For British app developers, the most important part of the UK's new digital-markets regime may turn out to be less dramatic than a breakup order or a billion-pound fine. It is the ability to tell a customer, inside an app, that there is another place to pay.
The Competition and Markets Authority has now closed consultations on proposed steering conduct requirements for Apple and Google. The proposals would allow developers to direct users out of an app, including to complete transactions elsewhere, on fair and reasonable terms. The consultation responses published in August show why the detail matters. Developers, publishers, consumer groups and industry bodies are not arguing only about the presence of a link. They are arguing about whether that link can lead to a genuinely competitive transaction.
Steering is a pricing issue disguised as a design issue
A developer that can advertise a lower web price, explain an alternative subscription route and maintain a direct billing relationship has more leverage over distribution costs. A developer that is technically allowed to include a link but faces additional fees, warnings, friction or restrictive eligibility rules may gain much less.
That is why the CMA's wording matters. Its proposed requirements are framed around allowing developers to communicate and transact with customers in their native apps while increasing competition in app distribution. The regulator is not merely asking whether a button exists. It is testing whether the commercial route behind the button is usable on fair and reasonable terms.
The UK is building the DMCC regime one conduct requirement at a time
The steering consultations follow the CMA's earlier use of the Digital Markets, Competition and Consumers Act regime in search. In June, the regulator imposed publisher, fair-ranking and data-portability conduct requirements on Google. Those measures now require controls over the use of publisher content in generative AI search features, objective and non-discriminatory organic ranking criteria, and mechanisms for authorised portability of search data.
That sequence is important. The UK's approach is becoming easier to read: designate a firm as having strategic market status in a defined activity, then impose targeted requirements around the specific bottlenecks the CMA believes are weakening competition. British Business Review's earlier guide to the DMCC Act explains the wider framework, but the Apple and Google steering work is the point at which many smaller software businesses may first feel the regime in their own unit economics.
Developers should watch fees, customer data and warning screens
Three details are likely to determine whether a final steering rule changes behaviour. The first is the fee structure applied to transactions that begin inside an app but finish elsewhere. If a platform can reproduce most of its existing commission through a different charge, the competitive effect is smaller.
The second is access to the customer relationship. Direct payments are valuable partly because they can give a developer more control over billing, retention and customer support. The third is friction. Warning screens, repeated confirmation steps or restrictions on how an external offer is described can reduce conversion even where steering is technically permitted.
Those questions also explain the breadth of consultation responses. The Apple process drew submissions from Apple itself, UK Finance, Which?, Associated Newspapers and others. The issue reaches beyond gaming and streaming. Any business that distributes a paid digital product through a mobile platform has an interest in how the final rule defines a fair route to the customer.
This is not the end of the CMA's mobile-platform work
The CMA has said it also expects to progress work involving Apple's browser restrictions and interoperable access to functionality for connected devices. It is monitoring the growing role of AI in mobile platforms as well. Steering is therefore better understood as one piece of a longer attempt to change the terms on which businesses reach users through the two dominant mobile ecosystems.
For UK developers, the sensible response is not to redesign payment flows before a final requirement exists. It is to model the economics now. Businesses should know the difference between their current in-app acquisition cost and a direct-payment route, how much conversion they could lose to added friction, and what customer data would become available if billing moved outside the platform. When the CMA settles the rules, those figures will determine whether steering is a legal curiosity or a meaningful margin opportunity.