Apple's EU terms now face a developer backlash

Apple's EU terms now face a developer backlash three weeks after the company announced them. The coalition pushing back is broad enough to matter. Eighteen developer and industry organisations, including the European Game Developer Federation and the Coalition for App Fairness, signed a joint open letter this week arguing that Apple's August fee restructuring still does not comply with the Digital Markets Act. Apple had presented that restructuring as its response to the DMA's requirements.

We covered the terms themselves when Apple announced them on August 18: a flat 5% Core Technology Commission for apps distributed outside the App Store, replacing the old per-install Core Technology Fee, alongside a tiered 26%, 20% and 15% commission structure inside the store, all taking effect October 1. This piece covers the reaction. The mechanics have not changed since we wrote about them. What has changed is that the developer groups Apple needs to satisfy for genuine DMA compliance have now said in writing, and in coordination with each other, that the new terms fall short.

What the coalition is actually arguing against Apple's EU terms

The letter makes three specific legal points rather than a general complaint about fee levels. First, the 15% steering fee, charged when a developer directs users toward external payment options, conflicts with Article 5(4) of the DMA, which requires gatekeepers to allow free communication and contracting with users outside their platform without commercial penalty. Second, the 5% commission Apple still charges on transactions made through alternative app stores or direct distribution prevents the competition the DMA set out to create. A developer distributing outside Apple's own store still hands Apple a cut of every transaction. Third, the letter points to the mandatory registration and app review that remain in place regardless of distribution channel, alongside contractual requirements that do the same. Those, it argues, preserve Apple's gatekeeping control over who can operate on iOS at all, independent of the fee structure layered on top.

Jari-Pekka Kaleva, managing director of the European Game Developer Federation, offered the sharpest line in the letter: "Other platforms like Windows and Linux charge neither platform nor distribution fees at all for self-distribution." The comparison is doing specific work here. It is not an argument that Apple should charge nothing. It is an argument that a five percent floor on every transaction, whatever route a developer picks to distribute, is not what genuine alternative distribution looks like on platforms that already support it without a toll.

What the coalition wants to happen next

The letter's ask is procedural rather than a specific fee demand: the signatories want the European Commission to formally conclude its ongoing proceedings against Apple's DMA compliance and consult directly with affected developers before accepting Apple's terms as sufficient. Their underlying concern, stated plainly in the letter, is that quietly accepting the August terms as compliant would let Apple rewrite what the DMA requires through its own implementation choices, rather than through regulatory scrutiny. The coalition is not only lobbying Apple. It is lobbying the Commission to stop this particular implementation becoming the de facto standard.

Why a coalition letter carries more weight than individual complaints

Apple has absorbed individual developer criticism of its DMA compliance approach continuously since the original terms took effect in January, without much visible change to its position. What makes this letter different is coordination and standing. The European Game Developer Federation and the Coalition for App Fairness are not individual developers with a grievance; they are organisations that exist specifically to represent developer interests to regulators, and eighteen of them signing the same letter within three weeks of the terms landing signals a level of consensus that is harder for the Commission to treat as background noise. It also puts Apple in a position where the loudest response to its August announcement has come from the representative bodies the Commission would normally consult anyway when assessing whether a gatekeeper's compliance plan is genuine, rather than from a single aggrieved competitor. None of that guarantees the Commission acts quickly, or at all. It does raise the reputational and procedural cost of Apple's terms sailing through unchallenged.

What this changes for a UA team this quarter

Nothing changes operationally yet. Apple's terms take effect October 1 regardless of this letter, and the Commission's proceedings, even if it acts on the coalition's request, will not resolve on a timeline that affects Q4 budget planning. Two things are worth tracking rather than acting on:

• If the Commission opens a fresh formal proceeding specifically on the August terms, that would be the first concrete sign the backlash has regulatory traction beyond an open letter, and a reason to revisit your fee-structure assumptions.
• The steering-fee argument is the one to watch, since it goes to whether developers can meaningfully tell users about cheaper payment options without effectively being taxed for doing so, which is directly relevant to any web shop strategy built around the DMA's external-payment provisions.

Do not delay your own October 1 fee-structure planning while you wait for this to resolve. The letter challenges Apple's compliance; it does not suspend the terms, and the terms are the operating reality until a regulator says otherwise.

For now, this is a fight over what "compliant" means, playing out between Apple and the developer organisations the DMA exists to protect, with the Commission holding the decision that actually matters. The terms UA teams need to plan against are still the ones Apple announced on August 18. That will remain true unless and until the Commission itself intervenes, which is a materially higher bar than an open letter, however broadly signed, clearing.

It is worth remembering how this pattern has played out with Apple's EU terms before. Apple has already revised its EU developer terms at least once under direct regulatory pressure: after a fine over its DMA compliance in 2025, the company updated its EU terms that same year in direct response. Those terms were themselves superseded at the start of this year, when the per-install Core Technology Fee gave way to a flat Core Technology Commission, the same mechanism the August overhaul now extends and restructures. So Apple has adjusted its terms under sustained regulatory pressure before, while maintaining each time that its approach already satisfies the DMA. Whether this letter generates enough pressure to prompt a similar adjustment is the open question the coming months should answer.

Related archive reading

These articles provide related context and remain subject to their stated review status.

• Apple's EU fee overhaul: a flat 5%, a 26/20/15 ladder, and October 1
• The DMA for UA operators, in plain terms