CMA Opens Consultation on Binding Requirements for Apple and Google Mobile Platforms
The Development
On June 30, the CMA opened a formal public consultation proposing specific conduct requirements for Apple and Google under the Digital Markets, Competition and Consumers Act — the legislation that granted the CMA designated 'Strategic Market Status' powers. The proposed obligations target the core chokepoints: Apple's App Store rules and iOS defaults, Google's browser and search defaults on Android, and the interoperability restrictions that both companies use to limit third-party competition. This is not an investigation or a warning — it is the CMA operationalising its new enforcement framework and moving toward binding rules that carry financial penalties for non-compliance. The consultation closes ahead of formal requirement-setting, making this the last structured window for market participants to shape the obligations before they become enforceable.
Our Take
The CMA's move signals that the era of self-regulation for mobile gatekeepers is closing in a second major market, alongside the EU's Digital Markets Act. What makes this consequential for marketing is the specific targeting of default settings and interoperability — the two levers Apple and Google use to control identity, attribution, and browser-based tracking. If the CMA compels changes to iOS defaults or mandates app store interoperability, the UK becomes a meaningful test environment for what post-gatekeeper mobile advertising infrastructure actually looks like. Brands with significant UK digital spend should be modelling that scenario now, not waiting for requirements to be finalised.
What Changed
For the first time in the UK, a regulator has a direct legislative mechanism to mandate specific behavioural changes on mobile platforms without waiting for lengthy competition litigation. Binding requirements can be imposed and updated faster than traditional antitrust remedies, creating an ongoing compliance obligation rather than a one-time settlement.
Marketing Impact
Media and programmatic buying teams with UK digital budgets face the highest near-term exposure. Changes to mobile defaults and app store access directly affect attribution infrastructure, audience reach on iOS, and the viability of alternative measurement approaches currently blocked by platform restrictions.
Competitive Implication
Privacy-first ad tech vendors and alternative browser and identity providers gain structural leverage if interoperability requirements are mandated — they get the access they cannot currently negotiate commercially. Apple and Google's ability to use platform defaults as a competitive moat in the UK is directly at risk.
Strategic Outlook
The consultation response period shapes the final requirements, which means trade bodies and large advertisers who engage formally have disproportionate influence on the outcome. Expect both Apple and Google to mount detailed submissions. The CMA is unlikely to retreat from the framework — the question is how specific and how quickly enforceable the obligations become.
The Exploit
Action Item
Heads of media and regulatory affairs at brands spending more than £5 million annually in UK digital should submit formal consultation responses before the deadline — this is the only structured moment to influence the specific conduct requirements before they become binding.