SMS Investigation into Apple’s mobile ecosystem
The Competition and Markets Authority (CMA) is investigating whether to designate Apple as having strategic market status (SMS) in the provision of mobile ecosystem services including its mobile operating system, native app distribution platform and mobile browser and browser engine.
This investigation runs parallel to the SMS investigation into Google’s mobile ecosystem.
Case information
The CMA has launched an ‘initial SMS investigation’ under Part 1 of the Digital Markets, Competition and Consumers (DMCC) Act 2024.
The CMA is investigating whether to designate Apple as having strategic market status (SMS) in the provision of its mobile ecosystem, including its:
- mobile operating system - which on Apple devices is iOS and iPadOS
- native app distribution – which on Apple devices is through the App Store
- mobile browser and browser engine – which for Apple is Safari and WebKit respectively
(The precise descriptions of the digital activities we are investigating are set out in the Investigation Notice).
Launch of SMS investigation:
- (23.1.25)
- Press release: CMA to investigate Apple and Google’s mobile ecosystems (23.1.25)
Invitation to comment
23 January 2025: To assist with its SMS investigation, the CMA has published an invitation to comment (ITC) setting out the scope of its investigations covering mobile ecosystems, the main avenues of investigation and the potential interventions we are currently considering. We invite submissions from interested parties on these issues as set out in the ITC. We will publish non-confidential responses in due course. If your response contains information that you consider to be confidential, please also submit a non-confidential version of your response for publication.
Responses should be provided following the instructions on the consultation page by 11.59pm on 12 February 2025.
- (23.1.25)
- Link to consultation page: SMS investigations into Apple and Google’s mobile ecosystems
Invitation to comment on consumer survey
23 January 2025: We intend to commission a research agency to conduct a consumer survey as part of this investigation. Interested parties will have an opportunity to comment on the proposed methodology and draft questionnaire.
The invitation to comment on the consumer survey (ITC on Consumer Survey) will be published at 9am on 24 January 2025 and will close at 11.59pm on 28 January 2025.
Indicative timetable
The table below sets out an indicative timetable for the SMS investigation. The dates set out are indicative only and represent our current expectations and estimates for different phases in the investigation and may be subject to change.
The DMCC Act allows the CMA to consult on proposed conduct requirements (CRs) at the same time as consulting on any proposed decision on whether to designate a firm with SMS. CRs may also be imposed at any point after a firm is designated. The CMA may therefore focus on a set of initial potential CRs during the course of the SMS investigation, with further CR work ongoing, should a decision be made to designate Apple with SMS in respect of any of the above activities.
This timetable will be updated as necessary throughout the investigation if there are changes to these timings.
Stage 1: Commencement of the SMS investigation and consideration of potential initial CRs
| Timing | Milestone | Engagement |
|---|---|---|
| 23 January 2025 | SMS investigation launch | |
| 23 January 2025 | SMS investigation notice sent to Apple and published on CMA website | Apple invited to attend introductory meetings with CMA investigation team |
| 23 January 2025 | Invitation to Comment published | Apple and third parties respond to ITC |
| 24 January 2025 | Invitation to Comment on consumer survey published | |
| 28 January 2025 | Invitation to Comment on consumer survey closes | |
| January to March 2025 | Initial evidence gathering and engagement with Apple and third parties in relation to SMS investigation and potential initial Conduct Requirements - this will include the CMA sending information notices and engaging with stakeholders through surveys, calls, meetings and workshops | Apple and other key market participants respond to information notices. Bilateral meetings and roundtables with stakeholders |
| 12 February 2025 | Invitation to Comment closes | |
| Early March 2025 | Publication of non-confidential responses to Invitation to Comment | |
| March to April 2025 | Further engagement with Apple and other key stakeholders in relation to SMS investigation and development of potential initial conduct requirements | Further engagement could include, for example, forums such as roundtables and workshops |
Stage 2: Preparation and publication of proposed decision on whether to designate Apple with SMS and consultation on any proposed initial CRs
| Timing | Milestone | Engagement |
|---|---|---|
| April to May 2025 | Further evidence gathering and analysis | This may include Apple and other key market participants responding to further CMA information notices |
| June 2025 | ’Put back’ process with Apple and other parties on potentially confidential material within proposed decision on SMS designation and consultation on any proposed initial conduct requirements | The CMA will share put back extracts with Apple and third parties for comment |
| Beginning of July 2025 | Consultation on proposed decision on SMS designation and any proposed initial conduct requirements | Apple and third parties respond to consultation on the CMA’s proposed decision |
Stage 3: After proposed decision and consultation
| Timing | Milestone | Engagement |
|---|---|---|
| July 2025 | Opportunity for Apple to make oral representations on proposed decisions on SMS designation | Apple may provide oral representations on the proposed decision to decision makers |
| August to September 2025 | Analysis of responses to consultation on proposed decision on SMS designation and any proposed initial conduct requirements | |
| August to September 2025 | Further evidence gathering and engagement with Apple and other parties, as necessary | The CMA may issue further information notices or arrange further calls and meetings |
| September 2025 | If necessary, put back process with Apple and other parties on potentially confidential material within SMS Decision Notice and any Conduct Requirements Notice | The CMA may share further put back extracts with Apple and third parties for comment |
| 22 October 2025 | Statutory deadline for issue of SMS Decision Notice | |
| Alongside or following any SMS designation | The CMA may issue a Conduct Requirements Notice to Apple, alongside any Interpretative Notes and Compliance Reporting Notice as soon as possible |
Decision makers
The Digital Markets Board Committee (DMBC) oversees and takes certain delegated decisions under the DMCC Act 2024.
Sub-committees of the DMBC have been established under the DMBC to oversee and take certain decisions in specific SMS investigations, in accordance with their terms of reference.
Contact
Please direct all correspondence or questions in relation to this investigation to: mobilesms@cma.gov.uk