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<?xml version="1.0" encoding="utf-8"?>
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<html newsdate="2026-04-20">
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<version>1</version>
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<head>
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<title>Apple keeps challenging its interoperability obligations under the DMA</title>
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</head>
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<body>
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<h1>Apple keeps challenging its interoperability obligations under the DMA</h1>
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<p>A new FSFE report exposes how 56 interoperability requests under the
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Digital Markets Act have produced no concrete solutions by Apple, and
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how their declines contradict their own official documentation, leaving
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third-party developers locked out of iOS and iPadOS, despite European
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Commission’s latest specification decision.</p>
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<figure>
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<img src="https://pics.fsfe.org/uploads/original/ee/3d/407431339a047caf4fc5f1ea05db.png" alt="Ilustration showing what looks like a snake in the shape of an apple in black with a red shadow"/>
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<figcaption>CC-BY-SA 4.0. by <a href="https://rahak.net/work.html">Rahak</a> for FSFE.</figcaption>
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</figure>
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<p>The Free Software Foundation Europe (FSFE)’s report <a href="https://download.fsfe.org/campaigns/device-neutrality/FSFE-DMA-AppleReport-v1.pdf">“The
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challenges of regulating interoperability. Analysing Apple’s
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request-based approach under the Digital Markets Act”</a> sheds lights
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on how Apple has been implementing the interoperability obligations
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under the <a href="/activities/dma">Digital Markets Act (DMA)</a>.
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Under the European Commission (EC)'s latest rules, third-party
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developers can formally request access to Apple's platform. This report
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looks at how Apple has handled those requests in practice. The evidence
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of the report is based on public data from Apple’s public tracker,
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implemented as a requirement of the regulatory framework.</p>
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<p>Despite the EC's clear requirements under the Digital Markets Act,
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the FSFE's report finds that, as of 22 March 2026, not one of 56 formal
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interoperability requests has resulted in a solution. Developers
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requesting access to Just-in-Time compilation, NFC protocols, and
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Bluetooth Low Energy Audio, for example, have seen their requests
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denied often because the features in question “fall outside of the
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scope of the law”. Despite the company's own technical documentation,
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which points in the opposite direction. The report
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elaborates on the shortcomings of Apple's request-based approach in
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relation to effective interoperability: Apple’s model requires
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developers to navigate account creation, fees, detailed requests,
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internal review, and potentially long implementation timelines, fearing
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sudden and unreasoned closure of their developer accounts during the
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whole process.</p>
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<p>The report argues that while the regulatory framework issued by the
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EC on interoperability represents a progress, requiring transparency
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and due process obligations from Apple, governance issues, as pointed
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out, will arise in the future. Therefore, the report calls for open
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standards, transparent procedures, and stronger regulatory enforcement
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so that Free Software developers can participate on fairer terms within
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the mobile ecosystem.</p>
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<div> <blockquote>“Despite being legally required by the European
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Commission, Apple continues to obstruct effective interoperability. Out
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of 56 requests, not a single one has resulted in a new interoperability
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solution. Developers are denied access to Just-In-Time-Compilation,
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NFC, or Bluetooth Low Energy Audio with arguments contradicting Apple’s
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own documentation. And there is the constant fear for developers to
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lose their developer accounts. The DMA must be implemented in a
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developer-friendly way, ensuring that legal obligations translate into
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fair and equal access to iOS and iPadOS features.”<cite>Matthias
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Kirschner, FSFE President</cite> </blockquote>
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</div>
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<div>
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<blockquote>“Interoperability only works when it is built into the
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platform from the start. The European Commission’s regulatory framework
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to facilitate interoperability between Apple and competitors is a good
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step forward. Or report sheds lights on the challenges faced by
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software developers under this new framework.”<cite>Lucas Lasota, FSFE
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Legal Programme Manager</cite>
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</blockquote>
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</div>
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<p>You can read the full report <a href="https://download.fsfe.org/campaigns/device-neutrality/FSFE-DMA-AppleReport-v1.pdf">here</a>.
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What follows is a summary of the main findings.
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</p>
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<p class="text-center">
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<fsfe-cd-donate-link class="btn btn-lg btn-primary">
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I want to donate for Device Neutrality!
