A new EU antitrust complaint filed with the European Commission alleges that Apple’s App Store terms still fall short of the Digital Markets Act (DMA), even after Apple introduced EU-specific pathways for alternative app distribution. The filing, submitted by civil-society groups, claims that the current program’s fine print and design choices limit real-world interoperability, keep third-party app stores on the margins, and impose financial barriers that smaller developers cannot realistically meet.
What’s new and why it matters
This complaint lands during a pivotal phase for the DMA, which is moving from theory to supervision and enforcement. The groups argue that Apple’s updated EU terms, while outwardly compliant, are structured in a way that frustrates the DMA’s core objective: a more open and contestable market in which rival app stores and direct distribution can meaningfully compete with the default App Store. Because the DMA allows the Commission to issue significant fines and binding remedies, an early complaint of this scope can influence how compliance gets interpreted across the entire ecosystem.
For users and developers, the moment matters because the stakes go beyond a single rule or a single store screen. If the Commission decides the current design suppresses workable competition, it can force changes that make alternative stores easier to find, easier to install, and less risky to operate; if, instead, the Commission buys Apple’s safety and integrity arguments, many developers could face another year of high friction and uncertain economics.
The key claims in the filing
The filing highlights three pillars. First, the groups say the practical experience of launching a third-party store or distributing outside the default channel remains constrained by UX hurdles, access restrictions, and review conditions that discourage mainstream users. The argument is that when installation steps feel unusual or unsafe, most people will abandon the flow and default back to the App Store, which keeps competition largely theoretical.
Second, the complaint points to a stand-by letter of credit (SBLC) reportedly set at €1,000,000 as a recurring and heavy requirement for teams that want to participate in alternative distribution. While Apple frames this as a risk-management measure, the groups note that many small or mid-size publishers cannot lock up that amount of collateral year after year, which turns a “permitted” route into one that is, for most studios, economically closed.
Third, the filing raises interoperability concerns that extend beyond payment mechanics. According to the complainants, limits on APIs, restrictions on certain installation methods, and friction in the store-to-device flow combine to make alternative channels feel like second-class citizens. In their view, the DMA’s promise is not merely that rival stores exist, but that they can operate at a level where ordinary users experience them as normal, safe, and reliable options.
Apple’s response
Apple argues that its EU program protects both users and developers, and that regulators are pressuring the company to run software distribution in ways that increase complexity, reduce clarity, and erode device security. The company has said that it notified the Commission about plans to adjust elements of its program, including the letter-of-credit policy, yet it also says EU officials asked Apple not to implement changes while supervisory reviews are ongoing. Apple’s broader legal stance, in parallel, is that the DMA imposes rigid obligations on gatekeepers without sufficient flexibility for platform stewardship and privacy safeguards.
In public messaging, Apple stresses two points. First, it claims most developers benefit from the scale, consistency, and trust signals the App Store provides, which it says are costly to replicate and easy to undervalue. Second, it argues that any shift away from its integrated review system invites new forms of fraud and malware, which inevitably harm consumers and legitimate developers who have done nothing wrong.
How this fits the DMA—and where enforcement is headed
The Digital Markets Act defines a list of “do’s and don’ts” for designated gatekeepers, and Apple’s mobile platform sits squarely in the spotlight. Earlier this year, the Commission issued the first DMA penalties, including fines tied to App Store anti-steering practices. Those decisions provide a template: the Commission is willing to move quickly when it believes workarounds blunt the DMA’s intent. The new complaint gives Brussels fresh third-party evidence to test whether Apple’s program merely complies on paper or enables genuine competition in practice.
If the Commission escalates, two paths are likely. It can open a formal Statement of Objections that details alleged non-compliance and seeks remedies, or it can fold the complaint into ongoing supervision and push for targeted adjustments, for example around financial guarantees, installation flows, or API access. Either route would send a clear signal to the rest of the industry on how tightly the DMA will be policed.
The UK backdrop and its signaling effect
Although the United Kingdom sits outside the EU framework, a recent UK tribunal ruling found that Apple abused a dominant position by charging excessive commissions for App Store distribution, with damages to be determined. Legally, that case runs on different rails, yet it shapes expectations across Europe. It strengthens the narrative that authorities are willing to scrutinize platform fees, discourage anti-competitive defaults, and entertain structural remedies if behavioral commitments fail to improve outcomes for consumers and developers.
What this means for developers
For studios, the operative question is not whether an alternative store is theoretically permitted; it’s whether a credible channel can be launched without prohibitive collateral, unfamiliar warnings, or endless workarounds. If financial guarantees come down or become risk-scaled, more teams could test true multi-store distribution. If the install flow becomes familiar, predictable, and secure—with clear, human-readable prompts—users will be more willing to try a reputable third-party store for specific genres or pricing models. And if interoperability improves—covering payments, entitlement, and update mechanisms—small publishers can plan roadmaps without betting the company on a single gatekeeper’s policies.
What this means for consumers
For users, the outcome will show up as a choice architecture issue. If the Commission succeeds in pushing for balanced prompts and straightforward installation, alternative stores should feel like normal parts of the device, not fringe experiments. That could translate into new pricing strategies, curated stores for niche categories, and bundles that emphasize privacy or parental controls. Conversely, if guardrails remain heavy and unfamiliar, the App Store will keep its practical monopoly even though formal alternatives exist on paper.
What to watch next
In the near term, watch the Commission’s docket for requests for information; those often precede bigger moves. Also watch Apple’s developer policy pages, which tend to change quietly and then ripple across forums within hours. Any update to the SBLC threshold, to install prompts, or to program eligibility is significant. Finally, expect more market tests where the Commission asks developers to share real data on adoption, churn, conversion, and compliance costs under the current scheme. Those datapoints can make or break the case for remedies.
Bottom line
The new EU antitrust complaint keeps the spotlight on Apple’s App Store terms at a time when Brussels is testing the DMA’s teeth and timelines. If regulators push for lighter financial guarantees, simpler install flows, and cleaner interoperability, developers will gain a practical path to market outside the default store—and EU users will gain real app-store choice, not just the appearance of it.
