Apple’s Response to the EU’s DMA: What Developers Need to Know

On 25th January, Apple published its guidance on how it would comply with the EU’s Digital Markets Act (DMA). The response, in keeping with Apple’s response to other demands for reforms, effectively disincentivizes most apps from taking advantage of the changes. The changes are complex and confusing, and the answer to whether apps should make changes isn’t completely black-and-white. 

To help developers navigate these changes, we pulled together an “emergency” episode featuring RevenueCat’s CEO Jacob Eiting and Head of Product Jens-Fabian Goetzmann, Runway CEO Gabriel Savit, and Nico Wittenborn, founder of Adjacent. 

Here are the discussion’s key takeaways:

📲 The DMA Reforms How App Stores Work in the EU — The DMA mandates that app stores, like Apple's, cannot enforce the use of first-party app stores or in-app payment systems in the EU. Android already supports third-party app stores (sideloading), so Google’s focus has been on offering alternative payments via “user-choice billing”. For Apple, which does not support sideloading, the EU reforms have needed to be much more significant.   

🔓 Apple Releases Opt-In New Business Terms — Apple’s response was to introduce an optional new set of business terms with a dizzying number of changes to fees and choices for developers. By opting-in, developers unlock new ways to distribute their app and charge users, but doing so comes with changes to and additions to fees paid to Apple. The changes are complex enough that developers have to analyze the implications very carefully.  

🌀Fee Structure of the New Terms is a Complex Maze — Apple's new terms introduce a convoluted fee structure, where reduced commissions are coupled with the Core Technology Fee (CTF), where developers pay €0.50 for the first annual install over a 1M threshold. The CTF includes not just first-time installs, but first annual re-installs and updates from first and third-party app stores as well. This install fee effectively means that any high volume low average revenue per user (ARPU) app is likely to lose out by accepting the new terms. 

🛑 Third-party App Stores Unviable for All but the Biggest Players — The new terms aren’t so rosy for potential new “marketplace apps”, either. New app stores will not be exempt from the CTF, making the first 3M downloads of the marketplace app itself cost the operator €1M — €0.50 per install over the 1M download threshold. And then apps within that marketplace also have to pay the CTF fee. This means that opening a third-party app store is unviable except for the very biggest attempts or for stores that have a high-charge per install (e.g. a game marketplace where users pay a relatively high one-off fee per game).     

🔍 There Might Be Strategic Opportunities, but They Remain to Be Seen — Yes, most apps seem to be better off sticking with the original terms. But there might be opportunities for niche apps. For example, apps that have a low volume of installs but high ARPU (by having a costly yearly subscription, for example) might be able to absorb the CTF, even considering yearly updates. An additional as-yet unexplored change is that Apple has introduced 600 new APIs, meaning that there’s an opening for new third-party applications and integrations.   

About Guests

📱Gabriel Savit is CEO of Runway, a release platform for iOS and Android apps. Find Gabriel on X and on LinkedIn.

💲Nico Wittenborn is Founder of Adjacent, an early-stage VC firm. Find Nico on X and on LinkedIn.

😺Jens-Fabian Goetzmann is Head of Product at RevenueCat

Links & Resources

• These aren’t the only concessions Apple has recently had to make. Earlier this month, the Supreme Court ordered that Apple needed to allow developers to link to alternative payment methods in the US. Read more about what those changes mean.
• On the RevenueCat blog, we’ve written up an overview of this podcast and included additional details that weren’t covered on the podcast and/or have come to light since the recording.

Episode Highlights

[2:31] What is the Digital Markets Act (DMA)? It’s a series of directives set by the EU that aim to limit the dominance of large tech platforms, dubbed “gatekeepers” (of which Apple and Google are a part), and provide more choices to developers and end-users.  

[10:34] The principal decision that developers need to make in response to Apple’s changes is: do we switch to the new terms or remain on the old? Right now, there is no indication that it’s a two-way door. 

[13:34] When opting into the new terms, there are effectively four separate models: stay distributing through the App Store using Apple’s IAPs; stay distributing through the App Store but use alternative payment providers; distribute instead on a third-party marketplace using alternative payments; or distribute on both the App Store and third-party marketplaces. 

[15:47] The Core Technology Fee (CTF), in the new terms, charges developers €0.50 per first annual app install on installs above the 1M threshold. This includes first annual reinstalls and updates, and it’s the CTF that is fundamentally making the economics of new terms unviable for most developers. 

[30:24] Why haven’t third-party marketplaces taken off on Android? It’s probably down to the size of the opportunity. Most apps, even if they’re multiplatform, make most of their money on iOS. Now that the possibility of third-party marketplaces is available on the most profitable platform, it suddenly becomes worth looking into.

[41:41] There are instances where creating a third-party marketplace would be financially beneficial, such as a premium game distribution platform — higher-priced games ($20+) would negate the disadvantages shown by the CTF. 

[47:03] Unless things change, 99% of developers should probably not switch to the new terms. At best, it’s a bad idea, at worst it’s a huge distraction with the risk of owing Apple more in fees than revenue generated. There is a small subset of apps that could benefit, but those apps know who they are, and they’ll find a way to test the waters and mitigate the risk involved.  

[52:48] Another opportunity is the 600 new APIs that Apple is making available. It’s too early to say what that opportunity will look like, but there are likely to be some innovative third-party applications to come out of it.