Apple/EU DMA Compliance Workshop whisper-generated transcript July 1 2025

apple_eu_dma_compliance_workshop_2026_whisper_transcript.txt

- Good morning.
*00:00-00:02*

We are starting sharp at 9.30.
*00:02-00:06*

So let's try to keep it like that the whole day.
*00:06-00:09*

My name is Lucia Boneva, I'm a head of unit in DG Comp, leading team responsible for the implementation of the DMA.
*00:09-00:17*

I will be today the moderator.
*00:17-00:19*

And I propose we start with some introductory remarks by Rita Wesenbeck, who is the director.
*00:19-00:26*

And then we will take you through the day.
*00:26-00:28*

So welcome in the room, welcome online.
*00:28-00:31*

Can you hear us online?
*00:31-00:33*

Can someone check that actually?
*00:33-00:36*

Whether we are being heard, maybe colleagues of people in the room, no one is texting, we don't hear anything.
*00:36-00:42*

Ah, Victor is saying they can hear us online, fantastic.
*00:42-00:47*

So welcome and I hand over to Rita Wesenbeck.
*00:47-00:50*

- Yes, good morning to everybody on this very warm day.
*00:50-00:55*

I think we will have a very warm getting together today also.
*00:55-00:59*

So indeed, very good to see you.
*00:59-01:02*

Also good to see you online and to see you on time in our DMA Compliance Workshop.
*01:02-01:09*

And as you know, today's edition is with Apple.
*01:09-01:12*

So after the positive experience we had last year, we are very glad to host this second edition, looking at how the first year of DMA Compliance went.
*01:12-01:23*

So the focus of this year, and you've heard it also if you attended the other workshops already, the focus is slightly different.
*01:23-01:29*

We are interested not only in the compliance solutions themselves, but also in the developments that have been observed this year, both from the gatekeepers and also from the participating third parties.
*01:29-01:41*

So many thanks for Apple.
*01:41-01:43*

I see on my right hand, Kyle Endier and Gary Davis, who have become celebrities by now, I think.
*01:43-01:49*

And they will-- - The definition of celebrity has changed.
*01:49-01:53*

(laughing)
*01:53-01:54*

- But they will definitely introduce their teams.
*01:54-01:57*

So they're very welcome to come today and explain and discuss the various updates on their DMA Compliance solutions, also focusing on the first experience with the solutions.
*01:57-02:08*

So many thanks as well to all of you interested parties in the room and online.
*02:08-02:14*

Your views have proven to be and continue to be crucial to inform our assessment on whether gatekeepers compliance is effective.
*02:14-02:24*

So indeed, in addition to the many attendees that are here in the room today, we have approximately 230 participants registered online.
*02:24-02:33*

And that reflects a continuous interest.
*02:33-02:36*

We look forward to having a constructive discussion and also to your valuable feedback.
*02:36-02:42*

So as a general scene setter, this is the second year that we are holding the DMA Compliance workshops.
*02:42-02:48*

Apple submitted their updated compliance report and audited report of consumer profiling techniques on the 7th of March.
*02:48-02:56*

A public version of those reports can be accessed through the commission's website.
*02:56-03:00*

And if it's okay, yes, indeed, the slide is on screen.
*03:00-03:04*

So one year and a half on, it's now time to look more closely at the compliance measures that have been adopted since the first compliance reports.
*03:04-03:13*

And as I said, this year, we have asked all the gatekeepers to focus on the changes they made in order to improve their compliance solutions, as reflected in their last compliance report, and also on the effects and take up of the compliance solutions.
*03:13-03:28*

We also asked them to present some of their new services in the fast developing field of AI, and how they intend to ensure compliance of those solutions with the DMA.
*03:28-03:38*

So the objective today is to understand better Apple's compliance measures and to enable you as third parties and beneficiaries of the obligations to ask questions or clarifications and provide feedback.
*03:38-03:52*

We think it's important to have a transparent, constructive and inclusive dialogue.
*03:52-03:58*

This is why we wanted to organize this second edition, in particular, since all of you considered it a very useful means to learn about compliance solutions in detail and provide your feedback and views.
*03:58-04:09*

So these workshops are important, but they will not substitute the continuous and all inclusive dialogue that we are having with both gatekeepers and third parties.
*04:09-04:20*

We encourage all gatekeepers to keep seeking feedback, providing explanations to clarification queries, and also to engage with third parties also when the commission is not in the room.
*04:20-04:32*

Likewise, we also encourage third parties to also reach out to the commission if they want to share some feedback or experience with no gatekeeper in the room.
*04:32-04:41*

So we want to achieve compliance with the spirit of the DMA, not just the letter.
*04:42-04:49*

This means that compliance solutions need to be effective and deliver fair opportunities for business users and choices for end users to make sure the digital markets become fairer and more contestable.
*04:49-05:01*

So I now give the floor to Lucia Brnova, who will moderate today's workshop.
*05:01-05:06*

There are many other colleagues who have been working on ensuring the effectiveness of the DMA, and they will present also our ongoing work throughout the day.
*05:06-05:16*

Lucia will now present the workshop agenda, and very importantly, the rules of engagement, and provide a bit more detail on the regulatory dialogue we had over the past year with Apple.
*05:16-05:28*

So take care of yourself on this warm day, drink enough, and with that, I wish you all a productive and fruitful workshop.
*05:28-05:35*

Over to Lucia.
*05:35-05:36*

- Thank you, Rita.
*05:36-05:39*

So before I kick off, I would like to maybe ask Gary and Kyle to briefly introduce themselves so you don't get introduced only in half an hour, a little bit, to tell us what's your role in fitting Apple in the context of the compliance.
*05:39-05:53*

- Sure thing.
*05:53-05:57*

Why don't I lead off?
*05:57-05:58*

Good morning, everyone.
*05:58-05:59*

My name is Kyle Landier.
*05:59-06:01*

I'm vice president of products and regulatory law at Apple.
*06:01-06:05*

I'll allow Gary to introduce himself in a moment, but I have some other colleagues as well.
*06:05-06:09*

Nina Schmidt, who leads up our compliance efforts here in Europe and plays a key role in our DMA compliance team.
*06:09-06:18*

Suzanne Garrity, who leads our legal efforts supporting businesses like the App Store, Apple Pay, iCloud, and a number of other services at Apple.
*06:18-06:29*

And then finally, Rocio, who is on Gary's team working on DMA issues, and so we're really pleased they could join us today.
*06:29-06:37*

Gary, you wanna try and introduce yourself?
*06:37-06:39*

- How long do I have, actually?
*06:39-06:41*

Gary Davis, as Kyle said, I'm a senior director on our legal team here in Europe.
*06:41-06:48*

I was, prior to this role, responsible for Apple's implementation of the GDPR and see some familiar faces where I worked closely with on those issues, and looking forward to talking to you all today.
*06:48-06:59*

- Excellent, thank you very much.
*06:59-07:02*

So with that, maybe we can start presenting the agenda for the day.
*07:02-07:06*

So we will see on the slide a little bit how the day will be run.
*07:06-07:10*

This agenda was made public, so normally should be no surprise.
*07:10-07:13*

But nevertheless, I will repeat that today is divided into four sections, which is aimed to discuss compliance solutions in the morning in relation to Article 6.7, so interoperability, then we will have a coffee break, then we'll be discussing App Store, so 5.4 steering, and then we will have a lunch, and after that, in the afternoon, we will look into 6.3, so the browser choice screens and the choice architecture, and finally, we'll finish the day after the second coffee break, discussing the data portability obligation 6.9, 6.10.
*07:13-07:56*

So we aim to finish at half past four.
*07:56-07:59*

We will try to be disciplined.
*07:59-08:01*

As you can see, every session is structured in the same way.
*08:01-08:05*

The Commission will introduce the obligation and also the dialogue that's been taking place in relation to the topic of the session.
*08:05-08:15*

Then Apple will be given the floor to present their compliance efforts, and then we will have a Q&A and discussion within the topic of the session.
*08:15-08:27*

There is people in the rooms.
*08:27-08:28*

We'll be taking questions from the room, but there are also, I think I heard now, actually it's more close to 500 people online.
*08:28-08:35*

We will also be taking questions from online participants through a slide-on.
*08:35-08:41*

I think it's important to recall a little bit the rules of engagement, how we would like to run it today.
*08:41-08:49*

So for those who attended the workshop last year, you know that there are two things we do not discuss here.
*08:49-08:56*

One is the past antitrust cases or other proceedings, and the other thing we will not be discussing today are any open cases.
*08:56-09:05*

So there are some cases which have been concluded, but there are still some cases which are ongoing, and you will certainly understand that for the integrity of these investigations, we will not discuss those topics.
*09:05-09:18*

I hope I don't need to recall that we should all keep very polite and civilized.
*09:18-09:27*

Sometimes the room can get hot, as Rita said, so my job will be to calm the game, but I know since last year that, I think I can count on you, that everything will go in a very constructive manner.
*09:27-09:44*

So, one thing is different from last year is that we have concluded some proceedings.
*09:44-09:55*

So in those cases, the commission will present those decisions.
*09:55-10:00*

Those decisions in all cases are made public, so you might have seen them, but we will present a little bit of the findings in the decision and the content.
*10:00-10:11*

The idea is really to present it, so to provide kind of the background for the discussion.
*10:11-10:17*

So there is no, I have no intention to debate the decisions, who was right, who was wrong, what was written, et cetera.
*10:17-10:24*

The decisions are available.
*10:24-10:25*

If you have questions to us, you can always address them to our ECDMA website.
*10:25-10:31*

If you have questions to Apple, which will not be able to be covered today, I'm pretty sure that Apple is always available to interact with you also in the other forum.
*10:31-10:42*

So the idea is really today to collect stakeholder feedback and really discuss the concrete compliance solutions.
*10:42-10:53*

The questions today should be DMA specific.
*10:53-10:56*

So please, if you have any other queries about other issues and proceedings in the US and I don't know what not, please maybe channel this through different channels.
*10:56-11:08*

So today really what we are discussing is compliance with the DMA.
*11:08-11:13*

Okay, so I mentioned the Slido.
*11:13-11:18*

Yes, when we'll be taking the questions from the room, please state your name, the organization you represent, and any affiliation you may have in particular with gatekeepers.
*11:18-11:30*

That can be Apple itself, but also others.
*11:30-11:33*

So I think that it's important there is a full transparency as to which interests who represents.
*11:33-11:38*

So now maybe we can kickstart the first session, which is called Introduction and Interoperability.
*11:38-11:47*

I will give a couple of words of interaction, a little bit on the whole regulatory dialogue, and then I will be handing over to the colleagues to start the sessions themselves.
*11:47-11:58*

In this case for interoperability, it will be my colleague Kaya on my left-hand side.
*11:58-12:02*

So here, just a quick timeline, a little bit.
*12:02-12:08*

I don't think I need to go into details.
*12:08-12:10*

As you know, that Apple was designated as gatekeeper for a number of its services.
*12:10-12:17*

We have operating system iOS, online intermediation service, browser engine Safari, online intermediation service App Store, obviously, and then browser Safari.
*12:17-12:27*

Then later on, Apple was designated for operating system iPadOS.
*12:27-12:33*

There was, as you know, per DMA, Apple and other gatekeepers have to submit compliance reports.
*12:33-12:40*

So first compliance report was submitted on 7 March, 2024.
*12:40-12:44*

Second one was submitted on 7 March, 2025.
*12:44-12:48*

Both of them are available online, as Rita already mentioned.
*12:48-12:51*

So we've been in a continuous dialogue with Apple in relation to all the obligations which are relevant for the core platform services for which Apple has been designated.
*12:51-13:07*

So I will say that there are some cases which hit the headlines, but I think the main instrument of the DMA is regulatory dialogue.
*13:07-13:18*

So just stay assured, there's hours and hours and hours and hours of meetings with Apple.
*13:18-13:24*

Gary is smiling because he knows what I'm talking about.
*13:24-13:27*

So there's lots of work ongoing.
*13:27-13:30*

Not everything, obviously, is on the headlines because typically people like sensations.
*13:30-13:36*

So what hits the headlines are the proceedings, more formal proceedings.
*13:36-13:40*

So we have concluded three proceedings in relation to Apple.
*13:40-13:43*

You see them in the kind of mustard color online.
*13:43-13:47*

I know these are not, I don't know what's the color code there, but no, the mustard color is those that we'll be discussing today, but there's a kind of large overlap.
*13:47-13:54*

So what we've done is, what we concluded proceedings in relation to app stores and the five force or the steering case.
*13:54-14:00*

We have concluded two specification decisions where we are assisting Apple in relation to their interoperability obligations in relation to the process and connected devices.
*14:00-14:12*

Kaya will be presenting them in a minute.
*14:12-14:14*

And we have concluded proceedings which we opened in relation to the choice architecture and those proceedings were concluded without finding non-compliance.
*14:14-14:24*

So we have one non-compliance, one finding of not finding non-compliance, and two specification proceedings.
*14:24-14:33*

So again, a lot happens behind the scenes.
*14:33-14:40*

I will also say that we have regular interactions with third parties, also in the context of proceedings, but also in the context of regulatory dialogue.
*14:40-14:50*

We are always open to engage with whoever is interested via submission or email.
*14:50-14:57*

We always follow through.
*14:57-14:59*

We also actually respond to citizens.
*14:59-15:03*

We get over 1,000 citizen requests per year in relation to compliance with the DMA.
*15:03-15:12*

So just to underline that we are always here and if anyone feels that they have something to say, please do not hesitate.
*15:12-15:21*

The email address will be put up throughout the workshop, throughout the day several times.
*15:21-15:29*

So with this in mind, I would like to hand over to Kaya Schmidt, who is my colleague and who will present the first session on interoperability.
*15:29-15:39*

So enjoy the day.
*15:39-15:40*

- Thanks a lot, Lucia.
*15:40-15:44*

So I'll kick it off right away with Article 6.7 and interoperability.
*15:44-15:48*

And would like to first explain a little bit what the obligation is about.
*15:48-15:52*

So in essence, Article 6.7 ensures effective access for third parties to interoperate with designated operating systems under the same conditions that gatekeepers apply to their own services.
*15:52-16:02*

Now that's quite wordy.
*16:02-16:03*

So on the right hand side, you see a visualization.
*16:03-16:08*

So basically in gray, you'll see that Article 6.7, if there's an Apple service or hardware, such as the Apple Watch, that is able to access an operating system feature of iOS or iPadOS, so Apple designated operating systems, then Article 6.7 says, that's what you see in yellow, that third party services and hardware, such as a third party app or a third party smartwatch should have access to that same operating system feature in a way that is equally effective and free of charge.
*16:08-16:37*

Now, none of this precludes Apple from having integrity measures and implementing integrity measures as long as they're strictly necessary and proportionate.
*16:37-16:47*

And basically the purpose of Article 6.7 is to create a level playing field on operating systems and to create innovation opportunities for smaller businesses and smaller companies and also thereby incentivize gatekeepers to innovate through the increased competitive pressure.
*16:47-17:05*

So as Lucia briefly mentioned, we concluded two specification proceedings in March and today's presentation from me is about these two cases, but that of course doesn't preclude that the regulatory dialogue with Apple goes beyond these two cases and Article 6.7 compliance also goes beyond these two cases.
*17:05-17:24*

So let's look into the first one.
*17:24-17:28*

The first case is about connected devices and basically how connected devices can interoperate with iOS.
*17:28-17:36*

And the specification decision that we adopted in March specifies kind of two main things.
*17:36-17:41*

The first one are individual measures for nine features that are available to Apple already today.
*17:41-17:46*

So these are things like the Apple Watch having access to iOS notifications or connected devices having access to peer-to-peer Wi-Fi between iOS and Apple's connected devices.
*17:46-17:58*

And so we specify that individual measures for these nine features and then we also have general measures that are applicable to all of these nine features that ensure that third parties and Apple can operate on a level playing field.
*17:58-18:11*

And these general measures are things like interoperability solution has to be available for any use case, so it has to be use case agnostic, it should be equally effective interoperability and so on.
*18:11-18:23*

So we have a number of general measures here.
*18:23-18:26*

And in terms of timeline, Apple has to implement part of these individual measures by the end of 2025, some by the end of 2026, but it depends a bit on a feature per feature basis.
*18:26-18:38*

Now I would like to make a point about the way we designed our measures that we presented.
*18:38-18:47*

The first part is that the features and measures that we selected, as I mentioned, are limited to what is available to Apple already today.
*18:47-18:54*

And they're also interoperable on other operating systems.
*18:54-18:57*

And again, when we designed these measures, the primary factor was user safety.
*18:57-19:02*

And we ensured that by engaging with Apple, with third parties, with internal and external security experts to really discuss that.
*19:02-19:09*

And the measures that we specify in our decision also come with privacy and security safeguards.
*19:09-19:14*

So a typical measure that we will have is specifying something that Apple also employs for a lot of its own services and its own ecosystem.
*19:14-19:23*

It's for example, having user permission to grant apps access to sensitive data.
*19:23-19:28*

You see that a little bit on the, if you can read that.
*19:28-19:30*

On the right hand side, it's for example, for a messaging app, you can grant whether you want to have limited access or want to give full access to sensitive data, in this case, photos.
*19:30-19:40*

And the same applies to contacts or location.
*19:40-19:44*

So our measures accommodate for these kind of permission, user permissions as well.
*19:44-19:49*

And in general, Apple can apply safety measures provided that these are based on transparent, objective, precise, and non-discriminatory criteria, and that they equally apply both to Apple and to third parties.
*19:49-20:02*

So let's look at what that is an example.
*20:02-20:05*

So I brought two features today that we specified in our decision.
*20:05-20:10*

The first one is automatic Wi-Fi.
*20:10-20:12*

So the automatic Wi-Fi feature is that today, Apple can automatically connect to Wi-Fi networks that the iPhone is connected to.
*20:12-20:19*

