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DMCC Act: Commitments on mobile ecosystems

The CMA’s proposed decision demonstrates the flexibility provided by the act, despite criticism of a weakened approach

The CMA proposes to accept non-binding conduct commitments from Apple and Google in mobile platforms markets

On 10 February 2026, the UK’s Competition and Markets Authority (CMA) published for consultation proposed commitments from Apple and Google related to their designation with strategic market status (SMS) in mobile platforms markets under the Digital Markets, Competition and Consumers (DMCC) Act. Both firms were designated with SMS in October 2025 for their respective mobile ecosystems, reflecting their dominance in operating system, app distribution, browser and browser engine markets. In a blog post announcing the commitments, Will Hayter (Executive Director for Digital Markets, CMA) repeatedly described the measures as “immediate” and “pragmatic”, allowing the CMA to deliver change in how these mobile ecosystems operate without the need for a “formal and lengthy process”. The proposed commitments will enter into force on 1 April 2026, subject to views expressed through the ongoing consultation (which closes on 3 March 2026). 

The competition authority will monitor adherence to the commitments through public and confidential reporting

The non-binding commitments offered by Google and Apple, developed through work with the CMA, are broadly grouped into four core priorities for improving access and transparency for app developers, including: 

  1. Fair, objective and transparent review of apps to be distributed in the Apple App Store and Google Play Store;

  2. Fair, objective and transparent process for ranking apps in respective app stores;

  3. Prohibition on the use of app data for unfair purposes, such as to inform Apple or Google’s own app development; and

  4. Fair, objective and transparent decision-making process for reviewing interoperability requests made to Apple. 

The CMA describes that Google and Apple both have internal processes in place in many instances to deliver fair reviews of requests and rankings, but app developers lack trust in these processes. The commitments offered by both firms therefore codify existing processes and aim to provide greater transparency to build or rebuild trust in the objectivity of reviews. Functionally, these commitments include notifying developers of changes to app guidelines and ranking processes, not self-preferencing any of their own apps and improving feedback channels on interoperability requests and app submissions. The CMA would monitor the effectiveness of these changes through each firm’s complaints processes and public reporting from the firms, as well as direct reporting to the CMA and the use of its own information gathering powers. 

The proposed commitments may only delay inevitable binding obligations on the two tech firms

Though the CMA emphasised that its proposed approach would deliver faster and proportionate results in addressing competitive harms in digital markets, it has been criticised as weak and disappointing in failing to create binding conduct requirements for the firms. Unlike the EU’s Digital Markets Act (DMA), in which obligations for dominant firms are explicit in the legislative text, the DMCC Act allows the CMA to design (or decline to design) bespoke interventions for each firm designated with SMS. The CMA noted it did not believe non-binding commitments would be appropriate in all cases and that it would move quickly to introduce conduct requirements in the event that Apple and Google do not meet their commitments or those commitments do not prevent anti-competitive conduct. Civil society advocates, as well as representatives from interested industry associations, expressed concern that only considering legally enforceable obligations after non-compliance would be a delayed response to harms to competition. Sarah Cardell (Chief Executive, CMA) described these commitments as “important first steps” among additional measures to address the functioning of the app store market, setting up potential additional and binding measures to be introduced in the future.