Two civil rights organisations, ARTICLE 19 and Gesellschaft für Freiheitsrechte (GFF), have filed a formal complaint with the European Commission alleging that Apple is failing to comply with key obligations under the EU Digital Markets Act (DMA). The complaint calls for decisive enforcement action to ensure that Apple grants users genuine choice over which applications and app stores they can access on their devices.
Under Articles 6(4) and 6(7) of the DMA, Apple, as a designated gatekeeper, must enable the installation and use of third-party apps and app stores on its iPhone and iPad devices. These provisions are intended to guarantee interoperability, foster competition from smaller or alternative providers—including not-for-profit developers—and enhance consumer choice.
However, according to the complaint, Apple’s terms and conditions for its App Store and iOS operating system make such interoperability “practically impossible.” The organisations argue that Apple’s restrictions, including a requirement for third-party app stores to provide a €1 million security deposit (in the form of a stand-by letter of credit), effectively exclude smaller providers from accessing Apple’s ecosystem. This, they claim, has a particularly detrimental effect on SMEs and free software developers.
“It’s time Apple users are free to access apps from their app store of choice. The EU rules mandate it – but Apple hides behind unfair, unnecessary, and disproportionate terms and conditions, making it impossible in practice,” said Maria Luisa Stasi, Head of Law and Policy for Digital Markets at ARTICLE 19.
The complaint urges the European Commission to take “appropriate steps” to bring Apple into full compliance with its DMA obligations. The groups contend that Apple’s continued non-compliance harms both third-party developers and end users, who remain unable to exercise meaningful choice in how they use their devices.
“The EU Digital Markets Act requires Apple to allow app stores from other providers on its devices. We want the company to finally comply with this requirement – and have therefore filed a complaint with the EU Commission,” said Jürgen Bering, Head of the Center for User Rights at GFF.
A copy of the 16-page complaint, shared with Reuters, highlights how Apple’s practices allegedly undermine the DMA’s core goal of opening digital markets to fair competition and innovation. The complainants also noted that the €1 million security requirement could impose a recurring annual cost and collateral obligations that many small developers cannot meet.
Under the Digital Markets Act, fines for non-compliance can reach 10% of a company’s global annual turnover, and up to 20% for repeated violations. The European Commission, which enforces the DMA, confirmed receipt of the complaint but declined to comment on whether it would launch a formal investigation. Apple has not yet issued a public response.
This complaint comes just months after Apple was fined €500 million by the Commission in April 2025 for breaching Article 5(4) of the DMA. That earlier case concerned Apple’s anti-steering provisions, which prevented app developers from directing users to alternative app stores or offering cheaper deals outside Apple’s own payment system. The decision marked the first major enforcement action under the DMA, which entered full effect in 2024.
As a designated gatekeeper, Apple is subject to ongoing DMA obligations covering its App Store, operating systems, and other core services. The law forms part of the EU’s broader digital strategy aimed at curbing the dominance of major online platforms—including Apple, Google, Meta, Amazon, and Microsoft—and ensuring fairer, more open digital markets.
If the European Commission proceeds with a formal investigation, it would intensify the mounting regulatory scrutiny Apple faces in Europe, where competition and consumer authorities are increasingly coordinating to enforce the EU’s digital fairness agenda.
