Apple recently updated its developer license agreement, granting the company expanded authority to collect fees and commissions from developers, including the ability to recoup funds directly from in-app purchases. This change impacts developers operating in regions allowing external payment systems and is raising concerns about potential financial uncertainty. The updated terms mark a shift in Apple’s approach to fee enforcement and introduce new regulations concerning user data collection.
Impact of Apple’s Updated Developer Agreement
The revised agreement allows Apple to “offset or recoup” any amounts it believes are owed by developers, encompassing commissions, fees, and taxes. This includes taking funds from payments Apple processes on a developer’s behalf – revenue generated from in-app purchases such as digital goods, services, and subscriptions – potentially leading to unexpected deductions. The company will be able to collect these amounts “at any time” and “from time to time,” meaning there’s no fixed schedule or warning for these adjustments.
This change is particularly relevant for developers in the European Union, the United States, and now Japan, where regulations permit linking to external payment options. These developers are responsible for reporting income from these alternative systems to Apple for commission calculations. A recent U.S. federal appeals court ruling suggested Apple may be able to collect commissions on sales made outside its App Store, though the exact percentage remains a point of legal contention.
Fee Structures and Regional Differences
Apple’s fee structures vary by region and are evolving. Currently, developers in the EU with over 1 million annual installs face the Core Technology Fee (CTF) of €0.50 per install. However, this will transition to the Core Technology Commission (CTC) in January 2026, a percentage-based fee that will apply to apps using external payment methods or operating under alternative business terms. The complexity of these fee arrangements raises questions about how Apple will determine accurate reporting and potential underpayment by developers.
The agreement doesn’t detail the specific methods Apple will use to audit developer payments or verify accuracy, leading to some ambiguity. The lack of transparency around this process is a significant concern for many developers.
Furthermore, Apple reserves the right to pursue unpaid amounts not just from the developer’s main account, but also from any related “affiliates, parents, or subsidiaries.” This allows the company to potentially collect debts from other apps published by the same developer or organization, expanding its reach for enforcement. This broad definition of financial responsibility is another point of concern for larger development groups.
New Regulations on User Data and Voice Assistants
Beyond financial implications, Apple’s updated agreement introduces new guidelines concerning user privacy and data collection. Specifically, the company is tightening restrictions around recordings made by apps, particularly those activated via the iPhone’s side button.
Apple is explicitly prohibiting apps from facilitating recordings of users without their explicit awareness. While the company is not entirely banning recordings, it is requiring clear notification and consent mechanisms. This focuses on audio and video recordings, as well as screen recordings, which developers often use for bug reporting and usability testing. The new rules are a direct response to concerns regarding surreptitious data gathering.
These regulations intersect with the growing adoption of AI-powered voice assistants and chatbots within mobile applications. The updated agreement suggests Apple is seeking to ensure that these features adhere to strict privacy standards. Developers integrating such technology will need to carefully review and comply with the new requirements to avoid potential violations. Alternative business models and app distribution are also seeing increasing scrutiny by regulatory bodies, adding to the complexity of navigating App Store policies.
This update comes as Apple faces increasing pressure from governments and competitors regarding its App Store practices. The debate around developer fees and fair competition continues globally. The company has made some concessions to address antitrust concerns, such as allowing developers more flexibility in communicating directly with customers about off-App Store purchasing options, but these changes haven’t entirely alleviated criticism. The ongoing legal battles regarding platform commissions in the US will likely influence Apple’s future policies.
Looking ahead, developers will be closely monitoring how Apple interprets and enforces these new terms. The absence of specific calculation methodologies for fees like the CTC leaves room for ambiguity and potential disputes. The next key date to watch is January 2026, when the new Core Technology Commission takes effect in the EU, potentially leading to a significant shift in the financial landscape for developers operating in that region. It remains to be seen whether further clarifications will be provided by Apple regarding the application of these updated policies.

