On April 22, 2026, the Japan Association of New Economy (JANE) submitted a written response to the Call for Evidence conducted by the UK Competition and Markets Authority (CMA) regarding recent changes to app store rules.

【Background】
The CMA is currently examining the future direction of steering measures in the UK — that is, the ability of developers to direct users from within apps to external transaction channels— in light of international developments surrounding Apple’s and Google’s app store rules. JANE has consistently advocated for the establishment of a fair competitive environment in the mobile OS and app store markets, as well as the early introduction of effective rules. In this submission, JANE calls on the UK Government to design an effective regulatory framework, drawing on precedents from Japan and the EU.

【Summary of Comments】
■On the level of fees imposed on steered transactions
Any fees imposed on steering to external payment options should be justified only to the extent that they strictly correspond to the services actually provided by the app store operator in relation to those payment transactions. As demonstrated by cases under Japan’s Mobile Software Competition Act (MSCA) and the EU’s Digital Markets Act (DMA), multi-layered fee structures that merely change their names undermine the economic benefit of using external payment options. In the United Kingdom as well, the appropriateness of fees should be assessed not on the basis of their name or formal structure, but on whether they materially impede the use of alternative payment channels.

■On the design of the user journey for steered transactions
The effectiveness of steering to external payment options depends as much — if not more — on the design of the user interface and navigation flow leading to external payment, as it does on the level of fees. Requiring the simultaneous display of external links alongside the platform’s own payment option, or repeatedly presenting warning screens that excessively emphasize potential risks, can function as a substantive restriction on competition. A design is required that allows app developers to direct users to external options through a variety of means, and that enables users to access external payment options seamlessly.

■On responses to privacy and security risks
Where restrictive measures are taken on the grounds of protecting privacy or ensuring security, platforms should be required to provide specific and verifiable evidence. A clear distinction must be drawn between genuinely necessary safeguards and friction designed primarily to protect the platform’s own commercial interests, and any countermeasures should be limited to the minimum necessary and proportionate to the specific level of risk involved.

■On the relationship with broader app store regulatory reform
Broader structural reforms – such as the introduction of alternative app stores or the permission of sideloading — do not, at the present time, substitute for the need for a steering intervention. As demonstrated by precedents in other countries, it is important for the United Kingdom to build its own robust and effective regulatory framework that goes beyond the mere formal establishment of rules and addresses loopholes and circumvention strategies.

※ For the CMA’s Call for Evidence, please see here.
※ For the full text of the JANE’s submitted response, please see here.