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</fsfe-cd-donate-link>
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</p>
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<h3>Recap on DMA interoperability</h3>
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<p>Apple is one of the largest tech companies in the world. Due to its
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market power, it is designated in Europe as a gatekeeper under the DMA,
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a law designed to regulate digital competition and open closed
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platforms. Under this legislation, Apple must provide free-of-charge
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interoperability for the features and functionalities controlled by its
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mobile operating systems, iOS and iPadOS. This should allow users to
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install and remove apps freely, use alternative app stores, and enable
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developers to connect their apps to key software and hardware features
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without being blocked.</p>
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<p>Making Article 6(7) of the DMA Free-Software-developer friendly is
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crucial for <a href="/activities/deviceneutrality.index.html">Device
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Neutrality</a>: it obliges gatekeepers to provide effective and free of
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charge interoperability with, and access to, the software and hardware
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features of designated operating systems such as iOS and iPadOS. In
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practical terms, this means that developers must be able to access the
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same operating-system-controlled features that the gatekeeper’s own
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services use, instead of being kept on the outside looking in.</p>
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<p>The DMA represents an opportunity for Free Software developers to
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compete on equal terms with gatekeeper services. Free Software
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developers deserve the right to build genuine alternatives to closed
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ecosystems like iOS and iPadOS, while users gain access to alternative
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app stores, payment systems, and unfettered software installation in
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mobile devices as well.</p>
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<h3>Apple DMA interoperability compliance in practice</h3>
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<p>When the DMA took effect, it expected gatekeepers like Apple to
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deliver interoperability by default: publishing APIs, clear
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documentation, and technical access matching that are equivalent to
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those used for their own services. Instead, Apple created a
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request-based system where each developer must seek permission for
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specific features, waiting for Apple to decide if they are ”in scope”.
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This led the European Commission to launch a specification case (<a href="https://competition-cases.ec.europa.eu/cases/DMA.100204">DMA.100204</a>),
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requiring a fairer process with timelines and a <a href="https://developer.apple.com/file/?file=interoperability-request-tracker">public
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tracker</a> (for access to which an Apple account is required).</p>
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<h3>How a developer must request interoperability to Apple</h3>
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<p>Rather than opening its platform by publishing APIs and
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documentation from the outset, Apple built a request-based system in
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which every developer must apply for access to each feature they
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need.</p>
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<p>The process starts with an Apple developer account, which costs at
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least 99 USD (in Spring 2026), then developers need to fill a detailed
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request describing the feature, the use case, the technical need, and
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possible alternatives to the feature or functionality they are asking
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access for. Apple then performs an initial eligibility check within 20
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working days, after which it may proceed, reject the request, or say
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that an existing solution already covers it.</p>
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<p>If Apple rejects the request, developers can seek internal review
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and, in some cases, conciliation. Even when a request is accepted,
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Apple can still take up to 24 months to implement the result, depending
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on its own assessment of technical complexity. That means the process
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can stretch across months or years before developers see any practical
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benefit, even though the underlying right to interoperability is
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already supposed to exist. </p>
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<figure>
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<img src="https://pics.fsfe.org/uploads/medium/1a/dc/4c74b42d10795f18d78c026f05b0.png" alt="flowchart describing the interoperability process"/>
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<figcaption>
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Timeline proposed by the European Commission to regulate Apple’s
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interoperability requests. Source: European Commission.
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</figcaption>
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</figure>
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<p>The EC’s intervention gave the process a regulatory framework. As
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of March 22, 2026, Apple has received 56 interoperability requests
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under Article 6(7) of the DMA since May 2025, of which 43 have been
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closed, but 27 of those closures are fully confidential. Of the 16
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publicly disclosed closures, none resulted in Apple developing a new
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interoperability solution: 10 were denied on “technical grounds”, 2
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were dismissed by Apple citing “existing solutions”, and 3 were
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rejected as “out of scope or invalid”.</p>
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<figure>
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<img src="https://pics.fsfe.org/uploads/original/33/45/d95b095fc4449143cff112d9af71.jpeg" alt="chart showing the interoperability requests received by Apple under Art. 6(7) DMA until 22.03.2026"/>
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<figcaption>
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Interoperability requests received by Apple under Article 6(7) DMA until 22.03.2026
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</figcaption>
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</figure>
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<figure>
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<img src="https://pics.fsfe.org/uploads/original/4b/6f/b9c393cb5a7a16d9fc787fe91396.jpeg" alt="chart showing the status of the interoperability requests received by Apple under Art. 6(7) DMA until 22.03.2026"/>
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<figcaption>Status of the interoperability requests received by Apple under
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Article 6(7) DMA until 22.03.2026</figcaption>
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</figure>
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<h3>What Apple tracker reveals: four examples of rejected requests</h3>
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<p>Several individual cases illustrate how the process works in
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practice. A Free Software terminal-like app requested access to
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Just-In-Time (JIT) compilation. JIT is already used by Apple’s Safari
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browser to run downloaded code securely in a sandbox. But Apple
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rejected the request from the developer and said JIT for non-browser
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apps was not a feature controlled by iOS.</p>
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<p>Another developer sought access to FIDO tokens in wallet passes and
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the VAS NFC protocol used by Apple Wallet. Apple again denied that
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these were OS-controlled features, despite its own documentation
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requiring a special entitlement for NFC access.</p>
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<p>A third case involved Bluetooth LE Audio for specialised research
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hardware. Apple said the feature was not available to or used by
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Apple’s own hardware or services, even though Bluetooth Low Energy is
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part of iOS and comparable functionality exists on competing platforms.
