CMA proposes designation of Apple and Google under the UK digital markets competition regime

The Competition and Markets Authority (CMA) is currently consulting on its provisional decisions to designate Apple and Google as having Strategic Market Status (SMS) in relation to each of their mobile platforms, under the UK digital markets competition regime.

These are the first proposed SMS designations under the regime in the Digital Markets, Competition and Consumers Act 2024 (DMCCA), which came into force on 1 January 2025. If confirmed by the CMA, the designations would not only affect Apple and Google; they could have far-reaching implications for the millions of businesses that use or rely on Apple and Google’s mobile platforms as a route to market.

In this briefing, we summarise what the CMA is proposing and how the CMA’s proposed approach aligns with its framework for supporting the UK government’s growth mission. We also highlight what businesses should be doing in response to the consultation and proposed designations now and going forward.

What has the CMA provisionally found and what is the CMA proposing?

Apple and Google hold an effective duopoly in mobile platforms in the UK. Having identified concerns about the operation of their mobile platforms in the face of limited competition, the CMA is proposing to designate Apple and Google as having SMS in relation to each of their mobile platforms (ie, mobile operating system, native app distribution, mobile browser and browser engine). For Apple, this includes iOS, iPadOS, App Store, Safari and WebKit. For Google, this includes Android, Google Play Store, Chrome and Blink.

A finding by the CMA that Apple/Google have SMS does not imply that they have acted anti-competitively. However, if the CMA designates Apple/Google as having SMS, then it will be able to impose bespoke Conduct Requirements (CRs) or Pro-Competition Interventions (PCIs) to promote greater competition and protect consumers. For further detail on the digital markets competition regime, read our briefing.

The CMA has published separate roadmaps for Apple and Google, setting out possible measures to improve competition in respect of each of their mobile platforms in the UK.

What are the CMA’s roadmaps?

The roadmaps are strategic planning documents in which the CMA has categorised potential interventions into four categories:

1. Category 1 concerns immediate priority areas in which the CMA sees a strong case for intervention and plans to begin consultations from autumn 2025. These focus on ensuring fair dealing for app developers in app distribution. Such areas include, for example: ensuring that Apple/Google act fairly in relation to reviewing, approving and ranking third party apps and in considering access requests from app developers; and ensuring that Apple allows developers to direct users outside the App Store (eg, to their own websites to make purchases).
   
   
2. Category 2 relates to medium-term priority areas which will require further analysis and which the CMA proposes to consider from the first half of 2026. Examples include: Requiring Apple to allow browsers other than Safari to use their own engines and design user interfaces, ensuring that Apple/Google do not favour their own services, and exploring Apple’s/Google’s control over AI functionality.
   
   
3. Category 3 concerns lower priority issues that the CMA does not expect to consider in the first half of the proposed (five-year) designation period. Examples include: Default app settings for all third-party apps, improved data transfer/switching application programming interfaces between iOS and Android, and equal functionality for third-party browsers.
   
   
4. Category 4 includes issues that are under investigation in other jurisdictions and which the CMA intends to monitor, such as: alternative app stores on iOS/iPadOS/Android, alternative in-app payment methods, and the impact of the revenue sharing agreement between Apple and Google (under which Google pays Apple a proportion of the advertising revenue that it earns from Google Search being the default search engine in Apple’s Safari browser).

The CMA has published the roadmaps to support pace and provide greater predictability for Apple and Google and other market participants. This is in line with the CMA’s “4Ps” framework (consisting of pace, predictability, proportionality and process), which was introduced earlier this year in response to the strategic steer from government to support growth, investment and business confidence in the UK economy. To learn more about the CMA’s “4Ps” framework, read our briefing. The CMA’s decision to defer action in relation to matters which are under investigation by regulators in other jurisdictions is in line with the principle of proportionality.

What should businesses be doing in response to the proposed designations? 

Businesses that currently (or may in the future decide to) use or rely on Apple’s/Google’s mobile platforms (whether as an app developer, service provider or platform user) should consider taking a proactive approach in response to the CMA’s consultations and the proposed designations, which includes:

• Identifying how their business interact with Apple’s / Google’s mobile platforms.
• Understanding the potential impact of the proposed designations on their business, including the potential benefits (eg, lower fees and alternative payment options, greater control over customer relationships and better visibility in app stores).
• Developing a clear strategy in terms of engagement with the CMA about the proposed designations.
• Considering responding to the CMA’s consultations, the deadline for which is 20 August 2025.
• Looking out for the CMA’s final decisions to be made by 22 October 2025.
• Looking out for updated roadmaps addressing the CMA’s approach to the more complex issues that the CMA has identified, to be published in the first half of 2026.
• Reviewing the business’ platform strategy, where appropriate, to prepare for future changes in relation to, for instance, app review and ranking processes.
• Monitoring and understanding the potential operational changes that may be required to comply with any CRs or PCIs that the CMA might decide to impose.