DMA.100204 – Consultation on the proposed measures for requesting interoperability with Apple’s iOS and iPadOS operating systems

All citizens, companies and organisations are welcome to contribute to this consultation. The Commission especially welcomes contributions from companies that have requested, or may consider requesting, interoperability with features from Apple’s operating systems iOS and iPadOS under the Digital Markets Act.

The DMA is a new European legislation that aims to make digital markets fairer and more open, including by opening closed ecosystems. The DMA applies to gatekeepers, which are companies operating large digital platforms that play an important role in the digital economy and act as gateways for other companies to access end users. Apple is one of such gatekeepers as concerns its operating systems iOS and iPadOS. 

Amongst others, the DMA requires gatekeepers to provide interoperability with and access to software and hardware features of designated operating systems such as iOS and iPadOS.  To assist Apple in enabling such interoperability, the Commission opened proceedings on 19 September 2024 to specify measures that Apple should implement to improve the request-based process for requesting interoperability with iOS and iPadOS set up by Apple to comply with the DMA. The Commission’s case reference is DMA.100204.

While the DMA prescribes interoperability by design for new features, the Commission considers that where gatekeepers set up a request-based process for existing non-interoperable features, it is crucial to ensure that this process preserves the developers right to effective interoperability.  

On 18 December 2024, the Commission addressed its preliminary findings to Apple, including the draft measures that Apple should implement to improve the request-based process for requesting interoperability with iOS and iPadOS. A case summary and the proposed measures are available in the Reference documents section below. 

The Commission is now seeking feedback from third parties on these proposed measures to ensure that Apple’s request-based process is transparent, timely and fair. In this context, the Commission seeks the views from interested third parties on whether the measures are sufficient to make the request-based process set up by Apple effective.

In particular, the Commission seeks views on whether these measures achieve their objectives:

• Is the mapping of existing frameworks adequate to provide developers with prior information to submit a request and to obtain interoperability?
• Are the proposed timelines adequate to establish a timely and predictable process that takes into account the specificities of the varying technical needs? 
• Are the proposed measures on communication and feedback allowing adequate developers’ involvement in the process?
• Are the transparency measures allowing developers to be sufficiently informed about the process and its outcome?
• Would the proposed process ensure a fair treatment of the requests and accountability for Apple’s decisions? 
• Are the proposed measures adequate to ensure that the request process delivers interoperability solutions that are effective and future-proof? 

Should the measures not be deemed adequate:

• How can a specific measure be improved in order to establish a fair, transparent and predictable process conducive to effective interoperability?

The Commission will carefully assess the feedback provided by interested parties and Apple. The input received may result in adjustments to the proposed measures and will feed into the Commission’s decision on the legally binding final measures applying to Apple. The Commission will adopt a final decision within 6 months of opening the proceedings.

This consultation concerns Apple’s process for requesting interoperability with iOS and iPadOS. The Commission is organizing a separate consultation on interoperability between iOS and connected devices (case reference DMA.100203).

You can submit your contributions through EUSurvey.

The deadline to respond to this consultation is 9 January 2025.

Your submission must be non-confidential in its entirety. 

If you need to submit confidential information to the Commission for this consultation, this confidential information must be submitted separately from a stand-alone non-confidential submission. You must also submit a non-confidential summary of your supplementary confidential submission. Technical input about the proposed measures should only be included in your non-confidential submission.