On July 28, 2026, the Japan Association of New Economy (JANE) submitted written responses to two consultations conducted by the UK Competition and Markets Authority (CMA) regarding its draft Steering Conduct Requirements for Apple’s and Google’s mobile platforms.

【Background】
In October 2025, the CMA designated Apple’s and Google’s mobile platforms as having Strategic Market Status (SMS) under the Digital Markets, Competition and Consumers Act (DMCCA). On June 30, 2026, the CMA published its proposed Steering Conduct Requirements (Steering CRs) for Apple’s and Google’s mobile platforms, which would allow developers to ‘steer’ users from within apps to external purchasing and payment options. The proposed Steering CRs also include principles for fees imposed on steering to be “fair and reasonable,” as well as a prohibition on discriminatory treatment of developers who engage in steering.
JANE has consistently advocated for the establishment of a fair competitive environment in the mobile OS and app store markets, drawing on Japan’s experience in enacting the Mobile Software Competition Act (MSCA) and developing its implementing guidelines, as well as on the operation of the EU’s Digital Markets Act (DMA). In these submissions, JANE argues that merely permitting steering in formal terms is insufficient to ensure effectiveness, and calls for modifications and clarifications to specific provisions of the draft requirements, based on the view that fee levels, screen design, reporting obligations, and anti-circumvention measures must be designed as an integrated whole.

【Summary of Comments】
■On the level of Steering Fees- The default should be zero.
Steering Fees charged in connection with Steered Transactions should in principle be zero. Even if some fee is permitted, it should be limited to the direct costs attributable to the services objectively necessary for that transaction, and fees above cost-based levels should not be justified on the basis of “value.” It should also be explicitly stated that all charges related to steering—regardless of name, timing, or basis—are to be assessed in the aggregate.

■On side-by-side display requirements for the designated firm’s app purchase system- Developers should not be required to display the designated firm’s app purchase system side by side with external purchasing options.
Developers should not be prevented from, at their own discretion, displaying the designated firm’s proprietary payment system side by side with external purchasing options. However, designated firms should not be permitted to require developers to display and maintain the firm’s proprietary payment system as a condition for steering.