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The EU Digital Markets Act (DMA) materially loosened Apple and Google’s grip on iOS and Android billing inside the European Union. For migration, the DMA is net helpful — it widens the lanes the framework already operates in, without requiring the framework itself to change.

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What the DMA changed

Effective March 2024, large platform operators (“gatekeepers” — Apple, Google, others) face additional obligations in the EU:
  • No anti-steering. Apps can communicate with users about alternative subscription options — including in-app — within EU jurisdictions, where previously this was restricted.
  • Alternative billing. Apple and Google must permit third-party billing systems for apps distributed in the EU, with reduced gatekeeper fees on those flows.
  • Sideloading (iOS only). Alternative app distribution outside the App Store, again EU-specific.
For most apps, the DMA’s practical effect on migration is that email outreach to EU subscribers is on even firmer footing than under standard Apple/Google guidelines, and alternative billing options inside the app are now also legal within the EU.

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What the framework does for EU subscribers

The framework’s default posture is policy-conservative: the migration runs entirely outside the app binary in all jurisdictions, including the EU. This is intentional — running one operating model across all geos is cleaner than splitting “DMA inside the app” from “non-DMA outside the app.” If your app is EU-heavy and there’s a meaningful upside to using DMA-permitted in-app communication, that’s a discussion in the Migration Review. The framework can support a hybrid model where EU subscribers see in-app messaging and non-EU subscribers don’t, but the operational complexity has to clear a bar.

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Apple’s Core Technology Fee (CTF) — note

Apple’s response to the DMA included the introduction of a Core Technology Fee for apps distributed via alternative methods or using alternative billing in the EU. The CTF is a per-install fee that can apply on top of (or instead of) the standard Apple commission, depending on configuration. The CTF is structured to make alternative-billing economics complicated for apps with very high download volumes. It does not apply to web-billed subscriptions — only to alternative billing happening inside an app distributed via the App Store. Migration to web is outside the CTF’s scope. If you’re considering both web migration and an in-app DMA-billing path, the CTF tradeoffs are worth modeling explicitly. The framework can help with the calculation.

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What the framework needs from you

Same as elsewhere — coordinate any EU-specific in-app messaging or DMA-billing decisions with the framework before they ship. The framework treats the EU as a regular geo bucket in cohort selection; nothing about the audit changes for EU-heavy apps unless you opt into a hybrid in-app model. Integration overview →