And our specification decision says that third parties should have access to that same network data to offer that exact same feature that Apple is able to provide.
*20:19-20:29*

And the decision also clarifies that Apple can seek user permission to share that kind of sensitive data with a third party connected device.
*20:29-20:37*

So again, it's this user safety mechanism that Apple also uses in its own ecosystem.
*20:37-20:44*

The second set of, or the second example I'm bringing today are iOS notifications.
*20:44-20:49*

The iOS notification feature is basically that a connected device like the Apple Watch can receive notifications from the iOS operating system.
*20:49-20:59*

And actually, iOS or Apple can process iOS notifications on the iPhone before sending those to the Apple Watch.
*20:59-21:06*

For example, to resize an image that was sent in a message to fit the display of the connected device or of the smartwatch.
*21:06-21:14*

And our measures say also that third parties should be able to do that.
*21:14-21:18*

They should be able to access and process these notifications on the iPhone, just as Apple does, in order to offer the same features that Apple is able to feature, to offer on its connected devices.
*21:18-21:31*

And again, in terms of user safety here, we have on the one hand that Apple can seek this user permission and let the user decide which sensitive data to share.
*21:31-21:39*

So it's the same kind of measure that I explained for automatic wifi.
*21:39-21:45*

But also Apple can require third parties to encrypt notifications and not to break any end-to-end encryption, but really to ensure that messages remain end-to-end decrypted, which is also what Apple does in its ecosystem.
*21:45-22:01*

So that's it for connected devices.
*22:01-22:04*

I'll briefly also touch on our second specification case, which is about the interoperability process.
*22:04-22:10*

The interoperability process is how third parties can request interoperability under Article 6.7 with Apple.
*22:10-22:18*

And initially, Apple in its Article 6.7 compliance introduced a request-based process, through which third parties could request access to interoperability with iOS and iPadOS on a request basis.
*22:18-22:34*

And so our specification decision makes sure that this request-based process is fair, predictable, and timely, and is based on specific principles and safeguards to ensure that.
*22:34-22:47*

Part of that is to increase transparency.
*22:47-22:49*

So how does the process work?
*22:49-22:50*

What features could be requested?
*22:50-22:52*

How long can developers wait?
*22:52-22:55*

So below here, you see a little bit the timeline of how long developers can expect to wait for an eligibility check, which is 20 days.
*22:55-23:03*

Then we also introduced, or want that the requests are handled fairly.
*23:03-23:09*

So there's also a mechanism, if a request gets refused, there's a mechanism to also address those, like a dispute resolution mechanism that we also introduced.
*23:09-23:22*

And overall, we want to deliver effective and future-proof interoperability solutions through this fair, predictable, and timely interoperability process.
*23:22-23:32*

So with that, I would actually invite third parties in general to provide feedback both on these two specification decisions that I presented.
*23:32-23:43*

Here also, for example, for this interoperability process, we would like to have your feedback on new updated APIs or the updated portal and the new tracker features.
*23:43-23:54*

But yes, we welcome any feedback also on the features and how Apple is implementing its interoperability solutions under these two specification decisions.
*23:54-24:02*

But also beyond that, also for Article 6.7 in general, we of course welcome your feedback.
*24:02-24:07*

And with that, I would like to hand to Apple.
*24:07-24:10*

- Thank you, Kaya.
*24:11-24:12*

So now it's for Apple to present their solution in relation to 6.7.
*24:12-24:18*

Do you have slides?
*24:18-24:19*

- All right, good morning again, everyone.
*24:19-24:28*

So I thought what I would do this morning is I'm gonna start by sharing a few observations about our philosophy when it comes to DMA compliance.
*24:28-24:38*

And then Gary and I will dig into our approach to interoperability.
*24:38-24:42*

I think it's fair to say that when we all come to this workshop, we come with different perspectives.
*24:42-24:48*

We come with different perspectives on the impact of the changes being wrought by certain aspects of the DMA on users, developers, and the market.
*24:48-24:57*

That's true of us in the commission on some issues.
*24:57-25:01*

That said, we have also found ways to work together, even when we do not agree on the law or its interpretation.
*25:01-25:07*

As I'm sure most of you know, Apple announced a number of changes last Thursday, which we'll talk about in detail later this morning.
*25:07-25:15*

I am hopeful that our work with the commission over the last two months will allow us to close the chapter on our compliance with Article 5.4.
*25:15-25:23*

And I'm also optimistic that those changes have us well on our way to turning the page on Article 6.4.
*25:23-25:29*

The announcements last week are a good example of constructive engagement to resolve matters.
*25:29-25:36*

We took the commission's specific guidance and direction, and we implemented it, working closely with their team over the last two months.
*25:36-25:44*

In this, I think Apple has demonstrated that we are willing to engage side-by-side with the commission on key issues.
*25:44-25:52*

With this in mind, I want to be crystal clear as we dive into the specifics of various articles today.
*25:52-25:59*

True to Apple's values, what we care about most is the ability to innovate and deliver trusted, excellent, easy-to-use design to our users, which is why we care so deeply in particular about the intrusive interoperability mandates we'll discuss in this session.
*25:59-26:18*

That means while we're gonna talk about new choices, we're also going to point out where we have concerns about the impact of the changes we have had to make on users, developers, competition, and Apple itself.
*26:18-26:31*

So yes, you're gonna hear about privacy and security and innovation and competition.
*26:31-26:38*

We talk about these things because they are important, and we say them here not to be trite, but because we are actually worried about what is happening to them, and that is worth saying and saying and saying many times if necessary, and I make no apologies for that.
*26:38-26:53*

So let's turn to how we've thought about DMA compliance more broadly.
*26:53-26:58*

I want to share our perspective on this journey since the law was passed and we began our preparations for compliance.
*26:58-27:05*

Our starting point was ensuring that we live up to our obligations under the law while remaining relentlessly focused on our users and delivering a great platform that's safe and secure for both users and developers.
*27:05-27:18*

Some have suggested that compliance with the DMA is simple, clear, and obvious, as if the answers are all there in the text.
*27:18-27:28*

That is not the reality.
*27:28-27:30*

No two people agree on what the DMA's substantive obligations mean.
*27:30-27:34*

That has made compliance incredibly difficult.
*27:34-27:38*

More so than with other laws, there is a lot of room for interpretation, and there are few objective standards when it comes to Article V and VI.
*27:38-27:48*

Everyone in this room comes to it with a different perspective, much of it based on self-interest, from developers to competitors to other gatekeepers, and we have seen the words take on different meanings, and some provisions apply differently to different gatekeepers.
*27:48-28:05*

Apple creates products in a way few others do, and we are proud of that.
*28:05-28:11*

It would be a shame if, despite the best intentions of the Commission, the DMA becomes a tool to undermine what makes Apple unique, but I worry that's exactly the path we're on.
*28:11-28:22*

To turn each regulated entity into a carbon copy of one another with no ability to differentiate, taking away choice from European consumers and making business difficult for developers.
*28:22-28:35*

That's never been what Apple is about, and as I understand it, it's not what was intended by the DMA, nor what is intended by the Commission.
*28:35-28:43*

Our approach to compliance has been deliberate and transparent.
*28:43-28:48*

We were the only gatekeeper to announce a comprehensive plan for compliance well before the DMA came into effect, and we have made changes to that plan since then.
*28:48-28:58*

At each step, our plan has as much as possible maintained the fundamental integrity of the experience that our customers expect from us.
*28:58-29:08*

Those expectations include the seamless integration of hardware, software, and services, a commitment to maintain user security, privacy, and safety as much as the law will allow, and a great platform on which developers can continue to thrive.
*29:08-29:24*

And of course, making something that stays easy for everyone, from my children to my parents, to use right out of the box.
*29:24-29:32*

For us, the biggest challenge was, and remains, how to maintain that experience while also ensuring compliance, which has necessarily forced us to change many things that were working well for our users.
*29:32-29:44*

We also thought a lot about the impact of compliance on developers.
*29:44-29:49*

It bears keeping in mind that we are not just focused on three or four developers when it comes to compliance.
*29:49-29:55*

No, our focus is not on just the billion dollar companies, but also the millions of developers today and to come in the future.
*29:55-30:04*

Apple's compliance solutions affect not only those millions of developers currently creating apps with our technologies and services, but also all the future developers with great ideas still to come.
*30:04-30:14*

We deeply value the relationships with developers we've built over several decades.
*30:14-30:21*

Part of the reason why so many developers from all over the world have been able to succeed on our platform is because of the trust we've earned from our users.
*30:21-30:30*

It helps them feel confident when trying out new apps from developers they've never heard of.
*30:30-30:36*

It's important to make sure future developers can continue to reap rewards from those benefits.
*30:36-30:41*

The changes we've made in response to the DMA are among the most significant changes Apple has made to our platform since the App Store launch almost two decades ago.
*30:41-30:53*

We made dozens of changes that reflected the work of hundreds of engineers across Apple.
*30:53-30:58*

For example, we enabled developers to launch third-party app stores.
*30:58-31:04*

We introduced a choice screen for browsers.
*31:04-31:07*

We eliminated our policies that required the use of Apple's in-app purchase.
*31:07-31:12*

We introduced programs that allowed third parties to use their own web engines.
*31:12-31:17*

We created new ways for developers to link out for users to complete transactions.
*31:17-31:22*

Yet, this was just the beginning.
*31:22-31:25*

Given the inherent ambiguity in the law and the ever-shifting interpretations of compliance, we knew this was going to be an iterative process.
*31:25-31:34*

We have adjusted course since January 2024 based on feedback from the developer community, the commission, and our users.
*31:34-31:42*

We have made a number of additional changes to our plans since I was last with all of you in this building in March of 2024, a few of which we'll talk about throughout the workshop sessions today.
*31:42-31:54*

For example, we implemented a new way for developers to submit interoperability requests and receive feedback on their ideas.
*31:54-32:02*

We created a new engineering team to better respond to developer questions about interoperability features and alternative app marketplaces.
*32:02-32:10*

We rolled out a new infrastructure on Safari for users to seamlessly and securely export and import browser data.
*32:10-32:19*

We launched the ability for developers to distribute their iOS apps directly from their websites.
*32:19-32:24*

We made changes to the deletion of Apple apps and created seven new categories of apps that users can select defaults in.
*32:24-32:31*

We introduced a process for users to enable data portability to authorize third parties.
*32:31-32:38*

And we've enabled additional options for developers to communicate and promote out-of-app offers to users.
*32:38-32:45*

And much, much more, including changes to our business model that reflect our response to many of the questions that were raised here in this room last year.
*32:45-32:53*

These changes go further than any other gatekeepers.
*32:53-32:59*

For instance, and as Gary will talk about more this afternoon, we allow users to download their App Store data on a recurring daily or weekly basis, not on a one-off or multiple-month basis as others do.
*32:59-33:11*

The changes we've had to make since March of 2024 raise serious concerns about their impact on users and developers.
*33:11-33:21*

These changes create real privacy, security, and safety risks to our users, forcing us to allow the distribution of apps that we think are harmful to our users, including pornography apps like Hot Tub, and also forcing us to decrypt notifications, share Wi-Fi history, and create data-sharing processes that can be abused by bad actors.
*33:21-33:45*

And they create friction for our users, rather than the easy-to-use, right-out-of-the-box experience they expect from Apple products.
*33:46-33:54*

While we're working hard to mitigate potential harms, many risks still do remain.
*33:54-34:00*

Many people seek to somehow dismiss these concerns with a wave of a hand, that somehow it's Apple using them to suit our own narrative.
*34:00-34:08*

I want to be as clear as I can.
*34:08-34:11*

That's just not true.
*34:11-34:14*

The evidence is there, and we continue to engage intensively with the Commission to try and reach a shared understanding of how these concerns are reflected in the day-to-day implementation of the DMA.
*34:15-34:27*

As you all know, the changes we have made in response to the EC's interpretation of the DMA also affects developers in a real way.
*34:27-34:36*

Let me give some examples in the context of interoperability since it's the subject of the first session.
*34:36-34:42*

Disspecification decisions are forcing us to rush interoperability engineering.
*34:42-34:48*

If you wouldn't mind just turning that off, that'd be great.
*34:48-34:51*

Yeah, maybe you could excuse yourself.
*34:51-34:53*

They're forcing us to rush interoperability engineering, creating the risk that we're going to have to offer premature solutions with bugs that developers incorporate into their own work, creating lasting problems for developers and users, even when we roll out updates.
*34:53-35:13*

This rush hurts us too.
*35:13-35:15*

If users encounter bad experiences on third-party devices connected to our platforms, users tend to blame us, not the developer.
*35:15-35:24*

And regardless, we feel responsible for user experience on our platform.
*35:24-35:28*

Not to mention, Apple is focused on creating new technologies and products that are intuitive and easy to use.
*35:28-35:36*

Our development process is dynamic and agile, but in order to comply with the EC's interpretation of the DMA, all the changes we put in place lead to very un-Apple bureaucratic processes we aren't used to.
*35:36-35:50*

And we think we'll create roadblocks for our own software engineering process and for developers too.
*35:50-35:56*

Excuse me, can you please maybe leave the room to fix it?
*35:56-36:01*

Because I can imagine it's disturbing.
*36:01-36:03*

Got it, perfect, thank you, sorry.
*36:03-36:05*

(microphone feedback)
*36:05-36:08*

I'm worried that these changes are forcing us to implement products designed not by our engineers, but by regulators and lawyers.
*36:08-36:26*

As many of you know, new innovations here in the EU are being impacted as well.
*36:26-36:32*

Apple pushes the frontiers of technology each and every year as we release new iPhone and iPad models and versions of our operating systems.
*36:32-36:41*

Yet the DMA will force us to hit the pause button here in the EU.
*36:41-36:44*

Each time we're ready to launch a new technology, we'll have to wait until we can comply with the EC's interoperability requirements, which may take a significant amount of time.
*36:44-36:55*

In many cases, it's not feasible on an engineering level for Apple to make features available to third parties at the very same time they're available to us.
*36:55-37:05*

We can't be sure all the bugs are gone and that we are adequately protecting our users when the experience has to be applied to potentially unlimited developer use cases.
*37:05-37:16*

It is just not possible.
*37:16-37:17*

This means EU users and developers will have to wait for some of our latest and greatest technology and may have to wait for a while.
*37:17-37:26*

And the EC's interpretation of the DMA hinders our ability to compete and innovate.
*37:26-37:33*

Let's be clear.
*37:33-37:35*

Apple already faces incredibly fierce competition in Europe.
*37:35-37:39*

Apple isn't the market share leader in Europe and it has never been.
*37:39-37:43*

Samsung is and others are quickly gaining share.
*37:43-37:47*

Nor are we the market share leader of mobile operating systems.
*37:47-37:50*

But so far, Apple is the only company who has to make these changes in response to the DMA.
*37:50-37:57*

The same interoperability requirements are not applied to the other gatekeepers that have been designated under the DMA, nor to our many competitors that are not designated.
*37:57-38:08*

We are very concerned that there will be those that seek to use these requirements to copy our innovations.
*38:08-38:14*

We will not turn over our hard-earned technology and intellectual property for free.
*38:14-38:21*

So our competitors can make use of our technologies and IP while not having to sacrifice their own.
*38:21-38:28*

Even though we were the ones who spent measureless hours dreaming them up, developing them, and making them a reality, we will look to defend these rights aggressively.
*38:28-38:39*

Not only will our competitors get to profit off our hard work, their products and services will look more like ours, giving consumers less choice, not more.
*38:39-38:49*

That also doesn't help spur innovation in the European economy.
*38:49-38:53*

We had concerns at the outset of this process.
*38:53-38:56*

And those concerns have only grown as we've seen interpretations of the law, untethered by the text, take root.
*38:56-39:03*

All that said, we are doing our best to comply with the moving target of compliance under the DMA.
*39:03-39:09*

In our efforts, we've made an incredible amount of resources available to keep developers and the public informed about these changes.
*39:09-39:17*

We've continued to build on the more than 100 documents we shared at launch detailing these changes.
*39:17-39:23*

Since launch, we've released additional resources to keep users and developers up to date on the latest developments.
*39:23-39:30*

We've continued to update our detailed landing page for developers, walking through our approach and providing extensive documentation on the new options available to them.
*39:30-39:41*

We have also made persistent efforts to solicit developers' feedback on our changes related to compliance with the DMA.
*39:41-39:50*

In our long tradition of actively seeking out developers' views, that's why over the decades, we've built multiple channels to hear directly from the developer community.
*39:50-40:00*

Channels like Developer Forums and our Worldwide Developer Conference, or WWDC, which we held earlier this month and brings together developers from around the world, both online and in person in Cupertino, California, giving them unique access to Apple experts and insight into our newest tools, frameworks, and features.
*40:00-40:24*

The technical and design content from last year's WWDC had over 5 million views from developer teams around the world.
*40:24-40:33*

And while we're still gathering data from earlier this month, I can tell you that there is no question of the international reach of WWDC25, with almost 60 countries participating in person in the special event at Apple Park a few weeks ago.
*40:33-40:49*

In all, our dedicated worldwide developer relations support organization has 2.3 million yearly contacts with the developer community.
*40:49-40:59*

Large developers, small developers, and everyone in between that works with them hears their feedback and helps them keep building great apps on our platform.
*40:59-41:08*

There are millions of developers on iOS with divergent and diverse needs.
*41:08-41:13*

And we try to balance those needs along with the interests of hundreds of millions of users.
*41:13-41:19*

That diversity of users is particularly evident around the DMA.
*41:19-41:24*

For instance, around our changes to our compliance plan last August, on top of our normal developer outreach, we also engaged with 1,000 developers for feedback and to hear their concerns.
*41:24-41:36*

The vast majority did not express concerns, validating our efforts to balance the interests of our whole community of developers.
*41:36-41:45*

Of the concerns we did hear, the demands were often contradictory and did not give any clear path forward.
*41:45-41:52*