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Two further requests sought alternatives to Apple’s Push Notification
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Service, including decentralised or user-controlled notification
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servers. But both were rejected on the grounds that APNS is already
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open and persistent connections are simply an OS function.</p>
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<p>These examples show the same pattern: Apple defines the scope
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narrowly enough to preserve its own product design choices, then treats
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those same choices as evidence that interoperability is
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unnecessary.</p>
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<h3>Why does this matter for Free Software developers?</h3>
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<p>The burden of requesting and eventually getting access to
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interoperability rights falls almost entirely on developers. Under
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Apple’s model, they must prove case by case that a feature is “used by
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Apple” before they can gain access, while Apple remains free to reject
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the request based on its own interpretation of the scope. The EC’s
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framework imposes on Apple transparency obligations. For Free Software
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projects, this means technical work becomes entangled with legal
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argument, procedural deadlines, and repeated submissions.</p>
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<p>The mandatory developer fee adds to the problem. Article 6(7)
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requires interoperability to be free of charge, yet Apple still
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requires a paid developer account to submit a request, which creates a
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financial hurdle at the very point where the law is supposed to lower
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barriers. For volunteers, small teams, and independent projects, that
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is not a minor inconvenience; it is a structural filter on who can
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participate from the beginning.</p>
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<h3>What effective interoperability needs</h3>
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<p>In the short term, effective and free interoperability access is
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essential to a developer-friendly enforcement of the DMA. Equal and
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fair access for all developers cannot depend solely on discretionary
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control of gatekeepers.</p>
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<p>Looking further ahead, shared governance is essential. Regulators
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alone cannot ensure that interoperability serves the public interest;
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developers, users, and civil society must have a genuine voice in how
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it is designed, monitored, and enforced. The Free Software tradition,
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built on open standards and community oversight, demonstrates that
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interoperability can be democratically governed as a digital common,
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rather than shaped by bilateral deals between gatekeepers and their
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largest competitors. That is the standard the DMA should be held
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to.</p>
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<h3>Call to action</h3>
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<p>The FSFE is still collecting first-hand accounts from developers who
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have engaged with Apple’s interoperability process under Article 6(7),
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or who were discouraged before they even began. Those experiences help
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document how the process works in practice and provide concrete
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evidence for regulators and enforcement actions.</p>
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<p>If you are a developer who has requested access to software or
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hardware features under Article 6(7) of the DMA, or if you have
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considered doing so but were discouraged by the process, the FSFE wants
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to hear from you. Your experience can help document how
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interoperability works in practice and support better enforcement.</p>
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<div class="color-box background" data-color="android-lime">
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<p>Share your experience: </p>
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<a class="btn btn-default" href="https://survey.fsfe.org/index.php/699938">Start the survey</a>
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</div>
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<h3>Support our work</h3>
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<p>Monitoring gatekeepers, analysing regulatory processes, and
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defending software freedom takes independent resources. Your support
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helps the FSFE continue this work, bring evidence to regulators, and
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push for interoperability by design.</p>
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<p>Please consider making a donation to support the FSFE’s work for
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Free Software, Device Neutrality, and user choice.</p>
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<banner><module id="banner-become-supporter"/></banner>
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</body>
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<sidebar promo="about-fsfe">
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<div class="hidden-xs hidden-sm">
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<h3>Share your DMA experience</h3>
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<p>
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📢 DMA Interoperability Survey - Art. 6(7) and Free Software. <a href="https://survey.fsfe.org/index.php/699938">➡️ Start the survey</a>.
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</p>
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</div>
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</sidebar>
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<tags>
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<tag key="dma">Digital Market Act</tag>
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<tag key="deviceneutrality">Device Neutrality</tag>
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<tag key="european-commission">European Commission</tag>
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<tag key="front-page"/>
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<tag key="highlights">highlights</tag>
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</tags>
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<discussion href="https://mastodon.social/@fsfe/116437188625469739"/>
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<image url="https://pics.fsfe.org/uploads/original/ee/3d/407431339a047caf4fc5f1ea05db.png" alt="Ilustration showing what looks like a snake in the shape of an apple in black with a red shadow"/>
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<translator/>
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</html>
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