Can App Developers Take Payments Off-Platform

What Is App-Store “Steering”?

Steering describes the ability of an app developer to tell users about ways of purchasing products, services or subscriptions outside the platform through which the app was distributed.

That could include directing a customer from an app to the developer's own website to complete a transaction or informing the customer that another payment option is available.

This matters because app-store rules can determine not only how an app reaches customers, but also how developers communicate with them and how transactions are processed.

What Is the CMA Proposing?

On 30 June 2026, the CMA launched separate consultations on proposed steering conduct requirements for Apple's and Google's mobile platforms.

The proposals are intended to allow developers to steer users outside an app, including to complete transactions on fair and reasonable terms.

Apple and Google were both designated as having strategic market status in relation to their mobile platforms in October 2025. That designation enables the CMA to consider targeted conduct requirements under the UK's digital markets competition regime.

Why This Matters Commercially

Steering Does Not Necessarily Mean “No Fees”

It would be too simplistic to treat steering as automatically creating a commission-free route for app developers.

The CMA's proposals expressly consider the terms on which steering should be permitted, including principles intended to ensure that fees charged by Apple and Google in connection with steering are fair and reasonable.

Google has also introduced changes to its Play Store terms concerning steering and developer fees. The CMA has said it will assess the likely effect of those changes on users and businesses as part of its wider mobile-platform work.

The commercial question is therefore not simply whether a developer can link to an external payment route. The economics and contractual conditions attached to doing so may be equally important.

Direct Customer Relationships Could Become More Important

The ability to transact outside an app store can potentially give a developer greater control over the customer relationship.

According to the CMA, where transactions take place outside an app, developers can potentially manage the relationship directly with their customers and choose their own billing provider.

For subscription businesses in particular, that could have consequences for pricing strategy, customer data, renewals, refunds, cancellation, payment processing and customer support.

But greater control can also mean greater responsibility.

A business processing transactions directly must consider the legal architecture supporting that relationship rather than assuming the app store will handle it.

Moving Off-Platform Changes the Legal Architecture

If developers gain greater freedom to sell directly to users, their own contractual and compliance framework becomes increasingly important.

Depending on the product and business model, that can include:

• consumer terms and subscription conditions;
• pricing and renewal disclosures;
• cancellation and refund processes;
• payment-provider agreements;
• privacy notices and data processing arrangements;
• marketing consent and direct customer communications;
• app-store developer terms;
• platform rules governing external links and steering; and
• the allocation of responsibility between the platform, developer and payment provider.

What Should UK App Developers Do Now?

The proposals are still developing, so businesses should avoid redesigning their commercial models on the assumption that a particular final rule will be imposed.

They can, however, begin examining what greater steering freedom would mean commercially.

• Model the economics: compare app-store transactions with potential direct-payment models.
• Review platform agreements: understand the current restrictions and how they affect external purchasing routes.
• Map the customer journey: consider where users would be directed and what information they would receive before purchasing.
• Review direct-sale terms: make sure the business has appropriate consumer and subscription terms if it becomes the direct contracting party.
• Assess payment arrangements: understand the contractual and operational consequences of choosing an independent billing provider.
• Monitor the CMA's final decision: the detail of any eventual conduct requirements will determine the practical opportunity available to developers.

Key Points

• The CMA consulted on proposed steering conduct requirements for both Apple and Google.
• The consultations opened on 30 June and closed on 28 July 2026.
• The proposed rules could give developers greater freedom to direct customers outside apps to complete transactions.
• Greater steering freedom could affect payment-provider choice, platform fees and direct customer relationships.
• Steering does not necessarily mean that all platform-related fees disappear.
• No final steering conduct requirement has yet been imposed under these consultations.