The experience demonstrated that there is no one-size-fits-all approach to many of these issues, which I think is understandable given the wide variety of developers with different interests and different perspectives.
*41:52-42:05*

As a European poet once said, "You can please some of the people all of the time, and all of the people some of the time, but you can't please all of the people all of the time." That goes for developers, too.
*42:05-42:19*

I also want to acknowledge the Herculean efforts behind all of this work by the Apple teams.
*42:19-42:24*

Apple may have more resources available to comply with a complex new regulatory scheme than a startup would, but that doesn't mean compliance isn't challenging all the same, requiring dedicated energy from leaders and innovators across our organization.
*42:24-42:41*

We have thousands of employees at Apple involved in dealing with the impact of the DMA in engineering, design, operations, marketing, and more.
*42:41-42:53*

Apple engineers have spent hundreds of thousands of hours to bring everything to life, often on incredibly compressed timelines.
*42:53-43:01*

They created hundreds of new APIs, and their work often required the development of new features, tools, and solutions.
*43:01-43:10*

It's been an enormous effort by teams across the company, and it's continuing today.
*43:10-43:16*

We're still in the early stages of understanding the full impact of the DMA.
*43:16-43:21*

This kind of regime is still new and experimental.
*43:21-43:24*

None of us can predict how it will turn out down the road.
*43:24-43:28*

However, we remain committed to ongoing stakeholder engagement to ensure our efforts align with the law, with our values, as well as our users and developers.
*43:28-43:39*

That, of course, includes an ongoing respectful dialogue with the commission.
*43:39-43:44*

By our count, we've met with the EC over 170 times since this compliance process began.
*43:44-43:52*

That's an average of more than once a week, every week, for more than two years.
*43:52-43:58*

I've become a Brussels regular, and Gary has essentially moved here.
*43:58-44:02*

So with that, I'll turn it over to noted Brusselier, Gary Davis.
*44:02-44:07*

Well pronounced.
*44:07-44:10*

Thank you very much, Kyle.
*44:10-44:11*

It's great to see so many familiar faces here, some sitting in the exact same seats they sat in last year, I think, as I look around the room.
*44:11-44:19*

And I want to reiterate what Kyle said at the outset.
*44:19-44:22*

We will not waver on our approach to the DMA.
*44:22-44:25*

And it was for this reason that I asked, could I come and work on DMA more?
*44:25-44:31*

This is incredibly interesting work, but work that needs to ensure we strike the right balance on privacy and security.
*44:31-44:40*

And I guess I trusted myself more than anyone else to help think about how we could achieve that.
*44:40-44:47*

I also want to reiterate what Kyle said, that Brussels has, in fact, become my home away from home.
*44:47-44:52*

Well, Uber has decided it has anyway.
*44:52-44:54*

It welcomes me here with a welcome message whenever I land.
*44:54-44:58*

My wife doesn't know that yet.
*44:58-45:00*

I haven't told her, and I am absolutely confident she will not be watching this workshop.
*45:00-45:06*

But the work is far from over, and we'll continue to always look forward to the future.
*45:06-45:13*

Apple's commitment to interoperability on mobile devices began in 2008 with iPad OS, when we first opened up the iPhone to third-party developers.
*45:13-45:26*

As Steve Jobs said then, opening up the iPhone required doing two diametrically opposed things-- providing an open platform to developers, but also protecting iPhone user security and privacy from the many malicious actors out there on the internet.
*45:26-45:48*

That means that for nearly 20 years, we have looked for responsible, careful ways to open iOS to developers.
*45:48-45:57*

Ever since we launched the App Store that summer and watched as hundreds, then thousands, and now millions of apps from developers all over the world transformed user experience, we've opened up an ever-expanding number of ways to build and innovate with the technologies we create every year, while still protecting our users' safety, security, and privacy, along with our own intellectual property.
*45:57-46:28*

We've enabled developers to leverage the powerful technologies we've engineered into iOS and iPhone, including more than 250,000 APIs across our platforms, 40 software development kits or SDKs, and much more that allowed them to build innovative, ever more powerful apps.
*46:28-46:50*

Of this, there can be no question.
*46:50-46:52*

Just look at the flourishing platform that developers are contributing to, creating amazing experiences for users.
*46:52-47:01*

We actively contribute to standards and are a member of more than 100 standards organizations that drive interoperability and compatibility and help everyone's technology work better together.
*47:01-47:15*

That includes shared standards for everything from cellular technologies like 5G to security protocols that protect people's information to support for third-party devices like hearing aids, which we've implemented on iPhone for developers to take advantage of.
*47:15-47:34*

We've been focused on giving developers these tools since the very beginning.
*47:34-47:39*

We improve the iPhone each year to introduce new technologies, new features, and new functionalities, and then give developers the ability to access these innovations to leverage their own creations, where it makes sense, and where we can do so safely.
*47:39-47:58*

To make sure we're building interoperability solutions that work for developers, we answer and solicit questions to our Apple Developer Forums and Feedback Assistant.
*47:58-48:08*

When developers bring an issue to our attention, we work on fixing it.
*48:08-48:13*

For instance, that's how we introduced Accessory Setup Kit, which I'll talk about a little bit later.
*48:13-48:19*

We were doing this before the DMA came into effect.
*48:19-48:22*

And as the platform has grown and evolved, we remain dedicated to answering questions and helping developers understand our changes and new processes, including those on interoperability.
*48:22-48:37*

Throughout this decades-long evolution, we've made some of the most beloved parts of our devices interoperable-- things like the camera, microphone, the contacts database, the photo library, and location services.
*48:37-48:52*

These and many other tools and technologies that we've made interoperable underlie so much of how developers build great apps and how users benefit from those apps' access to our devices' systems.
*48:52-49:06*

For example, for over a decade, third-party apps have been able to operate in the background of our devices, send instantaneous push notifications, and take advantage of our devices' Bluetooth and Wi-Fi capabilities.
*49:06-49:22*

There are innumerable more examples of interoperability we've enabled, and thousands of third-party devices have taken advantage of them, building great devices that integrate with our platforms.
*49:22-49:35*

Apple enables seamless integration and control of smart home accessories.
*49:35-49:40*

Through HomeKit and the Matter framework, we enable third-party devices like lights, outlets, dimmer switches, thermostats, door locks, security cameras, and more to interoperate with Apple devices.
*49:40-49:55*

HealthKit secures users' health and fitness data on Apple devices and works with health-related accessories in a privacy-protective framework.
*49:55-50:06*

For instance, Oura Ring, Witting's blood pressure monitors, and PolarHeart monitors use HealthKit, as do many scales, thermometers, sleep pods, and blood pressure cuffs.
*50:06-50:20*

These are just a few of the kinds of devices that interoperate with our platforms.
*50:20-50:25*

Thousands and thousands of developers and manufacturers worldwide create connected devices in areas from TVs, speakers, and headphones, to treadmills, smart lights, and gimbals.
*50:25-50:39*

And we're always coming up with new ways to help developers innovate.
*50:39-50:43*

For example, just last year, based on feedback from developers, we announced Accessory Setup Kit, which allows developers to seamlessly and securely pair accessories through their apps without relying on access to all nearby Bluetooth and Wi-Fi devices, keeping those other devices private.
*50:43-51:06*

As our decades of experience has taught us, interoperability is inherently complex.
*51:06-51:12*

It takes a lot of engineering, time, and effort to get right.
*51:12-51:18*

We don't rush interoperability solutions to market.
*51:18-51:21*

We wait until they're ready.
*51:21-51:24*

And in order to make sure that the technology is secure, private, stable, and fit for developers to rely on, we need to observe how the solutions are working in a real-world environment, often by running it on our own products first on a case-by-case basis.
*51:24-51:43*

We identify any security and privacy risks or material performance issues and adjust or control the update, feature, or functionality in question as required.
*51:43-51:55*

Internal and pre-release testing is just not an effective substitute to seeing all the real-world variables, especially when you add to that the untold number of ways that developers may wish to use a solution.
*51:55-52:10*

This has always been our approach.
*52:10-52:14*

Like everything else, we make things that work, that are safe for users, and reliable for developers.
*52:14-52:21*

And we don't unleash them on the marketplace unless we're confident that's true.
*52:21-52:28*

I suspect that even before Kyle spoke about it earlier, many of you here are familiar with our concerns about what we consider to be the extreme interpretation of interoperability that's currently held by the Commission, which we think stands in contrast to our careful approach to interoperability.
*52:28-52:45*

We think it's important to understand the costs that come with the EC's version.
*52:45-52:50*

As Kyle said earlier, it creates more risks for users and a potentially less reliable platform for developers to build on, and results in delays before our EU users and developers can get the new products they, and we, are really excited about.
*52:50-53:10*

We saw that happen with Apple Intelligence, which we launched to users in the US and other regions in October 2024.
*53:10-53:19*

In the EU, the process was different.
*53:19-53:22*

Following proactive engagement with the EC, shortly after announcement, we focused on offering developers direct access to the Apple Intelligence features embedded in iOS and iPadOS, like writing tools, smart replies, or image playground, right into their apps.
*53:22-53:44*

This took a lot of complicated engineering work as we navigated privacy and safety concerns.
*53:44-53:50*

So developers and users had to wait even longer than we anticipated to access these new capabilities in the EU.
*53:50-53:59*

Our announcements at WWDC earlier this month are another perfect case study of how our approach to interoperability and of how the EC's contrasting vision of interoperability affects our ability to bring great new products and features to market.
*53:59-54:17*

At WWDC, we announced new features and functionalities in the new versions of iOS, iPadOS, and our other operating systems.
*54:17-54:26*

There are a lot of exciting new opportunities for developers.
*54:26-54:32*

In this respect, I'd like to take a few minutes to highlight a new tool that will allow for even greater interoperability, which we are really excited about.
*54:32-54:42*

The Foundation Models framework gives developers access to the on-device large language model that powers Apple Intelligence.
*54:42-54:52*

With a convenient and powerful Swift API, we're especially excited about this framework because it will be available to developers to enhance their app's existing functionalities or create completely new ones.
*54:52-55:07*

It will give developers direct access to the on-device models that power features of Apple Intelligence with capabilities like text extraction and summarization and allow developers to prompt Apple's on-device model and receive a response.
*55:07-55:25*

Developers will be able to specify both the text-based prompt and instructions to the model and tune parameters of the model's output.
*55:25-55:34*

The applications are truly endless.
*55:34-55:38*

Developers can use Foundation Models to generate everything from writing assistance and travel itineraries to personalized search results and language learning.
*55:38-55:47*

For example, game developers can leverage Foundation Models to generate real-time in-game dialogue.
*55:47-55:55*

This is quite literally a game changer for developers.
*55:55-56:00*

We have made a concerted effort to make this easy for developers to use.
*56:00-56:04*

We have released a toolkit that enables developers to train so-called adapters, which enhances the performance of the model in highly specialized use cases.
*56:04-56:15*

And because all of this runs on-device, it helps users' data stay private, giving developers a privacy-protective way to personalize their use of the models to the user.
*56:15-56:27*

And as an added bonus, it means the models can run offline.
*56:27-56:34*

In short, with the Foundation Models framework, we've given developers access to an unbelievably powerful LLM that runs for free, no tokens required, so they can let their imaginations run wild.
*56:34-56:48*

We've also shown that our normal interoperability process demonstrates proactive compliance with the requirements and principles underlying Article 6.7 and satisfied them in full by opening up the on-device model we've built to developers.
*56:48-57:05*

This is just one of the latest tools we've enabled for developers to build great apps without mandated requirements forcing us to do so.
*57:05-57:14*

Throughout Apple's history, it has entirely been in Apple's interest to invest in giving developers the technologies they need to create great apps for users to enjoy.
*57:14-57:24*

And we're continuing to do so.
*57:24-57:26*

Unfortunately, because the EC's version of interoperability flips that successful model on its head, we've already had to make the decision to delay the release of products and features we announced this month for our EU customers.
*57:26-57:43*

These features include enhancements to iPhone mirroring and new Maps features, like Visited Places and Preferred Routes.
*57:43-57:51*

With Visited Places, users can allow iPhone to intelligently detect the places they visit and spend time in and automatically save those locations to Maps.
*57:51-58:02*

And the iPhone can use on-device intelligence to learn the routes users take between the places they frequently visit, even if they are not using Maps, and provide previews and commute notifications, even before the user's journey begins.
*58:02-58:17*

Critically, here, this location information is on the user's device, accessible only to them.
*58:17-58:26*

Apple doesn't have access to any of this data, and we want to make sure no one else does either.
*58:26-58:32*

We wish we could offer these features to our EU users.
*58:32-58:37*

But unfortunately, it's impossible to do all the complex engineering to comply with the Commission's current interpretation of the DMA, while protecting our users and providing a stable solution for developers, all in time for rollout.
*58:37-58:51*

As these tools show, enabling interoperability while protecting what our customers love about our products is not as simple as pressing a button or flipping a switch.
*58:51-59:02*

It requires careful thought, extensive engineering, and significant time to get right.
*59:02-59:09*

New regulations shouldn't mean that we can no longer offer our customers the innovative, privacy-protected products they expect, or developers the stable platforms they rely upon.
*59:09-59:20*

And we genuinely do not believe this was the intent of lawmakers when passing the DMA, nor the intent of the many Commission officials we engage with on these issues.
*59:20-59:31*

But this is somehow where we have found ourselves.
*59:31-59:35*

Nor do we believe that the lawmakers intended for the EC's DMA teams to be the final arbiters of user safety and security.
*59:35-59:42*

Instead, the regulators should be setting clear goals for companies to meet and call on experts from specialized agencies, like the EU Agency for Cybersecurity, the European Data Protection Board, National Data Protection Regulators, and telecommunication regulators, when necessary.
*59:42-01:00:01*

The Commission still has an opportunity to create a workable requirement here, to create a proportional interpretation of the DMA, to focus on interoperability areas where clear contestability risks appear, and to pay closer attention to the technical implications of their requirements.
*01:00:01-01:00:20*

As we've made clear here, we have disagreements with the EC's interpretation of Article 6.7 and have exercised our fundamental right to seek judicial review.
*01:00:20-01:00:31*

We believe these decisions will put our users' privacy and security at risk and will make it harder for us to provide the stable platform developers love to build upon.
*01:00:31-01:00:40*

And the fact that we're being forced to do this and our competitors are not, will hurt competition, not help it.
*01:00:41-01:00:50*

Of course, Apple is still working to comply with both the interoperability specifications for the request process and for the connected devices, and Gary will walk through updates on our efforts to implement both of those mandates.
*01:00:50-01:01:04*

>> Thank you, Kyle.
*01:01:04-01:01:08*

Let's start with the interoperability request process, which Kaya included a slide on at the start of her presentation also.
*01:01:08-01:01:17*

I want to reiterate that a tremendous amount of work went into implementing a system to review interoperability requests and develop solutions, including countless hours of engaging with developers and engineering interoperability solutions.
*01:01:17-01:01:34*

We did this even where we had similar processes and solutions in place for years, and we've always been in close discussion with developers, welcoming and soliciting their feedback, as I mentioned earlier also.
*01:01:34-01:01:49*

But in response to the specification decision, we've built another way for developers to submit interoperability requests through feedback assistant.
*01:01:49-01:01:58*

Developers can communicate directly with Apple's worldwide developers relations team and receive updates on the status of these requests, key milestones, and deadlines.
*01:01:58-01:02:09*

Developers can also view an up-to-date status of their request and directly communicate with Apple on their pending requests in the dedicated space in feedback assistant.
*01:02:09-01:02:19*

That is, in fact, the request -- yeah, yeah.
*01:02:19-01:02:24*

So what you're looking at there is the sign-in page for feedback assistant.
*01:02:24-01:02:29*

We think this location is intuitive for developers, since they're accustomed to using this system as a hub for feedback, including to report issues they encounter and to request enhancements to APIs, tools, and services across multiple of our operating systems and devices.
*01:02:29-01:02:48*

Developers can access feedback assistant from multiple links on Apple's dedicated interoperability support page through the developer portal, through the feedback assistant app, or by visiting feedbackassistant.apple.com directly.
*01:02:48-01:03:04*

On the interoperability support page, we've also introduced an example of a completed form for developers to reference.
*01:03:04-01:03:13*

On the interoperability request form itself, developers are required to answer a few questions to help us more effectively respond to their request.
*01:03:13-01:03:22*

First, a developer must provide a descriptive title of its request, identify the iOS, iPadOS, iPhone, or iPad feature they'd like to access, and the reason why they would like us to help us develop an effective interoperability solution.
*01:03:22-01:03:38*

This helps us understand exactly what a developer is looking for, so we can respond to their request as efficiently as possible.
*01:03:38-01:03:46*

Secondly, the requester is required to describe the product they intend to use their feature with, how their product will use the feature, and where they plan to offer their product.
*01:03:46-01:03:58*

We ask this just to better understand whether we already provide a solution, what exactly the developer needs from a solution, and confirm the request is in scope.
*01:03:58-01:04:11*

Third, a developer explains whether they have considered alternative frameworks or technology to achieve the desired result. This helps inform any possible solution we may build and our analysis of whether we already provide a solution that we can direct the developer to.
*01:04:11-01:04:27*

We also ask the developer to indicate how confidential they would like the request to be kept, and to provide any additional information they would like.
*01:04:30-01:04:39*

Finally, the developer can provide attachments to help provide context for the request if they wish.
*01:04:39-01:04:45*

So that's our updated process for submitting an interoperability request.
*01:04:45-01:04:51*

The process by which Apple reviews interoperability requests has largely remained the same.
*01:04:51-01:04:56*

I want to highlight some of the new specifics that apply to each step along the way.
*01:04:56-01:05:02*

First, we conduct an initial legal assessment to examine whether the request falls within the scope of the DMA.
*01:05:02-01:05:09*

