App store steering: what the CMA's proposal could mean for your business app

If your business has a mobile app that sells anything, whether subscriptions, bookings, top-ups or digital goods, the Competition and Markets Authority (CMA) is working on a change that could affect how you take payment. The proposal is about "steering": letting an app point customers to your own website to buy instead of using Apple's or Google's in-app payment system. It is not final, but it is worth understanding now, because it affects how you plan pricing and the way you build.

What steering means in plain English

Steering is an app developer's ability to tell users about purchase options outside the app store that distributed the app. In practice that could be a link or button inside your app that takes a customer to your own website to complete a purchase, or simply a message telling them another way to pay exists. At the moment, app store rules restrict this. The CMA describes steering as the restrictions that stop developers directing users outside an app to complete transactions.

Where things stand

The CMA's mobile platforms work is published on GOV.UK. The key dates are:

• 22 October 2025: the CMA designated Apple and Google as having strategic market status in their mobile platforms. The designations last five years.
• 1 April 2026: final voluntary commitments from Apple and Google were published, covering app review, how apps are ranked, how data is safeguarded and, for Apple, developers' requests for interoperable access to iOS features.
• June 2026: the CMA consulted on proposed steering conduct requirements for both companies, aimed at letting developers steer users out of apps on fair and reasonable terms.
• 14 August 2026: the responses to those consultations were published.

The CMA's page does not give a final decision or a date for one. A law firm briefing last updated on 29 August 2026 says plainly that the proposals are not yet final rules and that no final steering requirement has been imposed. Treat everything below as what could happen, not what has happened.

What could change for a business with an app

According to the CMA, if steering measures take effect, developers could direct users to complete purchases outside the app, manage customer relationships directly, choose their own billing provider and avoid the app store commissions that apply to in-app transactions. That last point needs care, which is the next section.

Payment choice is only part of it. Selling directly can change who owns the customer relationship, which matters for renewals, refunds, cancellations, customer data and support, particularly for subscription businesses.

Why it is not simply "no commission"

The solicitors PAIL make the point that steering does not automatically mean commission-free transactions. Fees linked to steering may still apply, and the contractual conditions attached to external routes matter as much as the right to link out. The CMA's proposals include principles intended to keep any fees Apple and Google charge for steering fair and reasonable.

That fee question is where opinion is sharpest. The Coalition for App Fairness, a developer lobby group, said on 30 June 2026 that the measures fall short of what is needed to meaningfully increase competition. It argued that any fee can only be justified by transparent data from Apple and Google on their actual costs, and that without limits on fees for transactions the platforms do not process, the reform risks being little more than cosmetic. In other words, developers want more, and the platforms are still being consulted. The mood is cautious rather than settled, which is a good reason not to bet your pricing on one outcome.

The legal side of selling directly

If a customer buys on your website instead of through the app store, you take on more of the legal responsibility. The PAIL briefing lists the areas to review:

• consumer and subscription terms
• pricing and renewal disclosures
• cancellation and refund processes
• payment-provider agreements
• privacy notices and data processing
• marketing consent and direct communications
• app store developer terms and rules on external links
• who is responsible for what between the platform, you and your payment provider

What to do this week

The PAIL briefing advises against redesigning your business model around a particular outcome while the rules are not final. A sensible, low-cost approach is to prepare rather than commit:

• Work out your numbers. Compare what you currently pay on app store transactions with what a direct payment model would cost, including payment provider fees and the extra admin.
• Read your platform agreements. Note what they currently say about external purchasing and links.
• Map the customer journey. Where would a user be sent, and what would they see before buying?
• Check your direct-sale terms. If you would become the contracting party, are your terms, refund process and renewal wording ready?
• Keep the build flexible. Ask your developer to keep payment logic modular, so a link-out option could be added later without rebuilding the app.
• Watch the CMA. Its final decision will set the practical opportunity.

If you are planning an app or reviewing an existing one, our mobile app development team can help you think through how payments and customer accounts should be structured so you are not locked into one route.

The bottom line

Steering could give app owners more choice over how and where customers pay, and possibly a better margin. But the fees are undecided, the rules are not final, and selling directly comes with extra legal and operational work. The smartest move for a small business is to do the sums, tidy up your terms and keep your app flexible, then decide when the CMA publishes its conclusions.