Apple EU Terms Update: What the DMA Fine Changed

Apple updated its developer terms for the European Union yesterday, and the Apple EU terms update is the direct follow-through on the European Commission's finding in April that Apple had violated the Digital Markets Act through its anti-steering rules. This is not a new fine and not a new investigation. It is Apple's practical response to one it already lost, and the terms of that response are what actually matter for any studio selling to EU customers on iOS. Mobile Dev Memo flagged the update as soon as it landed, and the useful work for a buyer this week is separating what has genuinely changed in the terms from what is simply Apple restating a position it has held since the DMA came into force.

What the April fine actually required Apple to fix

The Commission's April ruling, which this desk covered in The DMA's First App Store Fees: Apple and Meta Fined, centred on anti-steering: Apple's restrictions on how developers could tell users, inside or outside an app, about cheaper purchase options available elsewhere. The Commission's finding was that those restrictions themselves breached the DMA's requirement that gatekeepers allow developers to communicate and conclude deals with customers outside the platform's own payment system. A EUR 500 million fine accompanied the finding. Yesterday's terms update is Apple's attempt to bring its EU rulebook into compliance with that finding, rather than a voluntary improvement offered ahead of any obligation.

What the updated terms change in practice

The specifics of the update deserve a cautious read, since Apple's own communication has been terse and the practical mechanics take time to become clear through developer testing rather than through the announcement text alone. What is confirmed is the direction: loosened restrictions on how developers can direct EU users toward external purchase options, adjusted language around what a developer may communicate inside an app about pricing elsewhere, and continued evolution of the fee structure running alongside those changes. This sits inside a broader restructuring Apple had already signalled for its EU business terms, the shift toward a Core Technology Commission replacing the earlier per-install Core Technology Fee, which does not take effect until January 2026 but frames the direction Apple is moving in as it works through each individual compliance obligation the Commission identifies.

Why "compliant" is still contested

The Coalition for App Fairness, the developer advocacy group that has pushed hardest against Apple's DMA implementation, has consistently argued that each round of Apple's terms updates falls short of genuine compliance, reframing restrictions rather than removing them. That pattern is worth expecting to continue with this update specifically. A terms change made in direct response to a regulatory finding is not the same as a terms change both sides agree resolves the underlying complaint, and the Commission itself has shown a willingness to reopen enforcement when it judges a gatekeeper's response inadequate. Buyers should read this week's update as one move in an ongoing back-and-forth rather than a closed chapter, and should expect further iteration, and possibly further enforcement action, before the EU's anti-steering rules and Apple's implementation of them settle into a stable state.

What a UA and finance team should check this quarter

For a studio with meaningful EU iOS revenue, the practical to-do list is narrower than the regulatory story suggests:

• Confirm with legal or a platform-compliance lead exactly what language a store listing or in-app messaging can now use to reference external purchase options under the updated terms, rather than assuming a general loosening applies uniformly.
• Model the fee impact of both the current terms and the January 2026 Core Technology Commission shift against actual EU revenue, since the two changes are related but not identical, and treating them as one event risks missing which applies when.
• Keep a compliance log of what Apple's terms said at each update this year, given the pace of iteration, so a finance or legal review six months from now is not reconstructing history from memory.
• Watch for the Commission's own response to this update specifically, since a finding that Apple's fix is inadequate would restart the enforcement clock and could bring a further fine or a further terms revision before the year is out.

Why buyers, not just developers, should be reading this

It is tempting to treat App Store terms updates as a legal and business-development concern rather than a UA one, but the anti-steering mechanics at the centre of this fine and its follow-through directly affect how a studio can message its own web shop or external purchase options to EU users inside its own app and store listing. A UA team running a link-out or web shop strategy in the EU, the kind of setup this desk has covered repeatedly since the DMA's gatekeeper obligations came into force, needs to know precisely what in-app and store-listing language is now permitted, because a campaign or landing page built on last month's assumptions about what Apple allows could fall foul of restrictions the updated terms have not actually lifted, or could unnecessarily under-use permissions the update has newly granted. Reading the terms document itself, or getting a compliance lead's direct summary of it, is worth the time rather than working from a secondhand headline about "Apple loosens EU rules."

The through-line across this entire sequence, the fine, the update, the disputed compliance, is that Apple's EU terms in 2025 are best treated as a moving target with a fixed direction rather than a settled ruleset, and any planning built on the assumption that this week's update is the final word is planning against evidence that says otherwise. The safer planning assumption for the second half of the year is that at least one further round of terms revision, prompted either by continued Commission pressure or by the Coalition for App Fairness's ongoing objections, is more likely than not before Apple's EU rulebook settles into whatever form actually survives contact with sustained regulatory scrutiny.

Related archive reading

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

• The DMA for UA operators, in plain terms
• The EU Digital Markets Act and App Stores, One Year On