For instance, a request is not within the scope of the DMA if our own services or hardware don't use that operating system functionality.
*01:05:09-01:05:18*

In some cases, we contact the developer if we need additional information to evaluate their request.
*01:05:18-01:05:25*

Once an initial evaluation is complete, we inform the developer about the outcome of our assessment, including details about our reasoning.
*01:05:25-01:05:35*

At this stage, we also consider whether an effective interoperability solution, in fact, already exists.
*01:05:35-01:05:41*

It often does.
*01:05:41-01:05:43*

If so, we'll point the developer towards the many tools and technologies we already provide.
*01:05:43-01:05:51*

Second, if the request falls within the scope of the DMA and a solution doesn't already exist, our team puts together a project plan, which includes information on the proposed interoperability solution and a description of the engineering work.
*01:05:51-01:06:08*

The project plan will also include a timeline for developing a proposed solution, which will obviously depend on how complex it is.
*01:06:08-01:06:16*

Apple also welcomes feedback from the developer on the project plan at this time.
*01:06:16-01:06:22*

Third, and finally, Apple gets to building.
*01:06:22-01:06:26*

Each solution is tailored to the unique requirements of the interoperability request, at times demanding significant engineering resources and effort.
*01:06:26-01:06:38*

To meet that demand and as part of our compliance efforts, as Kyle mentioned earlier, we have established a separate engineering team to deal with these incoming requests in a dedicated, efficient manner and separately focus on ensuring that Apple provides third parties with effective interoperability with newly released iPhone and iPad hardware and software features in as timely a manner as we possibly can, taking account of the stability, privacy, and security issues we have spoken about here this morning.
*01:06:38-01:07:13*

If we reject an interoperability request, we give developers a detailed explanation as to why.
*01:07:13-01:07:20*

We provide specific reasons for the rejection, outlining the criteria or requirements that the request did not meet.
*01:07:20-01:07:28*

We let developers know who they can contact at Apple with any questions, giving them contact information for the relevant support team.
*01:07:28-01:07:36*

We also explain how they might use the internal review mechanism and, if applicable, any additional procedure for those decisions.
*01:07:36-01:07:44*

And we share information about the requests that don't move forward with the commission, adding yet another layer of transparency to the process.
*01:07:44-01:07:54*

To further increase transparency, we've also launched an interoperability request tracker, which is available via the Apple Developer Portal.
*01:07:54-01:08:02*

The interoperability request tracker includes all non-confidential, relevant material from each request and is updated weekly.
*01:08:02-01:08:12*

When a developer gives explicit consent to a feedback assistant, Apple makes the entire request fully available in the interoperability request tracker.
*01:08:12-01:08:21*

We also make available message and updates exchanged between Apple and the developer.
*01:08:21-01:08:28*

Alternatively, a developer can give us their explicit consent to make the request partially available through feedback assistant.
*01:08:28-01:08:35*

That selection allows us to share a more limited set of information from the request with other developers, like the name of the organization, the requested feature, the developer's own non-confidential description of the request, and the general status of the request.
*01:08:35-01:08:53*

And finally, a developer can decline to make its request fully available or partially available in the dedicated tracker system.
*01:08:53-01:09:01*

In this case, Apple makes available only very high level information about the request, like its status, and again, a developer provided generic description.
*01:09:01-01:09:13*

So that's the updated interoperability request process as required by the commission.
*01:09:13-01:09:19*

I wanted to take a moment to share some insights into the types of requests we have seen over the last year or so.
*01:09:19-01:09:27*

We're seeing quite a lot of requests that demand new functionalities that don't even exist or that otherwise don't make sense.
*01:09:27-01:09:35*

And to be clear, this is not due to a lack of information available to inform such requests.
*01:09:35-01:09:41*

One request, for example, came from a developer who wanted us to build a functionality that would allow them to run their iOS games from external storage rather on our own iPhone.
*01:09:41-01:09:53*

This isn't possible on iOS for Apple or anyone else.
*01:09:53-01:09:58*

Another request came in from someone who wanted to use the COVID-19 contact tracing API to create a game that connected to the phones of people they walk by in real life.
*01:09:58-01:10:10*

We developed the exposure notification framework specifically to identify users who had close contact with COVID-19 cases.
*01:10:10-01:10:19*

And unrelated use cases would give rise to serious user privacy and security implications, which we never accounted for.
*01:10:19-01:10:27*

We explicitly didn't make that API available to other teams at Apple to build products with either.
*01:10:27-01:10:33*

Some requests simply ask us to enable technology that we've decided not to build or make available to our own apps, like very long range Bluetooth.
*01:10:33-01:10:43*

This doesn't exist on iOS because we have concerns it could result in excessive battery drain in crowded environments.
*01:10:43-01:10:51*

I'll turn it back to Gary to talk about some of the specific risks we've seen in this process.
*01:10:51-01:10:57*

Some of the requests we receive also raise serious concerns about users' privacy and security.
*01:10:57-01:11:03*

Some third parties are weaponizing interoperability to access users' personal information, whether they're malicious actors or just hungry to ingest as much data on you as they can.
*01:11:03-01:11:15*

It's unclear why anyone needs this level of access to your personal lives, far beyond what Apple itself can see on your device.
*01:11:15-01:11:24*

Think about all of the information we store in our iPhones, our health and fitness information, messages with our family and friends, work-related emails, photos, location data, journal entries, and calendars with personal appointments.
*01:11:24-01:11:40*

Now, think about what could happen if any developer could access all of that information.
*01:11:40-01:11:45*

But yet, we have received requests from some companies that want the means to access it all.
*01:11:45-01:11:51*

Access to Apple has gone out of its way to ensure that we ourselves do not have.
*01:11:51-01:11:56*

We've received interoperability requests that, if granted, would give other companies the ability to read the contents from each and every message and email on the user's device.
*01:11:56-01:12:07*

See each and every phone call made or received, or look at their calendar events.
*01:12:07-01:12:14*

Providing third parties with unfettered access to every part of every user's iPhone, like these requests would have us do, would compromise user privacy and security.
*01:12:14-01:12:26*

And it is contrary to what was set out in the GDPR.
*01:12:26-01:12:31*

The DMA was explicitly intended to not undermine the GDPR.
*01:12:31-01:12:36*

Yet, it seems we are constantly being asked to do just that.
*01:12:36-01:12:40*

As you know, Article 6.7 allows us to introduce measures to mitigate concerns related to integrity.
*01:12:40-01:12:48*

But the EC's view is that the concept of integrity does not extend the privacy concerns.
*01:12:48-01:12:53*

Let me read a quote to you from the specification decision.
*01:12:53-01:12:57*

"Within the architecture of the DMA, integrity has a distinct meaning from users' privacy and security.
*01:12:57-01:13:04*

This is not what our users expect.
*01:13:04-01:13:07*

The fact that we have ensured that we ourselves do not have access due to end-to-end encryption or other security safeguards are not seen as relevant considerations.
*01:13:07-01:13:17*

That cannot be right, and again, cannot be what was intended." You all know how much Apple users value the privacy and security of their data.
*01:13:17-01:13:27*

That's one of the many reasons they choose Apple over our competitors' products, and why we work so hard to keep their data safe.
*01:13:27-01:13:35*

If we are forced to give up that value, this places our users at risk while compromising what makes Apple unique.
*01:13:35-01:13:42*

Before I get into the numbers on these requests, I think it's important to put the new request process mandated by the European Commission into the broader context.
*01:13:42-01:13:55*

We have always worked with developers and third parties to develop, enhance, and build iOS and our other operating systems to make them the very best technology platforms in the market.
*01:13:55-01:14:07*

That's been true since the very beginning, and Apple has always had an open door for the developer community.
*01:14:07-01:14:14*

We have open channels of communication with third parties about technology development, support, and interoperability.
*01:14:14-01:14:22*

Through feedback assistance, through developer technical support, through one-on-one engagement and consultations, through developer forums, and at WWDC, just to name a few.
*01:14:22-01:14:33*

The process Gary outlined is heavy on bureaucracy and mandates.
*01:14:33-01:14:37*

It's what we had to do under the Commission's interpretation of the law.
*01:14:37-01:14:41*

But it's important to remember that although it's one way for a developer or a third party to ask for access to our technology, it's far from the only way, nor from our perspective, the best way.
*01:14:41-01:14:53*

Now, to what we are seeing through this new process.
*01:14:53-01:14:55*

There have been 94 developers that have submitted a total of 150 interoperability requests as of June 25 of this year.
*01:14:56-01:15:05*

About 20% of the requests related to features that already have effective interoperability solutions.
*01:15:05-01:15:13*

Another handful were closed before our team had made an evaluation, either because the developer withdrew the request, or the request was blank or in a series of identical requests.
*01:15:13-01:15:23*

And another 40% of the requests weren't covered by Article 6.7 at all.
*01:15:23-01:15:28*

For example, the request to run iOS games from an external storage that I referenced earlier.
*01:15:28-01:15:35*

Now, I will say that simply because we decide that a particular request is not required by the law, it doesn't mean we simply ignore it.
*01:15:35-01:15:43*

We have already started working on some of these requests outside of this bureaucratic process.
*01:15:43-01:15:49*

We're reviewing requests to the Commission on Interoperability.
*01:15:49-01:15:54*

We're reviewing requests quickly, particularly in light of the inherent complexities of interoperability and the technologies at issue.
*01:15:54-01:16:01*

Since the specification decision, on average, it takes us about 17 and 1/2 working days to review an interoperability request and respond to the developer.
*01:16:01-01:16:12*

We have always made a determination within a time period allotted by the specification.
*01:16:12-01:16:17*

We've already released several interoperability solutions made under the DMA.
*01:16:17-01:16:22*

For example, in response to one developer's request, we created the Critical Messaging API, which provides a way for apps to deliver critical messages to a set of phone numbers.
*01:16:22-01:16:34*

If a business wants to receive check-ins from employees working in hazardous or rural environments, being able to automatically message a centralized corporate check-in point may help confirm the safety of those employees without disrupting their work.
*01:16:34-01:16:48*

Or if the employee is unable to access or unlock their iPhone.
*01:16:48-01:16:53*

And we're working on more.
*01:16:53-01:16:54*

Our talented engineers, some of the very best in the world, are dedicating enormous resources to tackle even the smallest requests, even if they don't serve a very broad set of customers and developers.
*01:16:54-01:17:06*

In addition to the time taken to respond to niche requests, we're worried this process is also being used to pursue ends other than what the Commission intended.
*01:17:06-01:17:15*

Nearly one-third of the 150 requests have been made by three other gatekeepers.
*01:17:15-01:17:22*

Now, I'll turn to the updates we've made to our compliance plan for connected devices following the specification.
*01:17:22-01:17:31*

I want to say at the outset that the Apple technology implicated by the specification is, of course, protected by intellectual property rights and developed over the course of many years.
*01:17:31-01:17:41*

The connected devices interfere with Apple's intellectual property rights by compelling the disclosure and use of proprietary technologies.
*01:17:41-01:17:49*

The ability to differentiate products based on innovation is precisely what IPRs are designed to protect.
*01:17:49-01:17:56*

I will just say that we are a little bit running behind the schedule already.
*01:17:56-01:18:04*

So if we could maybe try to discipline also that we don't go too much at the expense of the-- Well, I think I'll make an attempt to summarize a little bit and then pass it back to Kyle, Lucia.
*01:18:04-01:18:19*

I think, as I mentioned earlier, we have a decades-long commitment to providing interoperability to third parties.
*01:18:19-01:18:27*

I think it's just very important to make clear in a slide such as this how we have worked with so many other third parties to give them great experiences on iPhone and iPad and our other devices.
*01:18:27-01:18:40*

Maybe if we skip ahead one, Sam.
*01:18:40-01:18:44*

Obviously, and Kaya mentioned it in her intro, remarkably prescient, actually, for what I was going to cover.
*01:18:44-01:18:52*

Notifications is an area that we had deep discussions with the Commission on during the specification process.
*01:18:52-01:19:04*

There is an outcome there, which I think we have a view on as to a way to achieve it.
*01:19:04-01:19:09*

And I think the Commission has a view on a way to achieve it.
*01:19:09-01:19:12*

The outcome is requiring us to decrypt the notifications and pass them to the companion app on the device.
*01:19:12-01:19:21*

We happen to believe there is a way to do that that preserves end-to-end encryption.
*01:19:21-01:19:26*

We think it can be provided to the companion app, providing all the utilities sought by third parties in a way that does not create the outcome that we believe poses the risk.
*01:19:26-01:19:36*

Now, Kaya obviously outlined a different view from the Commission.
*01:19:36-01:19:39*

We believe we presented opportunities to do it differently and give third parties everything that is out there.
*01:19:39-01:19:47*

Secondly, moving on to sharing Wi-Fi history, and again, Kaya covered that in her intro.
*01:19:47-01:19:56*

We don't have any issue sharing Wi-Fi history at all, in fact.
*01:19:56-01:20:00*

We want to create those great experiences for third party connected devices so that it can seamlessly integrate with a Wi-Fi network without the device having to engage in extensive additional work to sign up.
*01:20:00-01:20:15*

That's not an issue.
*01:20:15-01:20:17*

Where we are disagreeing is-- if we move ahead perhaps one more slide, Sam-- where we're disagreeing is on an ability or a requirement to provide detailed history of a person's Wi-Fi connection over many years.
*01:20:17-01:20:36*

That is something that's in the measures.
*01:20:36-01:20:38*

It has been discussed.
*01:20:38-01:20:41*

I think we have a difference of views to what's needed in order to make the connectivity work.
*01:20:41-01:20:46*

We happen to think it can be done in a more clean way that protects privacy and security without a need for a user to have to hand over their full history, potentially, to third parties.
*01:20:46-01:21:00*

Now, with that, I think I will move on to talking about Wi-Fi Aware.
*01:21:03-01:21:10*

So we're also working-- and this is something we discussed at WWDC earlier this month-- we're working on other interoperability solutions, including those that will allow third party devices to connect to iOS devices via Wi-Fi Aware.
*01:21:10-01:21:26*

Enable-- and this, again, some of these were covered on the intro slides-- enable proximity-based pairing of third party connected devices.
*01:21:26-01:21:35*

Provide third party access to features enabling close range wireless file transfer.
*01:21:35-01:21:41*

Enhance functionalities available to custom casting protocols, including a new API for media casting.
*01:21:41-01:21:49*

Facilitate automatic switching for third party headphones.
*01:21:49-01:21:53*

And enable additional access to the NFC controller through another new API.
*01:21:53-01:22:00*

And to reiterate, one more time, as we're developing these solutions, we're doing everything we can to help keep our users safe and their personal information secure.
*01:22:00-01:22:11*

But the risks to safety, security, and privacy from the EC's version of interoperability are real, including around connected devices.
*01:22:11-01:22:22*

Importantly, I do believe that the people we work with every day at the Commission appreciate these issues.
*01:22:22-01:22:29*

But respectfully, they are not the designated authorities on privacy and security.
*01:22:29-01:22:34*

We understand the desire to get results, but it is critical that regulators take the time necessary to consult with their colleague regulators in the field and gather perspectives to build well-rounded solutions that account for all critical voices and any articulated downstream consequences.
*01:22:34-01:22:53*

This makes it difficult to strike the right balance between privacy and security concerns and interoperability, as the Commission is acting without detailed input from the experts in the field who can weigh in with their deep knowledge.
*01:22:53-01:23:08*

For instance, we actively participated at the high-level group set up by the Commission on AI, where the expert agencies and stakeholders we talked about earlier-- the European Data Protection Board, National Data Protection Regulators, telecommunication regulators, as well as consumer bodies-- were brought together, which provided a very useful opportunity to hear from different perspectives, all with expertise in their subject area.
*01:23:08-01:23:35*

But unfortunately, when it came to the DMA specifications, the high-level group, let alone cybersecurity experts like Anissa, were no more to be found, which despite the best intentions of the EC, creates a situation where all the complex decisions on the trade-offs that must be weighed around interoperability are being made by those without the requisite ongoing technical knowledge in privacy and security.
*01:23:35-01:24:03*

The Commission has a wealth of knowledge at its fingertips to draw on these significant decisions, independent expert viewpoints well-used to engage in discussions on enforcement, and to balance in risks and ensuring clarity for all.
*01:24:03-01:24:19*

And we do encourage the Commission to make sure these important perspectives are heard to help shape DMA compliance going forward.
*01:24:19-01:24:28*

So I'll wrap up here.
*01:24:28-01:24:29*

Thanks, Gary.
*01:24:29-01:24:30*

This morning, we've recapped Apple's long history of interoperability, giving developers access to countless tools and technologies over the years.
*01:24:30-01:24:39*

But the key to opening up Apple's devices is to do so in a careful, thoughtful way, a way that benefits developers and users.
*01:24:39-01:24:47*

The extreme interpretation of interoperability that's embedded in the specification decisions has been applied to Apple alone.
*01:24:47-01:24:55*

It puts users' security privacy and safety at risk.
*01:24:55-01:24:59*

And it's impacting our ability to innovate and bring new technologies to EU users.
*01:24:59-01:25:04*

Apple is essentially being required to give away access to our intellectual property for free to our competitors.
*01:25:04-01:25:11*

Meanwhile, our competitors are not bound by the same requirements and are allowed to continue to reap the value of their innovations and ours.
*01:25:11-01:25:20*

I also want to point out that three operating systems have been designated-- iOS, Android, and Windows.
*01:25:20-01:25:28*

However, the fact is we are the only gatekeeper targeted by these measures.
*01:25:28-01:25:32*

I should be clear, we worked hard to comply with Article 6.7 and will continue to do so.
*01:25:32-01:25:38*

As Gary mentioned, our teams have spent hundreds of thousands of engineering hours in the last few months alone to respond to the specification decisions.
*01:25:38-01:25:46*

And much more work is still to come.
*01:25:46-01:25:49*

We've rolled out and fine-tuned a very thorough, if overly bureaucratic, interoperability request process.
*01:25:49-01:25:56*

