ITIF challenges UK regulator over proposed Apple and Google steering mandates

The UK's move into ex-ante regulation via the Digital Markets, Competition and Consumers Act 2024 signals a shift from voluntary industry commitments to rigid enforcement. If the CMA effectively turns into a price regulator for link-out transactions, Apple and Google may pivot toward fixed 'core technology fees' to recover costs, directly impacting the margins of high-volume streaming and gaming apps. This regulatory friction mirrors the fragmented global landscape where platforms must navigate the EU’s DMA and Japan’s MSCA. Strategists should monitor if the CMA adopts ITIF's recommendation to allow broader security justifications for anti-steering, which would preserve more platform control over the user experience.

The UK’s Digital Markets, Competition and Consumers Act (DMCCA) represents a significant expansion of regulatory oversight, with the government commencing key parts of the regime in early 2025. Per Taylor Wessing (September 2024), the CMA expected to launch its first Strategic Market Status investigations shortly after commencement, specifically targeting firms with global revenues exceeding £25 billion. These steering consultations, closed in July 2026, follow a period of increased pressure on the regulator to deliver concrete competition gains after critics labeled earlier voluntary agreements with Apple and Google as too lenient.

Regulatory benchmarks from other regions suggest that mandates for lower fees do not always translate to lower costs for the end-user. According to an Analysis Group study commissioned by Apple (November 2025), a 10-percentage-point decrease in commission rates in the European Union led to price reductions for consumers only 9% of the time, with over 86% of the savings flowing to developers based outside the EU. This data has become a central argument for think tanks like ITIF when challenging the efficacy of mandated fee caps in the UK market.

Furthermore, the UK’s proposed approach appears more rigid than Japan's Mobile Software Competition Act (MSCA), which came into full effect in December 2025. Per CSIS (January 2026), the Japanese law designates Apple and Google as regulated providers but allows for more flexibility in how platforms notify users about the risks of third-party billing. As of early 2026, roughly 70% of surveyed smartphone games in Japan had already integrated external payment systems, providing the CMA with a real-time testing ground for how steering requirements influence both developer monetization and platform security protocols.