On this page · 10 sections
- Decided vs proposed: the status on 13 November 2026
- What the CMA is proposing on steering
- Where Google stands in the UK today
- Where Apple stands in the UK today
- Today vs the CMA proposal
- What it means in pounds
- Decision table: what to do before the CMA decides
- Implementation checklist
- How eCorpIT can help
- References
Summary. As of 13 November 2026, the Competition and Markets Authority (CMA) has not decided whether to impose steering rules on Apple or Google in the UK. Settled: both have had strategic market status (SMS) in mobile platforms since 22 October 2025, for five years, and voluntary commitments on app review, ranking and data use took effect on 1 April 2026. Proposed only: draft steering conduct requirements under the Digital Markets, Competition and Consumers Act 2024, consulted on from 30 June to 28 July 2026. They would let UK developers link to web checkout, allow one neutral interstitial screen, and permit a steering fee only if the platform proves it fair and reasonable, charged on purchases within seven days of the link. Both consultation pages still say the CMA is analysing feedback; it had promised a decision later in 2026. Apple still bars UK steering, while Google has allowed UK external links since 30 June 2026 at 10% on subscriptions and 20% on other purchases. For a £9.99 monthly plan, steering beats Apple's 15% or 30% commission only if a future Apple steering fee stays under about 10% or 25% respectively.
About this article. For UK product, payments and mobile teams selling digital goods or subscriptions through the App Store or Google Play. We checked every date, fee and draft provision against CMA documents, Apple and Google developer pages, Stripe's UK pricing and HMRC guidance on 13 November 2026. This is general information, not legal or tax advice; fees change, and no vendor paid for inclusion. Researched with AI assistance and reviewed by our editorial team.
Decided vs proposed: the status on 13 November 2026
The table separates decisions from proposals, using the CMA's case, programme and consultation pages and Google's billing choice page.
| Measure | Status | Date | What it means for UK developers |
|---|---|---|---|
| SMS designation of Apple and Google mobile platforms | Decided | 22 October 2025, for 5 years | The CMA can impose conduct requirements |
| Commitments on app review, ranking, data use and iOS interoperability requests | In force (voluntary) | 1 April 2026 | Clearer review and ranking; no fee changes |
| Google's UK Play terms allowing steering | In force (Google's terms, not a CMA order) | 30 June 2026 | External links and alternative billing, with fees |
| Steering requirement for Apple | Proposed; consultation closed | 30 June to 28 July 2026; responses 14 and 17 August | Would end Apple's UK ban on links |
| Steering requirement for Google | Proposed; consultation closed | Same; responses 14 August | Would test Google's UK fees and link rules |
| NFC access requirement for Apple | Proposed; consultation open | 20 October to 17 November 2026 | Not steering: contactless access for third-party apps |
| Direct commission cap | Not proposed | Kept under review | May return if steering fails |
The CMA's 30 June press release said it would decide later this year whether to impose new requirements. The case pages, last updated on 5 November 2026 for a change of decision makers, list no steering decision, and GOV.UK showed nothing later on 13 November. In September the CMA's executive director for digital markets said the platforms want value-based fees while many developers accept only cost-based ones.
Treat every steering detail below as a draft. Once imposed, a conduct requirement is binding, like the three already in place on Google search, including the fair ranking requirement. Our UK iPhone NFC guide covers the NFC proposal.
What the CMA is proposing on steering
The two consultation documents (79 pages for Apple, 78 for Google) set out near-identical drafts. The CMA notes Apple's 30% headline commission, with an average rate close to it.
Effective steering rights
Under draft paragraph 3, Apple and Google must not stop a developer from communicating with UK users, including after in-app account registration, or from placing a link in the app and its metadata that sends users to an external website to buy. The only carve-out is a restriction strictly necessary to prevent malware, fraud, unlawful content or content harmful to children.
Draft paragraph 5 adds that limiting a link's form, links carrying the user's selected product or authorised details, or the prices shown may count as restrictions. The platforms need not support steering into other installed apps, only to the web.
Equal treatment and the single interstitial
Draft paragraphs 6 to 8 require the link to be presented and used in the same or an equivalent way to the platform's in-app purchase flow; showing both side by side is allowed. One interstitial screen telling users they are leaving in-app purchase is permitted, but it must use neutral wording (no warnings, risk framing or talk of lost protections), match the in-app design and not discourage the purchase. No other friction is allowed: no hidden prices, extra steps or discouraging warnings.
The steering fee test
The drafts set no number. Under draft paragraphs 9 to 13, a steering fee is allowed only if the platform can show the CMA that it is fair and reasonable under three principles:
- Cost-based. Long-run incremental costs of the distribution services steered developers use, a share of common costs on objective drivers, and a reasonable return, excluding the platform's own content, general marketing, developer tooling and payment security features that steered sales do not use.