Our teams timely respond to those requests.
*01:25:56-01:25:59*

Needless to say, this is no easy task, especially given some of the technologies at hand.
*01:25:59-01:26:05*

Interoperability is complicated and can be risky.
*01:26:05-01:26:08*

Unfettered interoperability is very complicated and, frankly, dangerous.
*01:26:08-01:26:13*

But we remain committed to complying with the DMA, protecting our users, and our ability to innovate here in the EU and around the world to the best of our ability in engaging on these important issues.
*01:26:13-01:26:25*

I continue to hope that based on our experience with the Commission thus far, and especially over the last few weeks, we will be able to come up with a shared understanding of how to strike the right balance on interoperability and incorporating fair and reasonable security designs.
*01:26:25-01:26:41*

With that, I'll pass it back to the Commission.
*01:26:41-01:26:44*

Thank you, Kyle.
*01:26:44-01:26:45*

Thank you, Gary.
*01:26:45-01:26:47*

So as you could have heard, we have certain disagreements and differences, including on the scope of the DMA and privacy and security risks.
*01:26:47-01:26:57*

I will just recall that it's not the place today for us to react to what was said.
*01:26:57-01:27:03*

Our position is outlined in the decisions which have been made public.
*01:27:03-01:27:06*

I invite everyone to look at those.
*01:27:06-01:27:10*

I will now open the Q&A. I will take three to five questions at a time, depending on their complexity.
*01:27:10-01:27:16*

Please raise your hands.
*01:27:16-01:27:18*

Very good.
*01:27:18-01:27:18*

And we will be alternating the room and the slido.
*01:27:18-01:27:22*

So I think the gentleman there in white t-shirt was first.
*01:27:22-01:27:26*

So please go ahead.
*01:27:26-01:27:28*

Thank you very much.
*01:27:28-01:27:29*

My name is Leo.
*01:27:29-01:27:30*

I work for-- push that.
*01:27:30-01:27:32*

It's not open.
*01:27:32-01:27:33*

OK, I should keep it.
*01:27:33-01:27:34*

OK, thank you.
*01:27:34-01:27:35*

My name is Leo.
*01:27:35-01:27:36*

I work for AFNUM, the French Alliance for Digital Industries.
*01:27:36-01:27:45*

As a representative of manufacturer at AFNUM, we work a lot of infrastructure issue, especially cloud infrastructure or telecom infrastructure, which necessarily lead to a lot of discussion of interoperability.
*01:27:45-01:28:01*

I just wanted to emphasize that when we talk about interoperability, we must keep in mind that this is an industrial process that's in line with the time of industry.
*01:28:01-01:28:14*

So that's why when I work with regulators, especially French one, and I see it's on the point that I wanted to move too quickly, we forget that only time and innovation allow us to see the emergence of readable, interoperable, secure, and economically viable solution.
*01:28:14-01:28:34*

I think that the key word here is secure.
*01:28:34-01:28:38*

Cybersecurity should be at the heart of the interoperability discussion.
*01:28:38-01:28:43*

That's why I would like to hear you again on the cybersecurity challenges that derivate from this obligation and about the impact of the timeline on your ability to mitigate this issue.
*01:28:43-01:28:56*

I saw you said at the beginning of your introduction that the DMA opens the door for interpretation, and that is not really clear.
*01:28:56-01:29:05*

So what are your view regarding this obligation?
*01:29:05-01:29:09*

And maybe do you think there is a way to make it more objective or at least less subjective?
*01:29:09-01:29:14*

Thank you.
*01:29:14-01:29:16*

Thank you.
*01:29:16-01:29:19*

Maybe that one in the shirt.
*01:29:19-01:29:20*

Thank you.
*01:29:20-01:29:24*

Alexander from the European Consumer Organization.
*01:29:24-01:29:27*

Thank you for your explanations this morning.
*01:29:27-01:29:29*

On interoperability, could you please confirm first that Apple will ensure effective interoperability of physical connected devices free of charge?
*01:29:29-01:29:40*

You have explained how Apple provides services to developers that are free, but my question goes a bit beyond.
*01:29:40-01:29:45*

Do you ensure effective interoperability free of charge as per Article 6.7?
*01:29:45-01:29:50*

Second, could you please confirm that Apple has tested or will test the end user journey of its interoperability solutions to ensure that there is no negative friction, such as scared screen or defaults, which could go against third parties?
*01:29:50-01:30:05*

And I also have a question on AI services, because this was also on the list.
*01:30:05-01:30:09*

But maybe I stop here and I keep this question for later, or should I ask it now?
*01:30:09-01:30:15*

Maybe let's keep it for later.
*01:30:15-01:30:16*

Mark Schliebanner from Tala Systems.
*01:30:16-01:30:26*

We have a payment system, Nutala, which is free and open source, which competes with Apple Pay.
*01:30:26-01:30:34*

And we are using NFC to transfer data from one phone to the other to be able to make a payment with digital cash.
*01:30:34-01:30:49*

And Apple's own Tap to Pay app uses a nice and friendly user interface to show the other person that they can pay with it.
*01:30:49-01:31:01*

But in our case, when we try to access NFC, it will show a very ugly user interface here, which is inappropriate for this app, which is enforced by Apple.
*01:31:01-01:31:18*

And we cannot get rid of that.
*01:31:18-01:31:21*

So my question is, why are you enforcing that on your third party apps, but you don't do this on your own app?
*01:31:21-01:31:30*

This side of the room.
*01:31:32-01:31:36*

Yes, please.
*01:31:36-01:31:36*

Go.
*01:31:36-01:31:37*

Hi.
*01:31:37-01:31:42*

Lucas Lasota from the Free Software Foundation.
*01:31:42-01:31:46*

Lucas Lasota from the Free Software Foundation Europe.
*01:31:46-01:31:49*

I'm very glad to be here.
*01:31:49-01:31:51*

I have a question about interoperability and intellectual property rights.
*01:31:51-01:31:57*

I would like to refer to Kyle's statement about interoperability affecting Apple's intellectual property.
*01:31:57-01:32:03*

In both specification decisions, the commission has noted that Apple did not list and specify any concrete IPR being affected by interoperability under 6.7.
*01:32:03-01:32:13*

So our question is, how Apple concretely considers software interoperability under 6.7 affects its copyrights and patents?
*01:32:13-01:32:22*

Thank you.
*01:32:22-01:32:24*

And I will take one more.
*01:32:24-01:32:27*

Ladies, we need ladies here.
*01:32:27-01:32:30*

Thank you.
*01:32:30-01:32:31*

Maria Teresa from the CCIA Europe, a tech trade association representing gatekeepers as well.
*01:32:31-01:32:38*

Amazon is a gatekeeper and a member of the association.
*01:32:38-01:32:42*

Apple is-- sorry.
*01:32:42-01:32:45*

So with reference to the specification decision, I think those are very detailed in how they describe how the company needs to comply with the DMA and also on how the future scrutiny from the commission.
*01:32:45-01:33:02*

At the same time, the commission in Europe have an ambition for Europe to be more competitive, more innovative, to have companies that innovate in here.
*01:33:02-01:33:17*

And the question is, how do you think you can reconcile these two opposite approach to innovation, on the one hand, being very specific, and on the other hand, trying to foster an innovative continent?
*01:33:17-01:33:32*

And at the same time, on privacy and security, is the commission maybe thinking about a way, a solution?
*01:33:32-01:33:41*

I'm sorry.
*01:33:41-01:33:42*

The commission does not take questions.
*01:33:42-01:33:44*

I'm not sure whether that was clear or not.
*01:33:44-01:33:46*

But we will not be taking questions.
*01:33:46-01:33:48*

You can contact us via the address email.
*01:33:48-01:33:52*

So as I said, the decisions are public.
*01:33:52-01:33:54*

So a lot of what you already ask is addressed there.
*01:33:54-01:33:57*

But we will not take the floor here to answer the questions.
*01:33:57-01:34:00*

So really, the workshop, the purpose is for Apple to respond.
*01:34:00-01:34:03*

So one more fifth question, then, please.
*01:34:03-01:34:11*

We'll have several rounds.
*01:34:11-01:34:13*

I'm Gene Burrus.
*01:34:13-01:34:14*

I'm policy counsel for the Coalition for App Fairness, which is an organization of small and medium-sized app developers.
*01:34:14-01:34:23*

The question I've got relates to, it seems like with the goal of leveling the playing field for competitors when they're competing with Apple on Apple's own platform is kind of the purpose of 6.7.
*01:34:23-01:34:36*

The process of requesting and going through a long process seems to have a couple of, I would say, deficiencies in that regard, in that it will forever leave developers a year or two behind Apple's own internal teams when it comes to leveraging features of iOS.
*01:34:36-01:34:58*

And second, your intake process also requires giving potentially competitively sensitive information to the large company with which the developer is attempting to compete under already difficult circumstances.
*01:34:58-01:35:12*

So I wondered if there are ways to fix that problem, both in terms of timing and disclosures.
*01:35:12-01:35:19*

And then secondly, this seems to be driven a lot by the fact that your internal teams have been leveraging non-public APIs and non-disclosed interfaces for a long period of time.
*01:35:19-01:35:32*

And obviously, it will take time to remedy that situation.
*01:35:32-01:35:37*

But the question is whether going forward, there is consideration that you simply restrict your internal teams to using only documented interfaces going forward so that there would literally be no issue at all going forward if those restrictions were put in place on your internal teams.
*01:35:37-01:35:53*

Thanks.
*01:35:53-01:35:54*

Very good.
*01:35:54-01:35:55*

So we have five questions.
*01:35:55-01:35:56*

Sure.
*01:36:00-01:36:02*

Let's hope I get them all right.
*01:36:02-01:36:03*

So in terms of the first question, I think it touches on a really important issue.
*01:36:03-01:36:07*

And I'll ask Gary to weigh in as well, which is how do we think about cybersecurity, safety, privacy in a world where we're being forced to open up access that could create very real risks?
*01:36:07-01:36:23*

There are things that we can do in terms of managing those access points.
*01:36:23-01:36:27*

And that's something we've always done.
*01:36:27-01:36:29*

But usually, it takes a lot longer than a couple of days or a couple of months.
*01:36:29-01:36:32*

So we're being forced to rush through that process here.
*01:36:32-01:36:36*

I think there are also bigger things that we can do to try to mitigate the risks.
*01:36:36-01:36:41*

Unfortunately, we all should recognize that this process will create new risks, that there will be vulnerabilities here in Europe on iOS, on iPadOS that do not exist in other markets.
*01:36:41-01:36:53*

That is simply a fact.
*01:36:53-01:36:54*

And so I think we've got to figure out how to do our very best to mitigate that.
*01:36:54-01:36:59*

I think I keep in the back of my head thinking about what happened last year with CrowdStrike and how it shut down the world for a month.
*01:36:59-01:37:06*

That decision was forced upon Microsoft 10 years ago.
*01:37:06-01:37:09*

I worry about those lurking time bombs that are now being created.
*01:37:09-01:37:14*

But I don't know.
*01:37:14-01:37:14*

Gerard, do you have anything to add?
*01:37:14-01:37:17*

Well, I think it's something we're referring to in our script, Kyle, which is that obviously, we've been highlighting privacy and security issues for some time now in terms of the provisions in the DMA.
*01:37:17-01:37:28*

And I think what we've tried to suggest here is that if you don't believe us-- and you certainly always review what we're saying-- there are many authorities out there, privacy authorities.
*01:37:28-01:37:43*

Obviously, I have a reason to be pointing towards privacy authorities.
*01:37:43-01:37:46*

Haven't worked in one for a very long time, a very long time ago.
*01:37:46-01:37:50*

NISA, and there's a number of other-- the European Data Protection Board, the European Data Protection Supervisor.
*01:37:50-01:37:57*

There are authorities who can assist, bring some perspective to this, and actually indicate what is the right answer in this space.
*01:37:57-01:38:05*

We're not claiming to have the complete right answer, but we think there are others who can assist ensuring that we all can align on what is the right answer in that space.
*01:38:05-01:38:15*

So I think there were two related questions on intellectual property rights.
*01:38:15-01:38:25*

And so obviously, we went through an incredibly quick process when it came to these specifications.
*01:38:25-01:38:32*

There was less than six weeks of engagement before the preliminary decisions came out.
*01:38:32-01:38:37*

There was only a couple of weeks of engagement even after that.
*01:38:37-01:38:40*

So an incredibly compressed time frame to address a host of complicated questions.
*01:38:40-01:38:47*

We have said from the very beginning that we have intellectual property in the form of copyrights, in the form of trade secrets, and in the form of patents that are implicated.
*01:38:47-01:38:57*

Our ability to map all of that to the specific specifications didn't become clear until the very end of the process.
*01:38:57-01:39:04*

But certainly, we have put on notice that there are these copyrights that are out there, there are these trade secrets that are out there, and there are dozens, if not hundreds, of patents implicated here.
*01:39:04-01:39:15*

And so yes, when it comes to the interoperability solutions, we will be, pursuant to the commission's decision, making those available for free.
*01:39:15-01:39:23*

What we will not do, and what we will seek to pursue, is the validation of our intellectual property rights.
*01:39:23-01:39:29*

We are not going to give those away for free.
*01:39:29-01:39:32*

Now, the testing is also an important point.
*01:39:32-01:39:35*

Because I think, again, in our normal process, testing takes time.
*01:39:35-01:39:39*

We are not in a normal process.
*01:39:39-01:39:41*

We're in a bureaucratic process.
*01:39:41-01:39:43*

And so there will be risks associated with that.
*01:39:43-01:39:45*

There are limits to even what the great engineers we have at Apple can do.
*01:39:45-01:39:49*

And so we're going to do as much rigorous testing as possible before these solutions make it to market.
*01:39:49-01:39:55*

But unfortunately, we don't control the deadlines.
*01:39:55-01:39:58*

And so I have no doubt that there will be some issues at some point.
*01:39:58-01:40:02*

But we have committed resources to addressing it.
*01:40:02-01:40:05*

It's true with anything.
*01:40:05-01:40:06*

My friend here was using a beta on iOS 26 that he suggested was causing him troubles with the beeping.
*01:40:06-01:40:13*

That's natural.
*01:40:13-01:40:14*

That happens every time we release a beta, which is why we go through the beta process.
*01:40:14-01:40:19*

There are things, even when we spend years developing software, that we don't expect once it's out in the world.
*01:40:19-01:40:25*

We're not going to have that same ability here.
*01:40:25-01:40:28*

We're being forced to fast track a process that we've never had to do before.
*01:40:28-01:40:33*

And so you have our commitment.
*01:40:33-01:40:34*

We'll do our very best up to that point and afterwards to make sure these things are at the same level of quality, at the same level of expectations that our normal process is.
*01:40:34-01:40:44*

It's simply we're taking years-long process and squeezing it into weeks and months.
*01:40:44-01:40:49*

I don't know if you have anything to add.
*01:40:49-01:40:51*

Yeah.
*01:40:51-01:40:53*

I think there's a reality to our engineering process and anybody that reads the media will understand if those stories are correct that we don't ship everything we work on in the normal course.
*01:40:53-01:41:04*

We work on things.
*01:41:04-01:41:05*

We work through the process.
*01:41:05-01:41:07*

Maybe sometimes they even make them into betas.
*01:41:07-01:41:10*

And then we decide they don't meet our criteria for quality.
*01:41:10-01:41:16*

They don't meet our criteria for privacy and security.
*01:41:16-01:41:19*

There are issues.
*01:41:19-01:41:21*

And then we decide not to ship them.
*01:41:21-01:41:23*

That's actually not going to be a possibility with anything that's included in the connected devices decision.
*01:41:23-01:41:30*

We are actually locked into having to ship these solutions regardless.
*01:41:30-01:41:35*

And so I hope-- maybe referring back to something Kyle mentioned in relation to Microsoft-- I really do hope that when we get to the end of that process, we have something that is suitable for shipping and doesn't have those issues contained within them.
*01:41:35-01:41:48*

And we're just going to have to find that out together as we go through the next-- well, I think it's two years as we work through it, if that is indeed the right period.
*01:41:48-01:41:58*

This is certainly uncharted ground for us to start a process that must end in a particular way.
*01:41:58-01:42:04*

So to address briefly the NFC point, I'll admit that I'm not an expert in this space.
*01:42:04-01:42:12*

And so I'm sure I won't fully answer your question.
*01:42:12-01:42:15*

What I can do is we should talk and make sure we get an answer to your question.
*01:42:15-01:42:20*

What I can say as a general matter, we have opened up access to the NFC pursuant to a separate agreement with the commission that resolved both our competition case and some of the aspects of the DMA.
*01:42:20-01:42:33*

That seems to be working quite well.
*01:42:33-01:42:35*

We know there are dozens, if not hundreds, of developers who are now leveraging that solution across Europe.
*01:42:35-01:42:41*

We also announced as part of the specification decision that we're making further efforts there.
*01:42:41-01:42:45*

If there are gaps, if there are issues, listen, we should talk and figure out what those are.
*01:42:45-01:42:51*

When it comes to the question from Gene, the EPIC representative, I would say a couple of things.
*01:42:51-01:43:00*

One, we make a commitment.
*01:43:00-01:43:02*

This is true before the DMA.
*01:43:02-01:43:04*

We strive every year to make as much of the new technologies that we're developing, as many of the new features as we're developing, available on day one.
*01:43:04-01:43:14*

That happens every year for the last 15 years.
*01:43:14-01:43:18*

There are a handful, a very small handful of examples, where we have not been able to do that on day one.
*01:43:18-01:43:25*

But time and time again, we work to develop a solution that we're comfortable releasing.
*01:43:25-01:43:30*

So take, for example, the visited features and preferred routes example I used in my presentation.
*01:43:30-01:43:38*

