Apple’s has revealed its latest attempt to bypass the DMA. Its new proposed system(nouvelle fenêtre) looks like it gives developers more freedom to take users outside the App Store, but it’s nothing more than another blatant example of malicious compliance. Hidden under confusing fees and commissions, Apple has rebuilt the same Apple Tax and roadblocks, just with new names. And Apple has made it so confusing that no one can figure out what these new fees would look like in practice:
This is by design. Apple doesn’t want anyone to leave its current setup, where it skims 30% off every App Store purchase (and 15% off every renewal). That’s why its first attempt to “comply” with the DMA was incredibly punitive for developers. And that’s why this latest attempt is so complicated and full of risks. These proposals are custom-built to make Apple’s previous, illegal system look reasonable by comparison.
Apple, a company that rose to a valuation of over a trillion dollars by obsessing over every aspect of the user experience, is resorting to a maze of fees, complicated legalese, and threats — including the risk of being banned from the App Store — all to prevent developers and users from having a choice. It would be funny if it weren’t for all the users, developers, and businesses who are already hurting.
This is not a compliance plan. It’s a deterrent.
And it’s not an honest attempt to comply with the DMA. It’s Apple’s bid to keep its monopoly going.
Apple’s new class system – and a new “commission”
One of the most hated parts of Apple’s previous DMA compliance plan was the Core Technology Fee (CTF), a €0.50 charge per install after the first million installations for any given app. Apple’s new plan phases the CTF out on January 1, 2026, but replaces it with a Core Technology Commission (CTC), a 5% fee on any sale made using a link from the App Store to your own site or app. Until then, some developers may still have to pay the CTF, others the new CTC, making the new terms even harder to understand.
Apple has indicated that it will likely shift all developers to a new set of App Store terms on January 1, 2026. However, it hasn’t actually explained what those terms will be. This means the options Apple announced on June 26, 2025 aren’t real choices. Why would any competent developer switch to a new fee model that might be obsolete or rewritten in six months? This isn’t clarity or compliance. It’s another trick to buy time.
Below is our best attempt to explain how Apple’s new proposal would currently work in the EU. We break it down into four cases, but the reality is even more complex, as we don’t account for the Small Business Program’s different rates.
Option 1: The illegal status quo
Apple’s old terms still apply by default, meaning:
- 30% for subscriptions on in-app purchases
- 15% after the first year
These are Apple’s global terms and conditions. But developers aren’t allowed to link out of the App Store, meaning these terms clearly violate the DMA. Pressure from the European Commission is the only reason Apple decided to phase the old terms out on January 1, 2026.
Option 2: Developers remain in Apple’s walled garden
In cases where developers use the App Store, In-App Purchase (IAP) system, and Apple’s payment processing service without links to outside sites, their fees would be as follows:
- 17% App Store services fee on all new purchases in the App Store (and a 10% fee on all renewals).
- A 3% payment processing fee.
- A Core Technology Fee (CTF) of €.50 for each install after the first 1 million.
Option 3: Developers are buried under fees
This lets developers keep all the current functionality of the App Store while still being able to link outside. While they will have more freedom in what they can link to (webpages, apps, and alternate app stores) and can promote offers, use of Apple’s IAP or payment processing service will be unavailable. They face the following fees:
- A 2% “initial transaction fee” on all purchases made by new users for the first six months following the initial installation of the app.
- A 13% App Store services fee on all purchases and subscriptions inside the App Store (and 10% on renewals).
- The CTF of €.50 for each install after the first 1 million or a 5% Core Technology Commission (CTC), depending on the type of contract*.
- A payment processing fee, although the payment will go to a third-party payment provider. While not paid to Apple, developers still have to account for this fee, as Apple traditionally covered this cost.
Option 4: Slightly reduced fees for a greatly reduced user experience
This lets developers link outside the App Store but removes many of the App Store features that users and developers rely on. At this tier, apps cannot auto-update or automatically download across devices. They will not appear in App Store search suggestions or display user reviews or ratings.
They face the following fees:
- The 2% initial transaction fee for the first six months.
- A 5% App Store services fee on all purchases inside the App Store (and 5% on renewals).
- The CTF of €.50 for each install after the first 1 million or the 5% CTC, depending on the type of contract.
- A payment processing fee, although the payment will go to a third-party payment provider as in option 3.
Apple doesn’t want to let developers leave
If you take advantage of Apple’s new terms and link to your own site or app, you cannot use Apple’s in-app purchase feature. This prevents developers from being able to experiment, compare which method is more effective, or offer both options for a better user experience.
Additionally, any developer who wants to offer purchases outside the App Store must meet Apple’s strenuous requirements. You must use specific OS versions, report every transaction, and submit to audits.
And if you violate any part of this proposal, regardless of the additional burdens it imposes and its intentional opacity, Apple can boot you off the App Store.
Apple thinks it can bully the EU
It appears that Apple doesn’t believe the EU will continue to fight to enforce the DMA.
Apple thinks it can drag this out in court, file endless arguments, and pretend to comply while flouting the spirit of the law and continuing to charge illegal fees.
They believe they can get away with this because they’ve done it before. And they will do it again until it costs them less to finally comply with the law. The European Commission must now stop trying to negotiate with Apple and treat Apple’s plan for what it is: a direct challenge to its authority. The European Commission should use all possible tools in its DMA enforcement kit, including issuing a specification decision. If Apple’s non-compliance is still an issue, it should issue maximum fines.
If Europe wants to lead, if we want to build real sovereignty in tech, we must strengthen and speed up enforcement. This is about so much more than preventing exorbitant fees. It’s about creating a fair marketplace so European innovation can thrive.
Monopolies hold us all back
Apple thinks it can bully governments, developers, and its own users and still win. It doesn’t think the EU is willing to continue this fight. And that’s a shame. It shows that a company once defined by innovation would rather bleed dry everyone trapped in its walled garden than build something new.
We believe your success should be determined by your capacity to dream up things never before seen and your ability to bring those dreams to life, not the power you’ve amassed to hold your user and developer community captive. Apple keeps using fake and bad-faith security arguments to justify its non-compliance, but its main concern is clear: Ensuring it can continue using the App Store to trap and cheat developers and users.
Apple has chosen rent-seeking over risk-taking. It’s betting the EU won’t finish the fight. Europe must prove Apple wrong. It’s time to build a digital ecosystem where innovation matters more than gatekeeping.
*In the EU, Apple developers now face two options:
1. Stick with Apple’s old terms but they must sign a separate contract to enable link-outs(nouvelle fenêtre), and the Core Technology Commission (CTC) applies immediately.
2. Accept Apple’s full set of new terms(nouvelle fenêtre) and the Core Technology Fee (CTF) applies until the end of the year. ↑