- Value-based. The value the store provides, adjusted for the firm's substantial and entrenched market power, and crediting the value developers contribute.
- Administrative simplicity. The fee structure must not create technical or admin barriers that make steering ineffective.
The press release adds that the CMA would expect steering fees to be lower than current app store charges. That is an expectation, not a cap.
Timing rules for subscriptions
A steering fee may only apply to a purchase completed within seven days of the user reaching the alternative checkout through the developer's link. Recurring subscription payments fall outside that limit, so renewals of a subscription started through a link could carry a fee. The one protection: no steering fee on an auto-renewing subscription the user had entered into before reaching the alternative checkout.
Non-discrimination
Under draft paragraph 14, developers that steer must not be treated worse in app review, search ranking or discoverability, API access or interoperability. The April 2026 commitments on review and ranking are voluntary; a conduct requirement would be enforceable.
Where Google stands in the UK today
Google's billing choice program has been open for UK users since 30 June 2026 and lets developers offer in-app alternative billing or external web links, always alongside Google Play Billing. A transaction counts as an existing install if the user first installed or updated the app from Play before that date. Service fees on UK transactions:
- 10% on auto-renewing subscriptions.
- 20% on other purchases through an external web link, for new and existing installs.
- 20% on other purchases through in-app alternative billing from new installs, and 25% from existing installs.
- 10% on the first $1 million of annual earnings.
- 15% for Apps Experience or Games Level Up programme members on linked purchases and on alternative billing from new installs, available to UK users since 30 September 2026.
- A further 5% billing fee on purchases through Google Play Billing.
Google charges a link fee only on purchases completed within 24 hours of the user following the link, a shorter window than the CMA's seven-day maximum, and developers must report those transactions within 24 hours. The CMA said it would assess Google's changes in the next phase of its work, so a final Google requirement could accept, adjust or test these fees. Full fee tables, with US comparisons, are in our Google Play vs Apple App Store fees guide.
Where Apple stands in the UK today
Apple's App Review Guidelines, last updated on 16 October 2026, still bar apps and their metadata from including buttons, external links or other calls to action that point to other ways of buying digital goods, except on the US storefront and where Apple grants a link entitlement. Apple's StoreKit documentation describes those entitlements for regions including the EU, South Korea, Japan and Brazil, not the UK. The CMA describes steering as banned by Apple in the UK, with two narrow exceptions: multiplatform services that also sell the same items in-app, and reader apps, which can link to account creation or management but cannot offer in-app purchase.
Apple's UK rates are its global ones: 15% for Small Business Program members with up to $1 million in prior-year proceeds across associated accounts, 30% standard, and 15% on subscriptions after a subscriber's first year of paid service. Apps selling physical goods and services, such as groceries or rides, can already link out, choose their own payment processor and pay no commission.
US rules differ: the guidelines let US storefront apps include external purchase links, and Apple's case with Epic Games is before the US Supreme Court (No. 25-1311), with argument set for 11 January 2027.
Today vs the CMA proposal
Sources: Apple's guidelines, Google's billing choice page and the CMA drafts.
| Point | Apple today (UK) | Google today (UK) | CMA draft for both |
|---|---|---|---|
| In-app links to web checkout | Not allowed | Allowed via billing choice program | Must be allowed |
| Prices for outside offers shown in the app | Not allowed | No price restriction listed | Must be allowed |
| Warning or information screen | Not applicable | One-time information screen plus a user choice screen | One neutral interstitial only |
| Fee on steered purchases | Not applicable | 10% subscriptions, 20% other | Allowed only if shown fair and reasonable |
| Attribution window | Not applicable | 24 hours | Maximum 7 days, recurring subscription payments excepted |
| Fee on pre-existing auto-renewals | Not applicable | Not stated on Google's page | Not allowed |
| Ranking and review protection | Voluntary commitments | Voluntary commitments | Enforceable non-discrimination |
What it means in pounds
Because the CMA has not set a fee, the useful number is the break-even steering fee: the highest fee at which web checkout still beats in-app purchase.