Those are things that we're not comfortable releasing now, because of the dangers that there are developers out there that would suck up that data and use it in ways that none of us fully appreciate or anticipate.
*01:43:38-01:43:52*

And it's data that Apple itself doesn't even have available to it.
*01:43:52-01:43:55*

And so I think we're going to continue to be very careful in those respects.
*01:43:55-01:44:00*

Now, going forward, that means we're not going to hold it to ourselves.
*01:44:00-01:44:03*

It means we're not going to release it here in Europe.
*01:44:03-01:44:05*

That's unfortunate.
*01:44:05-01:44:06*

That's not a good outcome.
*01:44:06-01:44:08*

You mentioned concerns around how we might use information we get from developers through this bureaucratic process.
*01:44:08-01:44:17*

Again, we have firewalls in place.
*01:44:17-01:44:19*

And I'll ask Gary to kind of jump in here.
*01:44:19-01:44:21*

We have a number of measures in place to make sure that that information is not shared with other teams within Apple.
*01:44:21-01:44:28*

And that's been true from the very beginning.
*01:44:28-01:44:30*

Apple does not copy developers' ideas.
*01:44:30-01:44:33*

We simply do not.
*01:44:33-01:44:34*

It's never been demonstrated.
*01:44:34-01:44:36*

It's never been proven.
*01:44:36-01:44:37*

So we have a great team within Apple that works on these features and services.
*01:44:37-01:44:43*

It's separate from the team that supports developers, and it always has been.
*01:44:43-01:44:49*

Just a couple of additional points.
*01:44:49-01:44:52*

Gene, I think you asked me that exact question.
*01:44:52-01:44:54*

I'm having flashbacks while-- I say that because I once upon a time managed to team Shorts with interoperability.
*01:44:54-01:45:03*

All right, OK.
*01:45:03-01:45:04*

I think I gave a rather detailed answer on that occasion, which was centered at that point in Article 6(2) of the DMA and the extensive processes we have put in place to comply with it, in addition to the processes we already had in place.
*01:45:04-01:45:18*

In addition to those, you will know that the specification decisions actually go a step further and introduce some very additional requirements.
*01:45:18-01:45:28*

From my perspective, actually just reporting on what we already do.
*01:45:28-01:45:31*

So those are requirements that we're good with.
*01:45:31-01:45:34*

I did also want to pick up the Buick's comment from Alexander.
*01:45:34-01:45:41*

Look, I know that Buick also is deeply concerned about consumers in this.
*01:45:41-01:45:45*

That's your raison d'etre.
*01:45:45-01:45:48*

You care about privacy also.
*01:45:48-01:45:49*

And I think how we communicate with users in relation to something where the experience is going to be fundamentally different is important.
*01:45:49-01:46:00*

And it needs to be done in a balanced and fair manner.
*01:46:00-01:46:02*

Absolutely, that will be the case.
*01:46:02-01:46:04*

But I do think-- and I was trying to refer to it in some of my comments-- that there is something completely different potentially happening here.
*01:46:04-01:46:12*

When you're using your phone, your data is, by and large, on your phone.
*01:46:12-01:46:18*

Your photos are on your phone.
*01:46:18-01:46:19*

You can decide if you want to share them on iCloud, but they're on there.
*01:46:19-01:46:22*

Your location data, as you're moving around, stays on your phone.
*01:46:22-01:46:26*

So you, then, as a user of an iPhone, have an expectation of how that information will be handled.
*01:46:26-01:46:31*

As part of the specification decisions-- and I referred to it somewhat briefly with the Wi-Fi history one, but there's many other examples-- it is very important that a user knows that this is going to be different if it's going to a third party.
*01:46:31-01:46:45*

If it's going to a third party, it's leaving your phone.
*01:46:45-01:46:48*

It's going to servers.
*01:46:48-01:46:50*

And once it goes to a server, the experience is going to be different.
*01:46:50-01:46:53*

And I think it's important that a user understands that.
*01:46:53-01:46:56*

Now, of course, we will ensure-- and we'll be working closely with the commission to ensure that that is understood in an easy-to-access, understandable way for users.
*01:46:56-01:47:04*

That's absolutely the case.
*01:47:04-01:47:05*

But it is a very important point for-- and I think it should be an important point for everybody, and something which I will refer to probably a little bit later on again, that we cannot have the DMA become synonymous with an undermining of privacy.
*01:47:05-01:47:20*

And I will say, in that area, that is something where we have seen some good input from the commission as to how to manage that in a sensible way.
*01:47:20-01:47:29*

Thank you.
*01:47:29-01:47:30*

We'll take a couple of questions from Slido, and then I will come back to the room.
*01:47:30-01:47:33*

So we have a question from Mark Dempsey.
*01:47:33-01:47:43*

Over time, it should make little sense for Apple to maintain separate interrupt solutions, one for its own products and services, and another one for third parties.
*01:47:43-01:47:54*

Do you intend for interrupt by design for all new features to comply properly with Article 6.7?
*01:47:54-01:48:01*

That's the first question.
*01:48:01-01:48:02*

Second question is-- question by Sagar Yaa.
*01:48:02-01:48:20*

Apple sometimes blocks requests because they believe the interoperability requests cannot be implemented securely.
*01:48:20-01:48:27*

Has Apple ever shared details of how they arrive at such a conclusion?
*01:48:27-01:48:32*

Do they take third party-- Sorry, Lucy.
*01:48:32-01:48:34*

I'm not hearing the names of the people who are asking the questions.
*01:48:34-01:48:37*

Sagar Yaa.
*01:48:37-01:48:39*

All right, so there's no affiliation.
*01:48:39-01:48:40*

No, there is an affiliation here.
*01:48:40-01:48:43*

So yes, I will say, please, for the next round of Slido, also please put the affiliation so that there is a full transparency.
*01:48:43-01:48:50*

I'm sorry, was there a name of the first one?
*01:48:50-01:48:52*

Other than Slido?
*01:48:52-01:48:52*

First one was Mark Dempsey.
*01:48:52-01:48:55*

That, I think, is Article 19.
*01:48:55-01:48:57*

Article 19.
*01:48:57-01:48:58*

Yes.
*01:48:58-01:49:00*

So have you heard this question, then, or should I repeat?
*01:49:00-01:49:02*

No, I think we heard it.
*01:49:02-01:49:04*

So has Apple ever shared details of how they arrive at such a conclusion?
*01:49:04-01:49:08*

Do they take third party input on how to resolve security and privacy concerns?
*01:49:08-01:49:12*

Hold on, and one more.
*01:49:12-01:49:19*

By Ian Brown, does Apple commit to rolling out its foundation models and other frameworks around the world, not just to the European Economic Area residents, like many other gatekeeper compliance responses?
*01:49:22-01:49:37*

I think that's fine for now, so let's take these three.
*01:49:37-01:49:39*

Yeah.
*01:49:40-01:49:41*

All right, let's take those.
*01:49:41-01:49:46*

So I think as a response to the first question, we have made a commitment long before the DMA to make our technologies and features on the iPhone and the operating system available to third parties.
*01:49:46-01:50:00*

We have done that year after year after year.
*01:50:00-01:50:04*

There are some instances in which we are concerned, whether from a security or privacy perspective, that we're going to unleash a whole host of different problems.
*01:50:04-01:50:14*

I'll also say that Apple is different than every other company out there in the sense that we are integrated.
*01:50:14-01:50:21*

It is one of our strengths.
*01:50:21-01:50:23*

We have always believed that the very best products are built when you're all in the same room, in the same building, creating a product, as opposed to just the hardware components, just the design, just the operating system, just the services.
*01:50:23-01:50:40*

And I think our track record of quality, our track record of user appreciation and enjoyment is unmatched in the industry.
*01:50:40-01:50:50*

And we attribute that in large part to the fact that we are an integrated company.
*01:50:50-01:50:56*

That's not something that's new.
*01:50:56-01:50:58*

We didn't buy somebody and become integrated.
*01:50:58-01:51:00*

That has been a philosophy that Apple has had for nearly 50 years.
*01:51:00-01:51:05*

And we don't see the DMA as saying, you need to fundamentally break up your company into bits and parts.
*01:51:05-01:51:12*

Now, we face some pretty aggressive competition out there.
*01:51:12-01:51:16*

It's a lot cheaper and a lot easier to kind of bolt all of this together.
*01:51:16-01:51:20*

But again, as I said at the outset, the goal shouldn't simply be, let's go down to the least common denominator.
*01:51:20-01:51:25*

Let's just have a generic set of hardware.
*01:51:25-01:51:28*

Let's just have a generic set of operating systems.
*01:51:28-01:51:31*

Let's just build it that way.
*01:51:31-01:51:33*

Those options exist out there.
*01:51:33-01:51:34*

In fact, they do quite well.
*01:51:34-01:51:36*

What we do is offer something different, special, and unique.
*01:51:36-01:51:41*

In terms of how do we think about security and privacy as we design these solutions-- and I'll ask Gary to weigh in on those.
*01:51:41-01:51:51*

Listen, Apple-- I mean, this is not just words.
*01:51:51-01:51:53*

We have hundreds of engineers whose only job is to focus on how do we secure our platform.
*01:51:53-01:52:00*

How do we make sure that it is the very best?
*01:52:00-01:52:03*

And I think if you look at study after study after study, this is not an accident.
*01:52:03-01:52:07*

This is because we've invested in these engineers, in these people, the very best in the world, to think about how do we make sure that our platform isn't going to have the same problems we see with other operating systems?
*01:52:07-01:52:20*

How can we ensure leading-edge security?
*01:52:20-01:52:23*

How can we ensure leading-edge privacy?
*01:52:23-01:52:25*

How can we ensure that the device actually works?
*01:52:25-01:52:29*

And this is really hard work.
*01:52:29-01:52:32*

And so now that we're being asked to open up things that would take us time to, we're having to ask even more of that team.
*01:52:32-01:52:40*

And every single one of these requests, particularly if we can see it, go straight to that security team.
*01:52:40-01:52:46*

We ask them, what do you see?
*01:52:46-01:52:47*

If we do x, if we do y, if we do z, what happens?
*01:52:47-01:52:52*

What risks are we creating?
*01:52:52-01:52:55*

How can we mitigate those risks?
*01:52:55-01:52:57*

It's an ongoing, continuous conversation.
*01:52:57-01:53:00*

And I'll say, in this environment, where we have very short deadlines, people are working around the clock.
*01:53:00-01:53:06*

There have been more all-nighters pulled at Apple than, I think, since the early days of the iPhone and iPad, to try to make sure that we're doing our very best to protect our users.
*01:53:06-01:53:14*

Wow, it's kind of hard to-- and that does reflect the reality of how we review each and every request.
*01:53:14-01:53:26*

I think you made a point, Kyle, in relation to the number of engineers that we have.
*01:53:26-01:53:31*

And we do have the world's best engineers in this space.
*01:53:31-01:53:34*

But those engineers are actually told from the very top of our company how important it is that they do their jobs.
*01:53:34-01:53:40*

Every other engineer understands how important it is that the privacy and security considerations are part of every single thing we do.
*01:53:40-01:53:48*

There is, therefore, no reason why requests that come as part of an interoperability process will be handled in any way differently.
*01:53:48-01:53:55*

That wouldn't make any sense to us if we work on things.
*01:53:55-01:53:59*

I did also want to address the question from Article 19.
*01:53:59-01:54:03*

Article 19 is an organization that I have a huge amount of respect for from a privacy perspective.
*01:54:03-01:54:09*

It's an organization that has made extreme and strong inputs to protect users' data.
*01:54:09-01:54:18*

It's a strong supporter of end-to-end encryption.
*01:54:18-01:54:20*

In fact, also, and for that, we appreciate their support.
*01:54:20-01:54:24*

I do think in terms of how we develop interoperability solutions, there is just a reality.
*01:54:24-01:54:29*

The reality is that data needs to be handled in a particular way when it is either stored on your device, or if it's leaving your device, it leaves in an end-to-end encrypted manner as it syncs across your different devices so that you can have a great experience, or if that data is collected with random identifiers such that we as Apple cannot link to it.
*01:54:29-01:54:52*

Of course, we're going to look at different solutions where necessary, or at least think about how we do it, if that exact same data or experience is going to have to be made available in those circumstances to third parties.
*01:54:52-01:55:04*

That's just reality of what we need to work on.
*01:55:04-01:55:07*

I think that's crucially important for all of us as we do that, that we put the time and effort into examining, first of all, can we use the same solution?
*01:55:07-01:55:15*

If that solution is not going to work because of the security framework that benefits everybody, then we need time to work out what is a equivalent or next best solution that might be available.
*01:55:15-01:55:30*

Thank you.
*01:55:30-01:55:31*

So back to the room.
*01:55:31-01:55:32*

I will recall name, affiliation.
*01:55:32-01:55:35*

Please, let's keep the questions to the point, and maybe also the answers, so that we have an opportunity, the main people get opportunity.
*01:55:35-01:55:42*

John, you've been very patient.
*01:55:42-01:55:44*

Hi there.
*01:55:44-01:55:45*

First, I would like to thank the European Commission for having us here.
*01:55:45-01:55:48*

It's good to be here.
*01:55:48-01:55:50*

And it's good to see you both again, Kyle and Gary.
*01:55:50-01:55:53*

Thanks for joining us.
*01:55:53-01:55:54*

To Gary, it was good to hear you quote Steve Jobs.
*01:55:54-01:55:58*

Funnily, at the launch event of iPhone, he also said the feature of the iPhone is web apps.
*01:55:58-01:56:03*

But we'll talk more about that later today.
*01:56:03-01:56:05*

First off, during today's workshop, when we say iOS, we'll also be referring to iPadOS.
*01:56:05-01:56:10*

As for all practical purposes, they're the same.
*01:56:10-01:56:13*

I'm going to be talking about the tracking system.
*01:56:13-01:56:16*

Apple's compliance with Article 6.7 of the DMA has been plagued with problems ever since the law came into effect more than 15 months ago.
*01:56:16-01:56:24*

As developers, we have faced long delays, an unclear process, and no visibility into the status of our requests.
*01:56:24-01:56:31*

So a little bit of transparency would be amazing.
*01:56:31-01:56:33*

And by that, I don't mean making the entirety of iOS 26 see-through, which I'm sure went through the same rigorous testing process Kyle mentioned.
*01:56:33-01:56:42*

But that's a topic for another day.
*01:56:42-01:56:44*

Things got so bad that the commission had to launch a formal specification proceeding just to spell out exactly what Apple needed to do.
*01:56:44-01:56:52*

And in that proceeding, the commission made it clear if Apple wants to run a request-based system, it must meet basic standards.
*01:56:52-01:56:59*

That includes short response timelines, a clear process with deadlines for Apple, proper explanations when a request is rejected, and a public searchable tracker showing the status of all requests accessible to any developer.
*01:56:59-01:57:12*

Now, none of this is difficult. And Apple already runs public GitHub trackers for other projects.
*01:57:12-01:57:17*

They could have done the same here, or built something custom with the brilliant engineers they have.
*01:57:17-01:57:22*

But instead-- and this is the genuinely bizarre part-- they chose to publish a PDF, a static document updated once a week, hidden behind a hard-to-find link, no search, no comments, no filtering, or no interactivity.
*01:57:22-01:57:34*

So our question is this.
*01:57:34-01:57:36*

Does Apple believe that a static PDF meets the very clear requirements laid out by the commission?
*01:57:36-01:57:41*

Thank you.
*01:57:41-01:57:43*

Thank you.
*01:57:43-01:57:44*

Please.
*01:57:44-01:57:46*

Thank you.
*01:57:46-01:57:46*

Mike-- Thank you.
*01:57:46-01:57:52*

Mike Sax from ACT, the App Association.
*01:57:52-01:57:54*

We are a trade association.
*01:57:54-01:57:56*

Apple is a sponsor.
*01:57:56-01:57:57*

We represent SME app developers, actual SMEs.
*01:57:57-01:58:02*

Some of them are in this room, and I hope they also get to ask their questions.
*01:58:02-01:58:07*

I have a question about the interoperability around notifications and Wi-Fi network sharing, automatic Wi-Fi.
*01:58:07-01:58:17*

Our customers, a lot of our friends, our family, are not security experts, nor should they be.
*01:58:17-01:58:23*

So sharing your Wi-Fi networks actually has a lot of implications about what other private information you are revealing.
*01:58:23-01:58:33*

How are you going to make sure that people are fully aware of what kind of consent or permission they're giving and what the implications of that are?
*01:58:33-01:58:42*

And also, I think permission fatigue is a concern.
*01:58:42-01:58:47*

We don't want people just clicking yes through things without fully realizing what they're doing, because without actual informed consent, those prompts actually could be dangerous.
*01:58:47-01:59:02*

So what are you doing to make sure that people are fully aware of the implications of the permissions that they're giving and who that information will be shared and what it will be used for?
*01:59:02-01:59:16*

Thank you.
*01:59:16-01:59:18*

Please.
*01:59:18-01:59:19*

Hi.
*01:59:19-01:59:23*

Christian Conrad is the name.
*01:59:23-01:59:24*

I'm working for a company called LanguageTooler, which is a German AI company.
*01:59:24-01:59:29*

And we offer an intelligent writing assistant that helps people to communicate better.
*01:59:29-01:59:35*

So with Apple Intelligence, as we saw it on a slide, Apple did their own take on such writing assistant.
*01:59:35-01:59:42*

And this writing assistant is very much-- enjoys deep integration into the operating system, like into the keyboard.
*01:59:42-01:59:52*

But also, third-party developers get the tools at their hand to trigger this system capability.
*01:59:52-02:00:01*

We, as a third-party company, do not have access to those services in order to offer our services, which obviously poses a significant competitive disadvantage for us.
*02:00:01-02:00:14*

So my question is, does Apple plan to enable the integration of-- or the better integration of third-party language checkers into their system, for example, by a choice screen, like for the default browser or like we recently saw with the default translator app?
*02:00:14-02:00:30*

