The German competition authority, Bundeskartellamt, said on Monday that Apple had offered a series of commitments aimed at addressing its concerns. The commitments have now been made legally binding, bringing the competition proceedings against the technology company to an end.
At the centre of the case is Apple’s App Tracking Transparency Framework, which requires third-party app providers to obtain additional user consent through an Apple-designed prompt before carrying out certain forms of cross-company data use.
According to the regulator, the requirements were not applied in the same manner to Apple’s own services and offerings, raising concerns that the company’s rules could place competing app providers at a disadvantage.
Apple to Align Consent Requests
Under the commitments agreed with the German authority, Apple will bring the consent prompts used for its own offerings and those presented by third-party applications more closely into line.
The company will also remove symbols and wording from its predefined requests for third-party providers that the regulator considered potentially discouraging to users.
In addition, app publishers will have greater flexibility to combine Apple’s consent request with consent requirements arising under data protection legislation. They will also be able to connect the requests in ways that make the process clearer and easier for users to understand.
Bundeskartellamt President Andreas Mundt said the issue was not whether Apple should protect users’ privacy, but whether it could impose additional rules within its ecosystem that treated its own services more favourably than those of competitors.
“It is key that personal data and privacy are protected effectively when using apps. Apple is allowed to provide for a level of protection for its users that exceeds the minimum legal requirements,” Mundt said.
“However, if Apple sets up additional rules within its ecosystem for the use of data, these rules must, under Germany’s special abuse provision for large digital companies, not treat its own offerings better than those of its competitors.”
He added, “This is precisely where our competition concerns arose. Apple will now align the consent requests much more closely and give third-party app providers more freedom to combine the necessary requests in a sensible way.”
Regulator Says Goal Is Not More Advertising Consent
The German authority stressed that the changes were not designed to increase the number of users who agree to personalised advertising.
Mundt said the regulator’s objective was instead to ensure that consumers were able to make genuine and informed choices about how their personal data was used.
“It is expressly not our aim to help achieve the highest possible levels of consent to personalised advertising. We want to ensure that users can make a free and informed decision,” he said.
“Users who do not wish to allow their data to be used for personalised advertising must be able to make an equally free and informed decision as users who intend to consent to such data use. The new consent requests are aimed at better enabling users to make this decision.”
The Bundeskartellamt clarified that its investigation was conducted under competition law and was not an attempt to enforce Germany’s data protection rules.
Probe Began in 2022
The proceedings against Apple began in June 2022 after the Bundeskartellamt determined that the company held a position of paramount significance for competition across markets.
That finding was subsequently confirmed by Germany’s Federal Court of Justice in March 2025, strengthening the competition authority’s ability to examine Apple’s conduct under the country’s special rules governing major digital companies.
Apple now has four months from the date it receives the decision to implement the agreed changes.
The commitments will remain in force for seven years and will be overseen by an independent trustee to ensure that Apple complies with the terms.
The German regulator also pointed to similar scrutiny of Apple’s App Tracking Transparency Framework in other European markets.
It said, “competition authorities in France and Italy had previously fined Apple €150m and €98.6m respectively over proceedings concerning its App Tracking Transparency Framework.”
The latest decision adds to growing regulatory pressure on Apple’s digital ecosystem in Europe, particularly around the way the company balances user privacy protections with the competitive interests of third-party developers and advertising businesses.
