Bundeskartellamt forces Apple to overhaul App Tracking Transparency framework
Apple must align consent requests, remove discouraging language and simplify architecture under binding commitments that take effect within four months.
The German Federal Cartel Office (Bundeskartellamt) has declared binding commitments from Apple to modify its App Tracking Transparency Framework (ATTF), concluding a proceeding that found the tech giant’s design of consent prompts violated competition law. The regulator determined that Apple’s previous setup treated its own offerings more favourably than those of third-party app providers, creating an uneven playing field for personalised advertising.
Under the new rules, Apple must align consent requests for its own services with those required for third-party apps, ensuring neutrality in content, wording, and layout. The company is required to remove potentially discouraging symbols and phrasing from predefined requests for external providers. Additionally, app publishers and content providers will be granted greater freedom to combine Apple’s consent requests with data protection law requirements in a manner that is clear to users.
The proceeding was initiated in June 2022 and relied on Section 19a of the German Competition Act (GWB) and Article 102 of the Treaty on the Functioning of the European Union (TFEU). These provisions allow for special abuse control of large digital companies deemed to have paramount significance for competition across markets. Apple was declared to hold this status in April 2023, a decision confirmed by the Federal Court of Justice in March 2025.
Andreas Mundt, President of the Bundeskartellamt, stated that while Apple is permitted to provide privacy protections exceeding minimum legal requirements, it cannot set up additional rules that favour its own ecosystem. The regulator emphasised that the aim is not to maximise consent for personalised advertising, but to ensure users can make free and informed decisions without being steered by biased interface design.
Apple has four months from the service of the decision to implement the changes, a process that will involve testing the new prompts with app publishers beforehand. The commitments are set to apply for seven years and will be overseen by an independent monitoring trustee. The regulator also coordinated with the Federal Commissioner for Data Protection and Freedom of Information to avoid conflicts with data protection laws.
This decision follows similar actions by other European authorities. The French and Italian competition authorities previously imposed fines of 150 million euros and 98.6 million euros, respectively, on Apple in separate proceedings concerning the ATTF. The Bundeskartellamt maintained close dialogue with the European Commission and other EU member states through the European Competition Network to ensure consistent application of competition law.
The commitments address concerns that Apple’s dual role as a platform operator and service provider allowed it to impede third-party app publishers. By simplifying the consent request architecture and allowing publishers to explain the significance of personalised advertising to users, the regulator aims to restore competitive balance in the app economy.