Does Apple think it's obligated by the DMA to do so?
*02:00:30-02:00:34*

And if not, maybe why?
*02:00:34-02:00:35*

Thank you.
*02:00:35-02:00:38*

Hey, we have a winner.
*02:00:43-02:00:46*

Hi, my name is Mike Griffin.
*02:00:46-02:00:47*

I'm from MyPrintPod, which is a UK company which takes recycled plastic and solar power and 3D prints useful components.
*02:00:47-02:00:56*

And we are an Apple developer as well.
*02:00:56-02:00:59*

We're a member also of the Acts Association, with Mike here.
*02:00:59-02:01:02*

So the question is around interrupt requests.
*02:01:02-02:01:05*

Basically, you seem to have-- it seems to be quite manageable.
*02:01:05-02:01:08*

But at what point-- how do you stop a free-for-all on the interrupt requests right now it seems manageable?
*02:01:08-02:01:14*

I can easily see that it will grow to a point where it will not be.
*02:01:14-02:01:17*

And what will you do?
*02:01:17-02:01:20*

Very good.
*02:01:20-02:01:21*

One last one, please.
*02:01:21-02:01:24*

Hi, I'm Clement from France.
*02:01:24-02:01:25*

I'm from BNC Consulting, creating apps for startups and luxury brands.
*02:01:25-02:01:29*

First part of the question is, as an iPhone user, we all consider our iPhones as extensions ourselves.
*02:01:29-02:01:36*

And we all have banking and mutual insurance apps, for example.
*02:01:36-02:01:39*

How you see a private way to secure notification to avoid third parties, including some of the gatekeepers, to store and possibly sell those data, like salary received and refunding for hospitalization, or so on?
*02:01:39-02:01:53*

Second part is, being an app developer for something like almost 20 years now, how do you have estimates on bad actors from side loading?
*02:01:53-02:02:01*

I remember Steve Jobs wanting freedom of porn in the world.
*02:02:01-02:02:06*

And one of the most successful side store is a porn one.
*02:02:06-02:02:10*

And the last one is about DMA itself and your relation with the EC.
*02:02:10-02:02:16*

You are telling that you're being treated unfairly compared to other providers.
*02:02:16-02:02:20*

Is there a matrix we can see to verify this?
*02:02:20-02:02:24*

Very good.
*02:02:24-02:02:25*

Kyle?
*02:02:25-02:02:27*

So I'll take some of this, and then I'll turn it over to my much more steeped colleague, Gary, to answer some of the particulars.
*02:02:27-02:02:34*

I think one observation I'll make is there's this belief that we can do everything all at once, that we have unlimited resources.
*02:02:34-02:02:45*

And I recognize financially we do very well.
*02:02:45-02:02:49*

But we also-- the resources around talented engineers, talented business people is finite.
*02:02:49-02:02:57*

And so we have developed a process that complies with the bureaucratic mandates here, and we'll continue to enhance it and listen to feedback.
*02:02:57-02:03:07*

Over time, I think in terms of the free for all that the gentleman from Printport mentioned, this is a concern.
*02:03:07-02:03:18*

The bureaucratic process could lead us to be distracted from what we think is the core that serves all of our developers.
*02:03:18-02:03:26*

Our focus has always been on making sure that we're developing new technologies and features and providing access in a responsible way that can unlock new opportunities for developers.
*02:03:26-02:03:37*

We're constantly coming up with new ideas.
*02:03:37-02:03:40*

With this process, where there might be a niche solution that may benefit one or two developers that may serve five or 10 users, but nonetheless it's got to be treated as the same way as a technology or feature that benefits thousands, millions, tens of millions, hundreds of millions, that troubles me deeply, very deeply.
*02:03:40-02:04:04*

Like I said, the resources that do this work, if it was just a matter of throwing dollar bills at it, we could do it.
*02:04:04-02:04:12*

But people are not dollar bills.
*02:04:12-02:04:14*

Engineers are not dollar bills.
*02:04:14-02:04:16*

Engineers are finite resources.
*02:04:16-02:04:19*

And so we want them focused on the very best things going forward.
*02:04:19-02:04:23*

Unfortunately, we're going to be distracted by building some of these other things.
*02:04:23-02:04:27*

It's just simply a fact of life in this world, at least for now.
*02:04:27-02:04:32*

In terms of thinking through some of what's happened over the last year, yes, with side loading, we obviously have seen the most successful apps are ones like pornography.
*02:04:32-02:04:47*

We've seen apps out there that infringe on other developers' intellectual property.
*02:04:47-02:04:53*

We have seen other things that, frankly, concern us.
*02:04:53-02:04:57*

We're still in the early days.
*02:04:57-02:04:58*

I think we've got about seven, eight, nine different marketplaces.
*02:04:58-02:05:02*

Some of them are totally legitimate.
*02:05:02-02:05:04*

Some are at the edge.
*02:05:04-02:05:06*

And we do have concerns with what that's going to look like going forward and what other apps we might see.
*02:05:06-02:05:13*

But this is still a place to watch.
*02:05:13-02:05:15*

And I'll say on the relationship with the EC, I think it's a constructive one.
*02:05:15-02:05:22*

We'll continue to work with them to make sure we're fully transparent around our concerns and issues.
*02:05:22-02:05:29*

And we've seen-- I would not say it's always adversarial or we're always on polar opposites.
*02:05:29-02:05:34*

We do reach a meeting of the minds more often than we don't.
*02:05:34-02:05:38*

And I think this work will continue going forward.
*02:05:38-02:05:40*

And I think it's important for everyone.
*02:05:40-02:05:42*

There needs to be a balanced set of feedback to the commission.
*02:05:42-02:05:45*

I think sometimes the squeaky wheel gets all the attention.
*02:05:45-02:05:48*

I always think to myself, there are millions of developers out there.
*02:05:48-02:05:54*

We shouldn't just focus on the same five or six over and over and over again.
*02:05:54-02:05:58*

But to do that, I think those voices have to be heard.
*02:05:58-02:06:01*

Yeah, I'll pick up some of those.
*02:06:01-02:06:06*

I presumably see this the last round of questions for now?
*02:06:06-02:06:10*

Or what's the plan?
*02:06:10-02:06:11*

Is this it?
*02:06:11-02:06:13*

There's another round?
*02:06:13-02:06:14*

OK.
*02:06:14-02:06:15*

All right.
*02:06:15-02:06:15*

OK.
*02:06:15-02:06:16*

That's fine.
*02:06:16-02:06:16*

To the point, yes, please.
*02:06:16-02:06:17*

Yeah, back now.
*02:06:24-02:06:25*

OK, let's try and take some of the points at random.
*02:06:25-02:06:29*

I think, John, you focused on the interoperability request tracker.
*02:06:29-02:06:36*

That caused me to think about the 18th of September.
*02:06:36-02:06:39*

That was when the specification decision process was launched.
*02:06:39-02:06:43*

Then that caused me to think about somewhere around about the end of November when we had finalized the initial exchanges with the commission.
*02:06:43-02:06:51*

Then I had deep thoughts about the 18th of December when the preliminary findings were published.
*02:06:51-02:07:00*

And then we had a further round of detailed discussions with the commission.
*02:07:00-02:07:07*

And that then caused the 18th of March to emerge in my psyche, which is a very expedited timeline.
*02:07:07-02:07:16*

And I was one of those many people who had sleep deprivation over that period of time as well because of the unique-- together with commission colleagues, I should say-- because of the unique deadline that was placed upon us.
*02:07:16-02:07:29*

And then the next deadline after the 18th of March was the 18th of May in order to start publishing material.
*02:07:29-02:07:35*

Now, we are amazing at what we do.
*02:07:35-02:07:38*

We can do amazing things.
*02:07:38-02:07:40*

But achieving a fantastic solution against those deadlines while trying to comply with the obligations placed upon us causes some practical realities.
*02:07:40-02:07:51*

We set out to comply.
*02:07:51-02:07:53*

We did something that was the absolute best we could achieve in that short timeline.
*02:07:53-02:07:58*

And of course, we will be looking as we go along to enhance it as we do with everything we work on.
*02:07:58-02:08:04*

It is also available to all developers.
*02:08:04-02:08:06*

Just log in to App Store Connect to access it.
*02:08:06-02:08:11*

In terms then of-- I think the next question was Mike from ACT.
*02:08:11-02:08:18*

Yeah, so I think we've already addressed the Wi-Fi and notifications issue.
*02:08:18-02:08:22*

I think I've outlined the views we have in relation to striking a balance there.
*02:08:22-02:08:28*

I think permission fatigue is an issue.
*02:08:28-02:08:31*

I think it's one we all have to grapple with.
*02:08:31-02:08:33*

Certainly, as a former privacy regulator, I'm not going to say there shouldn't be permissions and we have to get the balance right.
*02:08:33-02:08:40*

I'm certainly wanting to advocate for permissions that inform users.
*02:08:40-02:08:45*

And I think in one of my earlier responses, I've already indicated that I think one of the issues that exist in this space is that we're failing to distinguish between what happens when Apple devices have access to data or they're sharing it over end-to-end encryption and when, in fact, a third party is going to use it for different purposes.
*02:08:45-02:09:04*

And I really hope we can arrive at a view of how to manage that in a way that provides the kind of connectivity that's been sought, which I believe is there, but also does not, in the rush to do so, undermine privacy and security.
*02:09:04-02:09:20*

I think there was a question then in relation to writing tools and how it's available.
*02:09:20-02:09:26*

So writing tools is a feature of iOS.
*02:09:26-02:09:30*

We have enabled alternative keyboards via the Keyboards Extension API, which we see a number of developers engaging in.
*02:09:30-02:09:41*

I think, Mike, you had a question in relation to what would we do if we got overrun by the requests coming in.
*02:09:41-02:09:51*

Well, I think I would be wanting to talk to my colleagues who are sitting here with me as well, because obviously, there has to be reasonableness on all sides.
*02:09:51-02:09:58*

We approach these issues to come up with solutions.
*02:09:58-02:10:01*

We have extremely tight deadlines on us.
*02:10:01-02:10:05*

We endeavor to meet them.
*02:10:05-02:10:06*

But obviously, that's all taken account of what I might say is a Chetris Paribus situation, with everything staying roughly as it is today.
*02:10:06-02:10:17*

And then I think Clement and I think Kyle addressed this already.
*02:10:17-02:10:22*

In terms of the metrics of how should we think about iOS and iPadOS compared to other platforms in relation to sideloading, well, I think the Nokia Threat Intelligence Report is the industry standard in that space.
*02:10:22-02:10:37*

And that is a report that does highlight a huge difference between the threats faced by users of iOS compared to Android, far lower on iOS, because of the nature of how we've architected it over 20 years with the help of people such as yourself.
*02:10:37-02:10:55*

I think there was one final point, Kyle, which was the metrics of how we are being unfairly treated compared to other developers, which perhaps are other gatekeepers.
*02:10:55-02:11:07*

I think that's a really important question, Gary.
*02:11:07-02:11:10*

And I think-- thank you for reminding me.
*02:11:10-02:11:12*

I think it's pretty easy to go publicly and look at how we're being treated versus other operating systems, compare what they've said they will do versus what we are being asked to do.
*02:11:12-02:11:23*

And there are massive differences.
*02:11:23-02:11:25*

There are differences when it comes to interoperability.
*02:11:25-02:11:28*

There are differences when it comes to browsers.
*02:11:28-02:11:30*

There's differences when it comes to data portability.
*02:11:30-02:11:33*

There are differences when it comes to Article 5.4 and steering across the board.
*02:11:33-02:11:38*

It is clear by objective public evidence that there are two different standards at play.
*02:11:38-02:11:44*

There's a standard for Apple, and there's a standard for everybody else.
*02:11:44-02:11:50*

Thank you.
*02:11:50-02:11:50*

We will take three last questions from the Slido.
*02:11:50-02:11:54*

So we have one by Bruce Lawson, Vivaldi Tech.
*02:11:54-02:12:00*

In November '24, I sent an interop request for all the browser engines to read iOS parental control settings.
*02:12:00-02:12:08*

In March, Apple said, this is a mild engineering effort we plan to complete by March 2026.
*02:12:08-02:12:17*

The question is, is 16 months for a mild effort fast enough?
*02:12:17-02:12:22*

So that's one question.
*02:12:22-02:12:23*

Then question by Fideszmon, when will secure element access be available?
*02:12:23-02:12:28*

Apple Pay is using secure element, and the NFC pay availability you provided is not using the secure element.
*02:12:28-02:12:35*

So you are not providing the same functionality for developers as you use yourself.
*02:12:35-02:12:41*

And third one, Ian Brown, if Apple is so concerned about ambiguity in the DMA, does it welcome the EC's very detailed specifications to clarify key aspects?
*02:12:41-02:12:53*

Would it welcome many further such specifications under the DMA?
*02:12:53-02:12:58*

[AUDIO OUT]
*02:12:58-02:13:03*

All right, I'm going to do my best to answer this after two hours and 45 minutes.
*02:13:03-02:13:10*

So on the first question, like I said, we are working through a number of different requests.
*02:13:10-02:13:18*

Some of those are very simple, and we get solutions out very quickly.
*02:13:18-02:13:22*

Others are more complex.
*02:13:22-02:13:24*

When you're talking about parental controls, you're talking about tools that are used to protect children.
*02:13:24-02:13:31*

Those are not tools that we are going to simply rush through and see what happens.
*02:13:31-02:13:37*

There are going to be different standards here in terms of what we're being asked to provide.
*02:13:37-02:13:41*

If we think children are going to be at risk, whether it's through manipulative or deceptive advertising techniques or other things on our platform that puts them at risk, we're going to be very careful about developing those solutions.
*02:13:41-02:13:56*

In terms of SE access, I would point to the fact that we reached an agreement with the European Commission to launch an HCE solution.
*02:13:56-02:14:08*

I should note this is a solution that Apple itself doesn't use.
*02:14:08-02:14:13*

We launched this solution working with the commission, working with third parties, because what we heard consistently was this is the solution that the payment industry was looking for.
*02:14:13-02:14:23*

And so we have complied with that aspect of the DMA.
*02:14:23-02:14:26*

In terms of ambiguity, I think what we welcome is speedy judicial review of these decisions.
*02:14:26-02:14:35*

We think the ambiguity in the law is so significant.
*02:14:35-02:14:38*

And we recognize that the commission has taken its positions, in some cases we think extreme positions, that we hope can be tested as quickly as possible by the European courts.
*02:14:38-02:14:49*

It's unfortunate, very unfortunate, that we're going to have to wait years, in some cases, for the courts to weigh in.
*02:14:49-02:14:55*

But we are going to, given the ambiguity of the law, the extreme interpretations out there, pursue our legal rights to ensure that we get clarity.
*02:14:55-02:15:05*

The commission should not be the final word on what the DMA means.
*02:15:05-02:15:08*

It is not the final word.
*02:15:08-02:15:09*

The courts are.
*02:15:09-02:15:11*

And we're going to be looking forward to getting some of that guidance from the courts.
*02:15:11-02:15:15*

Gary, anything?
*02:15:15-02:15:17*

Maybe just one small point on the mild engineering efforts.
*02:15:17-02:15:23*

That's not a term that we would use, of course, in the normal course.
*02:15:23-02:15:27*

That's a term that was introduced by the specification decision.
*02:15:27-02:15:31*

So we are required to indicate efforts as mild, medium, and significant.
*02:15:31-02:15:38*

And so the actual engineering effort was mild.
*02:15:38-02:15:42*

It still takes considerable time.
*02:15:42-02:15:43*

As Kyle indicated, we have to do it in a way that takes full respect of the risks that arise in that space.
*02:15:43-02:15:53*

Very good.
*02:15:53-02:15:54*

So with this, I propose we close this session on interoperability.
*02:15:54-02:15:58*

Thank you very much, Apple, for presenting your solutions.
*02:15:58-02:16:03*

Thank you, everyone in the room.
*02:16:03-02:16:05*

Given that we have a slight delay, I would propose we cut the break to 15 minutes and we'll try to be back at noon sharp so that the next session doesn't suffer too much from the delay.
*02:16:05-02:16:17*

We will, of course, extend, if needed, the next session.
*02:16:17-02:16:22*

But let's please be back by noon.
*02:16:22-02:16:24*

Thank you.
*02:16:24-02:16:25*

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*02:32:12-02:32:13*

Welcome back.
*02:32:13-02:32:16*

Welcome back to the second session on a very interesting topic.
*02:32:16-02:32:25*

Hello, the room.
*02:32:25-02:32:29*

This is not working, is it?
*02:32:29-02:32:30*

Is this working?
*02:32:30-02:32:33*

Can you hear me?
*02:32:33-02:32:34*

No.
*02:32:34-02:32:36*

Can you hear me now?
*02:32:36-02:32:37*

Can you hear me?
*02:32:37-02:32:42*

No.
*02:32:42-02:32:45*

Can you hear me?
*02:32:45-02:32:46*

No.
*02:32:46-02:32:47*

Can you hear me now?
*02:32:47-02:32:48*

No, but if they-- can you hear me?
*02:32:48-02:32:52*

OK, I'm starting to think that app stores are not interesting.
*02:32:52-02:32:57*

You can hear me now.
*02:32:57-02:32:58*

Excellent.
*02:32:58-02:32:59*

Thank you very much.
*02:32:59-02:33:00*

Thank you for being back to the room only four minutes-- three minutes behind.
*02:33:00-02:33:04*

So we'll try to catch up a little bit the delay while keeping the minutes of the sessions as planned in the agenda.
*02:33:04-02:33:15*

So I will invite very quickly my colleague Luben Karbachev to present the commission work on app stores.
*02:33:15-02:33:26*

Then it will be Apple's turn.
*02:33:26-02:33:27*

And I invite both Luben and Apple to keep to the time allocated so that we can have the Q&A as planned.
*02:33:27-02:33:35*

