Which regulatory agencies enforce this type of clause?

{'agency': 'FTC', 'reason': "The mandatory IAP requirement and anti-steering prohibition implicate FTC Act Section 5 unfair competition authority and are subject to ongoing FTC scrutiny of Apple's App Store practices.", 'complaint_url': 'https://reportfraud.ftc.gov/'}, {'agency': 'State_AG', 'reason': 'State AGs, particularly California (UCL/Cartwright Act), have jurisdiction over anti-competitive pricing and anti-steering practices affecting consumers in their states.', 'complaint_url': 'https://www.naag.org/find-my-ag/'}

What is the severity of this clause?

ConductAtlas classifies this Mandatory In-App Purchase Requirement clause as high severity. Severity reflects the magnitude of rights affected, the breadth of users impacted, and the degree of discretion the platform retains.

Mandatory In-App Purchase Requirement — Apple

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What it is

If an app sells digital content — like subscriptions, games, or extra features — it must use Apple's own payment system, and cannot send you to a cheaper website to buy the same thing.

Consumer impact (what this means for users)

This provision means consumers may pay more for digital subscriptions and in-app purchases because Apple's 30% commission is typically built into the price; it also prevents developers from showing you a cheaper external price.

Cross-platform context

See how other platforms handle Mandatory In-App Purchase Requirement and similar clauses.

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Why it matters (compliance & risk perspective)

Apple takes up to 30% of every digital purchase made through its payment system, a cost developers often pass on to consumers through higher prices.

View original clause language

Apps may not use their own mechanisms to unlock content or functionality, such as license keys, augmented reality markers, QR codes, cryptocurrencies and cryptocurrency wallets, and so on. Apps and their metadata may not include buttons, external links, or other calls to action that direct customers to purchasing mechanisms other than in-app purchase.

Institutional analysis (Compliance & legal intelligence)

(1) REGULATORY FRAMEWORK: This provision directly implicates the EU Digital Markets Act (DMA, Regulation (EU) 2022/1925, Arts. 5(7) and 6(12)), which requires Apple as a gatekeeper to allow third-party payment processors and prohibits anti-steering obligations in the EU. It also engages FTC Act Section 5 (15 U.S.C. §45) regarding unfair methods of competition, and is at the center of DOJ v. Apple Inc. (D.N.J. 2024) antitrust proceedings. In the US, Epic Games v. Apple (9th Cir. 2023) addressed anti-steering specifically. Enforcement authorities include the European Commission (DG COMP), DOJ Antitrust Division, FTC, and state AGs. (2)

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Applicable agencies

FTC

The mandatory IAP requirement and anti-steering prohibition implicate FTC Act Section 5 unfair competition authority and are subject to ongoing FTC scrutiny of Apple's App Store practices.
File a complaint →
State AG

State AGs, particularly California (UCL/Cartwright Act), have jurisdiction over anti-competitive pricing and anti-steering practices affecting consumers in their states.
File a complaint →

Provision details

Document information

Document

Apple App Store Review Guidelines

Entity

Apple

Document last updated

March 24, 2026

Tracking information

First tracked

April 28, 2026

Last verified

April 28, 2026

Record ID

CA-P-003882

Document ID

CA-D-00025

Evidence Provenance

Source URL

https://developer.apple.com/app-store/review/guidelines/

Wayback Machine

View archived versions →

SHA-256

307db15d06f03003277f88a1476a1308e92cc7cba75906b4fac341d1054f5040

Verified

✓ Snapshot stored ✓ Change verified

How to Cite

ConductAtlas Policy Archive
Entity: Apple | Document: Apple App Store Review Guidelines | Record: CA-P-003882
Captured: 2026-04-28 08:36:55 UTC | SHA-256: 307db15d06f03003…
URL: https://conductatlas.com/platform/apple/apple-app-store-review-guidelines/mandatory-in-app-purchase-requirement/
Accessed: April 29, 2026

Classification

Severity

High

Mandatory In-App Purchase Requirement