DMA steering links on an EU IAP screen
Operator checklist for EU App Store anti-steering duties under DMA Article 5(4), anchored to the Commission’s 23 April 2025 Apple non-compliance decision.
Purpose
When shipping an EU IAP screen with web or alternative-offer links, map the flow to DMA Article 5(4) anti-steering duties as enforced against Apple’s App Store CPS.
Anchors
The Commission’s 23 April 2025 press summary states developers distributing via Apple’s App Store must be able to inform customers free of charge of alternative offers outside the App Store, steer them to those offers, and allow them to make purchases. It records a €500 million fine on Apple for breach. The EUR-Lex summary of Decision DMA.100109 describes Commission findings that Apple’s terms limited steering (including link-out-only paths, destination restrictions, recurrent disclosure sheets, and fees on transactions completed within seven days after link-out).
Checklist
| # | Check | Pass if |
|---|---|---|
| 1 | Jurisdiction | EU/EEA storefront users only for this flow |
| 2 | Communication | In-app pricing / offer communication not blocked beyond what current Apple EU terms still unlawfully restrict — escalate to counsel if still gated |
| 3 | Link-out | Destination not artificially limited to a single approved template if your counsel reads Art. 5(4) more broadly |
| 4 | Fee on steered txn | Finance model flags any Apple fee on steered transactions as DMA-contested |
| 5 | Disclosure sheet UX | Recurrent scare-sheet friction logged as compliance risk, not “best practice” |
| 6 | Parallel Japan/US | Do not copy Japan MSCA or US screens into EU without a separate legal pass |
Limits
This is an operator checklist from Commission decision materials, not a substitute for the full non-confidential decision PDF or live Apple EU business terms on the day you ship.
