & Co LLP, questioned the CMA's acceptance approach, asking "Why accept this? Judicial Review need to be filed quickly."

The commitments contrast with enforcement actions in other jurisdictions. Japan's Mobile Software Competition Act, which took effect December 17, 2025, requires platform operators to allow alternative app stores and payment systems with strict compliance rules. Italy imposed a €98.6 million fine on Apple on December 22, 2025 for requiring developers to obtain double consent under App Tracking Transparency while using different standards for Apple's own advertising services.

The CMA's Mobile Ecosystems Market Study, published in 2022, outlined competition concerns across 356 pages. The regulator followed with Strategic Market Status decisions for Apple's and Google's mobile platforms spanning 283 and 217 pages respectively in 2025. Despite this extensive investigation record, the CMA opted to accept voluntary commitments rather than impose binding requirements under its Digital Markets, Competition and Consumers Act 2024 powers.

Competition authorities in multiple jurisdictions have pursued more aggressive intervention. Privacy-focused software company Proton AG filed a class-action lawsuit against Apple on June 30, 2025, alleging the company maintains illegal monopolies in app distribution and payment processing markets. The European Commission imposed a €1.8 billion fine on Google for ad tech practices on September 5, 2025.

The consultation period for stakeholder feedback closes at 5pm on March 3, 2026. The CMA stated it will "consider views alongside ongoing engagement with stakeholders" before finalizing whether to accept the commitments as sufficient to address competition concerns in mobile ecosystems.

Timeline

  • June 10, 2022: CMA publishes Mobile Ecosystems Market Study identifying competition concerns across 356 pages
  • August 13, 2020: Epic Games files lawsuits against Google and Apple challenging app store practices
  • October 7, 2024: Federal judge orders Google to allow third-party app stores access to Play Store catalog
  • September 30, 2025: CMA designates Google with Strategic Market Status following investigation finding 90%+ market share
  • October 23, 2025: UK Competition Appeal Tribunal rules Apple abused dominant position in app markets
  • December 17, 2025: Japan's Mobile Software Competition Act takes effect requiring alternative app stores and payment systems
  • December 22, 2025: Italy fines Apple €98.6 million for App Tracking Transparency double consent requirements
  • January 14, 2025: CMA launches Strategic Market Status investigation into Google's search and advertising services
  • February 5, 2026: Apple and Google submit proposed commitments to CMA
  • February 10, 2026: CMA publishes call for evidence on proposed commitments
  • March 3, 2026: Deadline for stakeholder feedback on proposed commitments
  • April 1, 2026: Proposed effective date for commitments if accepted by CMA

Summary

Who: The UK Competition and Markets Authority announced proposed commitments from Apple Inc. and Google LLC addressing mobile platform competition concerns. The proposals affect thousands of UK app developers distributing applications through the App Store and Google Play Store.

What: Apple and Google each submitted voluntary commitments covering app review processes, search ranking algorithms, developer data usage, and interoperability access. The commitments rely on enhanced transparency reporting, public attestations, complaint mechanisms, and confidential reporting to the CMA rather than structural changes to platform operations or binding conduct requirements.

When: The companies submitted proposals on February 5, 2026. The CMA published its call for evidence on February 10, 2026, with a consultation period closing March 3, 2026. The commitments would take effect April 1, 2026, if accepted.

Where: The commitments apply to UK-based developers and UK App Store and Google Play operations. The regulatory action occurs under the CMA's Digital Markets, Competition and Consumers Act 2024 authority following Strategic Market Status designations and extensive mobile ecosystem investigations.

Why: The CMA seeks to provide developers with confidence that app review, ranking, and data usage operate fairly, objectively, and transparently without requiring formal conduct requirements. The regulator concluded that voluntary commitments could prove "a swift, effective and proportionate way of addressing these specific concerns" despite receiving feedback documenting inconsistent application of policies, arbitrary ranking changes, and concerns about platform data usage for competitive advantage.

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