
In compliance with the EU Digital Markets Act, Apple does permit developers to direct users to external links for completing purchases. However, developers are required to follow a prescribed format and may not prepopulate the URL with user data (such as identifiers used to track payments). Additionally, Apple displays a security warning before such links are opened.
Most notably, even when developers guide users to make payments via external links, they are still obligated to pay Apple a commission of 27%. While this appears marginally lower than the 30% fee imposed through Apple’s in-app purchase system, once external payment processing fees are added, developers may actually incur greater losses. Furthermore, smaller developers already benefit from a reduced 15% commission rate under Apple’s standard policy.
Given Apple’s previous non-compliance, the EU imposed a €500 million fine on the company in April 2025. However, following the issuance of the penalty, Apple failed to address the violations. Consequently, under the provisions of the Digital Markets Act, the European Commission has issued a formal warning, demanding that Apple rectify its conduct within 30 days. If no corrective action is taken within 60 days, the Commission will proceed with additional penalties.
In its official statement, the European Commission declared:
“In view of the seriousness of Apple’s non-compliance with Article 5(4) of Regulation (EU) 2022/1925, as established in this Decision and considering that the non-compliance has been found to be on-going, the Commission concludes that it is necessary to impose periodic penalty payments pursuant to Article 31(1), point (h), of Regulation (EU) 2022/1925 if Apple were to fail to implement measures that bring the infringement effectively to an end within 60 calendar days from the date of notification of this Decision.
Any periodic penalty payments that may be definitively set should be sufficient to ensure compliance by Apple with this Decision and may take account of Apple’s significant financial resources (see recitals (286) and (307) of this Decision).”
Following its investigation, the Commission concluded that Apple had failed to provide any compelling evidence to challenge the severity of its non-compliance. The company’s conduct remains in violation of the Digital Markets Act. As a result, the Commission has issued a new notice demanding immediate corrective action.
Apple, for its part, argued that the Digital Markets Act does not mandate it to technically enable or facilitate “steering” (i.e., guiding users to external payment options), asserting that the legislation merely permits such steering. This semantic interpretation was summarily rejected by the EU, which stated that Apple’s restrictions, surcharges, and technical barriers undermine the effectiveness of the regulation.
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