The German Federal Cartel Office (Bundeskartellamt) has initiated a market test to evaluate Apple’s proposed adjustments to its App Tracking Transparency Framework (ATTF), following significant competition concerns raised earlier in February 2025. The move marks a key step in the authority’s ongoing assessment of whether Apple’s data-access rules unfairly disadvantage rival app developers.
According to Andreas Mundt, President of the Federal Cartel Office, the case hinges on who controls access to user data—and consequently, who gains a competitive edge in the digital ecosystem. Because Apple unilaterally designs and enforces the ATTF, its rules have far-reaching implications for competition. Mundt emphasized that such rules must be transparent, fair, and applied equally to all developers. The authority continues to see “a fundamental need for change” and is now examining whether Apple’s latest proposals meet competition law requirements.
The ATTF regulates how apps obtain user consent to access data used for advertising. In its current form, Apple displays different consent prompts for its own apps compared with those shown to third-party apps. These prompts vary in design, wording, and complexity, which the authority believes nudges users toward granting data-use permission to Apple services while discouraging consent for competing apps. This asymmetry, the Bundeskartellamt argues, may create significant competitive distortions, particularly as third-party developers depend heavily on data-driven advertising revenue.
Apple’s recently submitted commitments—developed after extended discussions with the regulator—include substantial revisions to both the ATT Prompt used by third-party apps and Apple’s own PA Prompt. The company proposes neutral, standardized designs free from previously identified “dark patterns,” along with clearer explanations of technical processes. Apple has also outlined options to simplify the consent architecture for third-party developers, allowing them to obtain user consent for advertising-related data processing more efficiently through a unified prompt.
However, Apple is not offering changes to its attribution system for measuring advertising performance, which it currently conducts without obtaining user consent. The Bundeskartellamt remains critical of this practice and will evaluate during the market test whether Apple’s limited data usage in attribution continues to place competitors at a disadvantage. The question of whether Apple is legally required to obtain consent for attribution will be addressed in consultation with data protection authorities.
The market test will involve app developers, media and advertising associations, content providers, and German data protection authorities. Their feedback will inform the authority’s continued assessment. Only after evaluating the responses will the Bundeskartellamt determine whether Apple’s commitments sufficiently address the competition concerns identified.
The proceedings are being conducted under both German law (§19a GWB) and EU competition law (Article 102 TFEU). Several national authorities have conducted or are still conducting similar investigations, with coordination taking place through the European Competition Network and the European Commission.