Assumptions: a £9.99 monthly or £79.99 annual plan including 20% VAT, so £8.33 or £66.66 net, with store percentages applied to the net price. Web checkout uses Stripe's UK list prices on 13 November 2026: 1.5% + 20p per standard UK card (premium UK cards cost 2.8% + 20p) plus Stripe Billing's 0.7% pay-as-you-go fee. On £9.99 that is £0.15 + £0.20 + £0.07 = £0.42 per payment (5.0% of net); on £79.99 it is £1.20 + £0.20 + £0.56 = £1.96 (2.9%). On your own website you account for UK VAT; when you sell digital services through a platform such as an app store, HMRC says the platform accounts for it. Conversion loss, refunds and support costs are excluded.
| Plan | In-app purchase rate | Break-even steering fee |
|---|---|---|
| £9.99 monthly | 15% (Small Business Program or after year one) | About 10% |
| £9.99 monthly | 30% (standard, first year) | About 25% |
| £79.99 annual | 15% | About 12% |
| £79.99 annual | 30% | About 27% |
Each break-even figure is the in-app rate minus Stripe's cost as a share of net price: 15 minus 5.0, 30 minus 5.0, 15 minus 2.9 and 30 minus 2.9.
Worked example: a UK subscription app
A hypothetical company has 15,000 UK iOS subscribers on the £9.99 monthly plan: 15,000 × £8.325 × 12 = £1,498,500 a year net of VAT. Half are past their first paid year, so its blended Apple rate is 22.5%, or £337,163 a year. Its proceeds after commission, about £1.16 million, equal roughly $1.54 million at ECB reference rates for 12 November 2026 (₹124.66 per pound, ₹94.05 per dollar), above the Small Business Program threshold.
Suppose a steering requirement is imposed and 40% of payments (72,000 a year) move to web checkout. The remaining in-app payments cost £202,298 in commission and the web payments £30,224 in Stripe fees. The fee levels below are scenarios, not CMA or Apple figures; each 5 points of steering fee adds £29,970 (5% of the £599,400 steered).
| Apple steering fee (scenario) | Annual cost of commission, Stripe and steering fee | Saving against today |
|---|---|---|
| 0% | £232,522 | £104,641 |
| 5% | £262,492 | £74,671 |
| 10% | £292,462 | £44,701 |
| 15% | £322,432 | £14,731 |
At this blended rate, the saving disappears once a steering fee passes about 17.5%; for a Small Business Program developer paying 15%, at about 10%. That is why the fee principles in draft paragraphs 10 to 13 matter more to most UK teams than the right to show a link.
On Android, where steering is open today, the £9.99 plan costs about £1.25 per payment either way: Google's 10% link fee (£0.83) plus £0.42 for Stripe, or 10% plus the 5% billing fee through Play Billing. On the £79.99 annual plan, Play Billing costs £10.00 a year against £8.63 for a link (£6.67 plus £1.96), saving about £1.37 per subscriber.
Decision table: what to do before the CMA decides
| Do this | If |
|---|---|
| Build web checkout now, behind a UK iOS flag set to off | You sell digital content or subscriptions on iOS and want to switch on soon after a decision |
| Steer on Android now | You sell annual plans or one-off purchases, where Google's link fee saves 5 to 10 points before processing |
| Stay on Play Billing for Android monthly plans | Your monthly price is near or below £10, where Stripe's fixed 20p erases the 5-point saving |
| Enrol in Apple's Small Business Program | Your prior-year proceeds across associated accounts were up to $1 million; at 15%, steering pays only below a fee of about 10% |
| Wait before re-pricing UK iOS plans | Until the CMA publishes a final requirement and Apple publishes a UK steering fee |
Implementation checklist
- Separate UK from US logic. US storefront apps may include purchase links under Apple's guidelines; UK apps may not. Configure by storefront, not device locale.
- Prepare UK VAT handling for web sales. HMRC says non-UK sellers whose digital sales to UK consumers are liable to UK VAT must register, and cross-border sellers must keep two pieces of evidence of where each consumer lives.
- Design the link UI to the draft. Price display, a single button next to in-app purchase and no extra steps.
- Instrument attribution. Record link taps and purchase timestamps to test whether a purchase falls within 7 days (CMA draft) or 24 hours (Google today).
- Separate pre-existing subscribers. The draft bars a steering fee on auto-renewals that began before the user reached your checkout, so tag web subscribers by origin.
- Integrate Google's billing choice APIs. Report linked UK transactions within 24 hours, after moving to a current Play Billing Library; our Play Billing Library 9 migration guide covers it.
- Watch the CMA case pages. They will carry any decision notice and compliance date.
How eCorpIT can help
eCorpIT is a Gurugram-based technology organisation, founded in 2021, assessed at CMMI Level 5 and MSME certified, with senior-led engineering teams working across AWS, Microsoft and Google platforms. Our mobile application development team builds storefront-aware billing for UK apps, from web checkout behind a feature flag to Google billing choice integration and attribution logging. Talk to us at /contact-us/.
Last updated: 13 November 2026.
