Apple’s new App Store warnings in the EU technically comply with regulation—but raise questions about whether they are designed more to deter than to inform.
Apple’s ongoing efforts to comply with the European Union’s Digital Markets Act (DMA) are facing renewed scrutiny following the introduction of new warning messages on App Store listings in the EU.
While these user disclosure screens have been in place since March 2024 as part of Apple’s original DMA compliance plan, they have gained renewed attention in recent weeks.
Apple told Payments Expert that in August 2024, the company announced a package of updates to its compliance plan, including changes to the disclosure messaging. However, the company says the European Commission (EC) objected to the rollout of these changes at the time and has not since provided further guidance.
The warnings, which reportedly now appear on apps using external payment systems, are the latest in a series of moves by Apple to align with the regulation.
But while the company technically meets the letter of the law, questions remain about whether its approach undermines the broader intent of the DMA.
The warning labels
The new notices, which began appearing across the EU App Store in recent weeks, inform users when an app does not use Apple’s own in-app payment system.
The message reads: “This app does not support the App Store’s private and secure payment system. It uses external purchases.”
A red exclamation mark accompanies the message, drawing immediate visual attention and implicitly signalling risk. When tapped, the warning links to a dedicated Apple support page outlining the potential risks of external payment processors, including fraud, lack of refund guarantees, and weaker consumer protections.
Though the language is carefully worded, the messaging leans towards highlighting the relative safety of Apple’s own infrastructure over third-party solutions.
Regulatory context
The changes come in the wake of the European Commission’s $560m (€500m) fine against Apple earlier this year, following a lengthy investigation into its App Store policies.
One of the primary findings was that Apple’s long-standing “anti-steering” rules—preventing developers from directing users to alternative payment options—violated the DMA, which aims to increase competition and limit the gatekeeping power of dominant platforms.
The DMA requires so-called “gatekeepers” to allow app developers to inform users of alternative payment methods and to offer them within apps. Apple’s previous restriction on this practice was deemed to stifle competition and unfairly prioritise its own payment system.
In response, Apple updated its policies in the EU to permit external payments. But the implementation has drawn criticism from developers and industry watchers who argue that the company’s execution creates friction for users and casts doubt on non-Apple options.
Apple says the EC did not raise objections to the user disclosure screen that went live in March 2024, but did request that Apple hold off on planned revisions to the screen announced in August of that year. The company maintains it has not received further guidance from the EC since then.
Meeting the letter, not the spirit
From a regulatory perspective, Apple can argue that it is in compliance. Developers are now allowed to offer external payment systems, and users are being clearly notified when an app does so. Transparency, in theory, is a step forward.
However, the design and language of the warnings suggest an intent to discourage use of these alternatives. The red exclamation mark, in particular, gives the appearance of a security alert—more akin to a system error than a neutral disclosure. The framing may lead consumers to associate third-party payments with lower trust, regardless of the reputability of providers such as Stripe, PayPal, or Square.
The messaging also raises broader concerns about whether Apple’s approach upholds the spirit of the DMA. While technical compliance is achieved, the law’s intent is to level the playing field—not to create new, subtler barriers to competition.
What’s next?
The European Commission has not yet formally responded to the updated warning system. However, given Apple’s contention that it was not allowed to implement revised disclosures despite offering them, this regulatory standoff could become a flashpoint in the evolving interpretation of DMA compliance.
It also sets a precedent for how other gatekeepers may seek to comply with the DMA. Google, which operates the Play Store, has introduced alternative billing in some regions but has not implemented comparable warning labels.
If Apple’s approach is seen as setting a precedent, it could influence broader industry practice—or trigger further rulemaking to clarify acceptable disclosure standards.
This article was amended on May 21, following Apple providing clarification to Payment Expert regarding the issue.
