UK designates Apple and Google with Strategic Market Status: what the DMCC means

The UK’s Competition and Markets Authority (CMA) has formally designated Apple and Google as having Strategic Market Status (SMS) under the Digital Markets, Competition and Consumers Act 2024 (DMCC). The move recognizes their entrenched market power in key parts of the mobile ecosystem and allows the CMA to impose targeted rules to keep those markets open and competitive.

What “Strategic Market Status” means

SMS is a legal designation under the DMCC for firms with substantial and entrenched market power and strategic significance in digital markets. It doesn’t allege wrongdoing by itself; instead, it gives the CMA tools to set conduct requirements and, where needed, order pro-competitive interventions.

Scope: where the CMA can act

• App distribution: App stores, discovery and rules for developers.
• Mobile browsers and web tech: Defaults, access and technical constraints that affect competing browsers.
• Payments and in-app transactions: Rules governing payment choice and access terms.
• Default settings and choice screens: How search engines, browsers and other services are pre-set on devices.

Potential obligations (illustrative)

• Fair, reasonable and transparent (FRT) terms for developers and businesses on app stores and payments.
• No self‑preferencing or discriminatory treatment of rival apps and services.
• Interoperability and access to key functionalities or data on proportionate terms.
• More user choice over defaults (e.g., search, browser) with clear, friction‑reduced switching.

Note: The CMA will consult on bespoke conduct requirements for each firm, so the final obligations may differ from the above examples.

Timeline and process

• Designation confirmed: October 2025.
• Next steps: CMA consultations on proposed conduct requirements and any pro‑competitive interventions, followed by implementation windows for compliance.
• Duration: SMS designations are typically time‑limited (e.g., up to five years) and reviewable.

Penalties for non‑compliance

• Under the DMCC, the CMA can issue fines of up to 10% of global turnover for breaches of conduct requirements.
• Additional daily penalties can apply for ongoing non‑compliance.

What could change for users and developers?

• Users: Clearer options to pick and keep preferred defaults; potential improvements in browser choice and app discovery.
• Developers: More predictable rules, potential changes to payment options, and greater transparency around app store policies and ranking.

Context: UK DMCC vs. EU DMA

Like the EU’s Digital Markets Act (DMA), the UK’s DMCC seeks to curb gatekeeper power. A key difference is that the DMCC allows the CMA to apply tailored, firm‑specific remedies rather than a single rulebook for all designated firms.

References and further reading

• CMA cases and announcements
• Coverage: CMA designates Apple and Google (9to5Mac)
• Coverage: SMS designations explained (The Register)

Discussion: What change would you most like to see from Apple’s and Google’s mobile ecosystems in the UK — easier default switching, more browser choice, alternative app stores, or better terms for in‑app payments?