But I think it's already clear that the lunch will start a little bit later.
*02:33:35-02:33:39*

So I hope you grabbed whatever you needed in the break.
*02:33:39-02:33:42*

Thank you.
*02:33:42-02:33:43*

Luben, the floor is yours.
*02:33:43-02:33:46*

Thank you, Lucia.
*02:33:46-02:33:48*

Good afternoon, everyone.
*02:33:48-02:33:50*

So as Lucia mentioned, this session will focus on the first year of Apple's DMA compliance with Article 5.4, or otherwise known as the so-called anti-steering prohibition.
*02:33:50-02:34:02*

So I think this is how you-- I'm just checking if it works with the slides.
*02:34:02-02:34:06*

Yes, perfect.
*02:34:06-02:34:07*

So you have, as you can see on the screen, the rather lengthy text of the provision.
*02:34:07-02:34:13*

It reads as follows.
*02:34:13-02:34:14*

So the gatekeeper shall allow business users, free of charge, to communicate and promote offers, including under different conditions, to end users acquired by its core platform service or to other channels, and to conclude contracts with those end users, regardless of whether for that purpose they use the core platform service of the gatekeeper.
*02:34:14-02:34:35*

So as you know, on the 23rd of April, the commission adopted a noncompliance decision against Apple regarding its compliance with that provision.
*02:34:35-02:34:44*

You can find the commission's interpretation of this provision in more detail in the decision, which is published on our DMA website.
*02:34:44-02:34:54*

But for now, I'm going to move on to what the noncompliance decision orders Apple to do.
*02:34:54-02:35:04*

So first, the decision orders Apple to bring the noncompliance to an end within 60 days and to refrain from repeating any conduct constituting noncompliance with Article 5(4), as well as from any conduct having the same or equivalent object or effect.
*02:35:04-02:35:23*

The commission also sets out measures that Apple needs to take to ensure compliance with the commission's decision within 60 days, in particular to ensure effective steering and conclusion of contracts free of charge.
*02:35:23-02:35:37*

So these require Apple to first to ensure that app developers are allowed technically and contractually to engage in any form of communication, promotion of offers, and conclusion of contracts following steering with end users, both within and outside the app.
*02:35:37-02:35:57*

Second, Apple is required to ensure that both the communication and promotion of offers and the conclusion of contracts following steering with end users acquired through the app store is free of charge.
*02:35:57-02:36:09*

And third, Apple is required to ensure that any potential remuneration for facilitating the initial acquisition of end users by the app developers is related first to the initial acquisition only.
*02:36:09-02:36:23*

Second, is commensurate to the value of the initial acquisition, and also must take into account any other direct or indirect remuneration received from business users for facilitating the initial acquisition, and also does not remunerate the gatekeeper for gatekeeper value.
*02:36:23-02:36:42*

Apple is also prohibited from imposing any other fee, in addition to a potential fee for initial acquisition that covers services linked to the acquisition of end users.
*02:36:42-02:36:52*

So moving to the final slide, as you may have seen last week on 26th of June, Apple published the measures it has implemented to comply with the commission's decision.
*02:36:52-02:37:07*

This includes revised contractual terms for developers.
*02:37:07-02:37:11*

You can see the summary here on the screen.
*02:37:11-02:37:13*

The commission is currently assessing the solution, so the assessment is ongoing.
*02:37:16-02:37:22*

But nonetheless, the commission already invites feedback from interested parties.
*02:37:22-02:37:28*

And with this introduction, I want to pass it forward to Apple, which will present in more detail the measures it has taken to comply with the non-compliance decision.
*02:37:28-02:37:37*

The floor is yours.
*02:37:37-02:37:38*

Great.
*02:37:38-02:37:41*

Thank you, Lubin, Thomas, Dennis, Antoine.
*02:37:41-02:37:43*

It's been a full four days since I saw you.
*02:37:43-02:37:46*

There's been something missing in my life, so I feel more complete.
*02:37:46-02:37:51*

Everyone else, welcome back.
*02:37:51-02:37:54*

I'm sure everyone is aware, and as Lubin just outlined, last week we announced and implemented a plan to comply with the decision issued by the commission in April.
*02:37:54-02:38:05*

We also announced a number of other changes that we believe resolve the commission's investigation to our new business terms and approach to 6/4.
*02:38:05-02:38:13*

Let me say at the outset that we believe these changes go beyond what the law requires, and in some cases, well beyond.
*02:38:13-02:38:21*

And we will see clarity on our legal obligations in court.
*02:38:21-02:38:25*

But our focus today is not on those kinds of future legal judgments, but rather on the solutions that implement the commission's mandates and that will be in the market here in the EU for the foreseeable future.
*02:38:25-02:38:37*

I think it's important to take a step back to reiterate our deep commitment to an open and constructive dialogue with the commission.
*02:38:37-02:38:46*

Throughout this process, over the last two years, we have tried our best to listen to the commission's feedback and implement their requirements.
*02:38:46-02:38:54*

In particular, I want to highlight the incredible amount of work by Apple and the commission over the last two months, which led to the dozens of changes we introduced last week.
*02:38:54-02:39:04*

And I want to acknowledge the constructive and collaborative nature of those conversations that allowed us to reach what I hope is a resolution of our differences on these matters.
*02:39:04-02:39:15*

Before we dive into the details, I'd like to share a bit more about how this process unfolded and how we arrived at the changes announced on Thursday.
*02:39:15-02:39:23*

It has been quite a journey to get to this point.
*02:39:23-02:39:27*

This is the fourth Article 5.4 plan we have developed over the last two years.
*02:39:27-02:39:33*

Our initial plan was grounded in the text of the DMA, specifically in the words of Article 5.4 and Recital 40.
*02:39:33-02:39:42*

As it relates to the App Store, we believe a plain reading of the law requires Apple to allow developers to communicate and promote offers that are available outside of their app from within their app.
*02:39:42-02:39:54*

That means a developer should be free to provide information in their app about those offers and where users can take advantage of those offers.
*02:39:54-02:40:03*

We did not read the law to require us to enable linking out, web views, or other forms of payment from within the app.
*02:40:03-02:40:11*

Indeed, the terms linking out, web views, or in-app payments appear nowhere in the text of this provision.
*02:40:11-02:40:19*

We read the plain language of Article 5.4 as requiring us to allow developers to inform users of promotions and offers that those developers made available outside of the App Store, nothing more.
*02:40:19-02:40:33*

However, it became clear in our pre-March 2024 conversations with the Commission that they had a different expectation.
*02:40:33-02:40:42*

So we announced a plan last January that was focused on what's often referred to as linking out.
*02:40:42-02:40:48*

Under this plan, developers could direct EU users to complete a transaction for digital goods and services on their external web page, including communications about promotions, discounts, and other deals.
*02:40:48-02:41:02*

This plan, which we implemented last March, reflected feedback from and engagement with the Commission.
*02:41:02-02:41:08*

We thought this plan would meet the Commission's expectations.
*02:41:08-02:41:12*

Unfortunately, it was not enough.
*02:41:12-02:41:14*

So we went back to the drawing board.
*02:41:14-02:41:16*

We spent last summer working with the Commission on a third plan.
*02:41:16-02:41:20*

We held weekly meetings together in an effort to understand their positions, develop a revised plan, and then iterate on the details.
*02:41:20-02:41:28*

That effort led to announcement last August of a third plan that introduced more choices and greater flexibility for developers to communicate and promote offers to users as required by the Commission.
*02:41:28-02:41:40*

We kept working even after that announcement.
*02:41:40-02:41:43*

We held hundreds of one-on-one consultations with a diverse group of developers about our plan.
*02:41:43-02:41:49*

We also met individually with Spotify, Match Group, Epic Games, and their trade association, CAF.
*02:41:49-02:41:56*

Mind you, these are multibillion-dollar companies that have a business interest in getting access to our platform and technology for free.
*02:41:56-02:42:04*

In those meetings, we heard different and often contradictory feedback.
*02:42:04-02:42:09*

The overall reaction from the developer community we spoke with was generally positive.
*02:42:09-02:42:14*

That said, we worked with the Commission to make additional changes to our August proposal in the fall.
*02:42:14-02:42:19*

By October, we felt we had a proposal that met all of the Commission's requirements.
*02:42:19-02:42:24*

Yet after all that work, the Commission advised us that it would be better not to implement the revised proposal at that time.
*02:42:24-02:42:31*

The Commission then issued its decision in April, and we spent the last two months working with the Commission on the plan we will talk about today.
*02:42:31-02:42:39*

Now, it goes without saying that this is not the plan we would have chosen if it was purely up to us.
*02:42:39-02:42:44*

Nor is it one we think is required by law.
*02:42:44-02:42:47*

But we did what we had to do to avoid the threat of future significant fines.
*02:42:47-02:42:53*

I know there are some who will say that Apple should give everything away for free.
*02:42:53-02:42:59*

We should charge nothing for the technology or intellectual property we make available to developers.
*02:42:59-02:43:04*

We should charge nothing for a marketplace trusted by millions of Europeans across the continent.
*02:43:04-02:43:11*

We should charge nothing for dozens of services that we provide to the app store.
*02:43:11-02:43:15*

We should charge nothing for payment processing.
*02:43:15-02:43:18*

Look, I get it.
*02:43:18-02:43:20*

I like free stuff, too.
*02:43:20-02:43:22*

But that's not how a market economy works.
*02:43:22-02:43:25*

That's not how innovation and competition work.
*02:43:25-02:43:28*

The DMA does not mandate that businesses give away their technology and services for free.
*02:43:28-02:43:34*

Indeed, respect for the rights of platform owners can be found throughout the law's text, including in Recital 109, which calls for respect of the Charter of Fundamental Rights of the EU.
*02:43:34-02:43:46*

The Commission has always agreed that Apple should be able to receive remuneration for the significant value that we provide to developers through our technology, tools, and services.
*02:43:46-02:43:58*

But now, because of differences in interpretation of Article 5.4, we have been forced to change how we offer these services and how we charge for these services.
*02:43:58-02:44:08*

As we understand it, the Commission wants us to provide developers with more choices about what services they want to use from Apple.
*02:44:08-02:44:16*

And that's what we've done in this fourth plan that we just announced, which reflects the direction and guidance we received from the EC.
*02:44:16-02:44:24*

So with that, let's talk about these new changes we've made to the App Store.
*02:44:24-02:44:28*

First, we made a number of changes to how developers in the EU can communicate and promote offers.
*02:44:28-02:44:35*

Developers are now free to communicate and promote offers in many different ways.
*02:44:35-02:44:39*

They can promote offers to channels outside their app, including a website, another app, or even a third party app marketplace.
*02:44:39-02:44:47*

Developers can also include actionable links to any destination they choose.
*02:44:47-02:44:52*

A link or button can take a user to any website, any app, or any marketplace of the developer's choosing.
*02:44:52-02:44:59*

Our new plan also allows developers to build seamless in-app experiences.
*02:44:59-02:45:05*

For example, a developer can build an in-app web view that allows users to make purchases on the web or download the developer's other apps without leaving the app.
*02:45:05-02:45:16*

A developer can even integrate a web view of external payment processing, creating a user experience that is indistinguishable from in-app payment.
*02:45:16-02:45:27*

In addition, developers are able to freely design and execute how they communicate and promote their offers from within their app.
*02:45:27-02:45:36*

For example, developers can tell users the price of offers that are available in or outside of their app.
*02:45:36-02:45:42*

And developers can give users instructions about how to purchase or subscribe to those offers.
*02:45:42-02:45:48*

We also made changes to the links that developers can use.
*02:45:48-02:45:51*

Developers can now use any number of URLs for linking out to complete purchases.
*02:45:51-02:45:57*

And those allowable links can now include parameters, redirects, and intermediate links.
*02:45:57-02:46:03*

We have even removed the policy under which developers were asked not to use those parameters for purposes of profiling end users.
*02:46:03-02:46:12*

Developers are welcome to post a sign or a dozen in their apps that steer a user to leave our store to make a purchase.
*02:46:12-02:46:20*

I'll go over more of the new business terms in just a minute.
*02:46:20-02:46:22*

But I want to emphasize that as a result of our engagement with the commission, developers will pay nothing to Apple for so-called static promotions in their app.
*02:46:22-02:46:31*

With all that said, we will continue to keep users informed through a disclosure sheet that shows when a user initiates a steered purchase, including buying through an in-app alternative payment service provider, an in-app web view, and linking out to the web.
*02:46:31-02:46:48*

On Thursday, we introduced a number of changes to the disclosure sheets users see before completing a transaction in an alternative payment method.
*02:46:48-02:46:57*

For example, we will now provide users with a show this next time prompt, which gives users control over future disclosures.
*02:46:57-02:47:04*

In our latest version of the disclosure sheet, users will get a pop-up that will ask them to choose whether they would like to see the disclosure reminders in the future or not.
*02:47:04-02:47:14*

These updated policies and capabilities are available to every developer in the EU, regardless of whether they are on our original terms or the new terms we made available to developers in the EU last year.
*02:47:14-02:47:26*

In other words, developers do not need to sign the alternative terms addendum in order to take advantage of these options immediately.
*02:47:26-02:47:35*

Now let's take a look at the new business terms.
*02:47:35-02:47:37*

I want to emphasize that there are changes here which are unrelated to the commission's decision on Article 5.4.
*02:47:37-02:47:44*

We also work with the commission to address their concerns in the context of Article 6.4 investigation, like the move to a single business model and a new fee structure to replace the core technology fee, to name just two.
*02:47:44-02:47:57*

I want to make clear that in developing the business terms I'm about to go over, Apple listened carefully to what the EC told us it wanted us to do differently, and we implemented it accordingly.
*02:47:57-02:48:09*

As you have likely heard, all developers with apps in the EU will transition to a single business model by January 1, 2026.
*02:48:09-02:48:19*

Let me briefly sketch out the elements of the unified model that all developers will be subject to starting next year.
*02:48:19-02:48:25*

First, there will be a core technology commission, or CTC, of 5% on sales of digital goods and services.
*02:48:25-02:48:34*

The CTC reflects value Apple provides to developers regardless of whether they choose the app store or alternatives for distribution.
*02:48:34-02:48:42*

The CTC is not tied to whether a developer is distributing through the app store or steering a customer to making a purchase outside of the store.
*02:48:42-02:48:51*

The CTC reflects Apple's ongoing investments in platform tools, technologies, and services that enable developers to build and share innovative apps with users.
*02:48:51-02:49:02*

To be clear, as of January, there will be no core technology fee.
*02:49:02-02:49:07*

There will only be the CTC.
*02:49:07-02:49:10*

Second, developers distributing apps on the app store will pay an app store commission on sales of digital goods and services.
*02:49:10-02:49:18*

So this captures things like subscriptions, digital content, and paid apps.
*02:49:18-02:49:22*

Developers who choose alternative distribution do not pay this commission.
*02:49:22-02:49:27*

And as I'll explain in a moment, the same is true for developers that use alternative methods to process payments.
*02:49:27-02:49:33*

Those developers also will not pay this commission.
*02:49:33-02:49:36*

Developers who choose to use Apple's payment processing system will pay an additional payment processing fee.
*02:49:36-02:49:43*

Developers who instead choose to use an alternative to our payment processing system, whether that takes the form of a third-party payment service provider, a website, or a web view, will be subject to a new fee model that provides those developers with choices of services and fees.
*02:49:43-02:50:01*

They will not pay the app store commission or the payment processing fee to Apple, but rather have a range of new choices.
*02:50:01-02:50:09*

We have yet to work out every detail of this unified business model.
*02:50:09-02:50:13*

There are more choices, and that drives complexity.
*02:50:13-02:50:17*

Each of these elements is the result of complex and lengthy discussion with the commission.
*02:50:17-02:50:22*

Based on our discussions with the EC, it was important to announce these changes now and ensure that developers could prepare for these changes.
*02:50:22-02:50:30*

And we'll have more details to share on this transition later this year.
*02:50:30-02:50:34*

For now, let's talk about the aspects of this model that were implemented last week.
*02:50:34-02:50:40*

Developers that choose to use an alternative to our payment processing system will not pay the app store commission under either of the two agreements we have in place in the EU.
*02:50:40-02:50:50*

Instead, we introduced a new fee model for these developers.
*02:50:50-02:50:54*

The new model applies to developers who use alternative payment options in their app or link out to the web, another app, or another app marketplace.
*02:50:54-02:51:04*

The new fee structure includes an initial acquisition fee, or an IAF, for new users that reflects the value the app store provides when connecting developers with new customers in the EU.
*02:51:04-02:51:19*

However, there is no IAF for all the users who had downloaded the app before these changes came into effect.
*02:51:19-02:51:26*

This means that it only applies to a very small fraction of users.
*02:51:26-02:51:31*

Under the new terms, there is also a store services fee, or SSF.
*02:51:31-02:51:37*

That reflects the ongoing services and capabilities that Apple provides to developers, including app distribution and management, rediscovery and engagement, app insights, and more.
*02:51:37-02:51:48*

This framework was not one we chose.
*02:51:48-02:51:51*

The commission considers that the DMA requires us to distinguish between the value which the app store provides to developers by facilitating the initial matchmaking from the other app store benefits and make the matchmaking value subject to a separate fee, which must be limited in duration.
*02:51:51-02:52:07*

We work with them to develop a model that would be as simple as possible for developers, but also compliant with the commission's legal interpretation.
*02:52:07-02:52:16*

One complicating factor for the near term is the fact that we have two different sets of agreements in place today that account for the value that we deliver through the platform.
*02:52:16-02:52:26*

Under the new terms we introduced in Europe last year, that value is reflected in the core technology fee, or CTF.
*02:52:26-02:52:34*

We'll account for that value when developers are using these alternatives under our longstanding original terms in Europe with the new core technology commission, or CTC.
*02:52:34-02:52:45*

Let's dig in a little deeper.
*02:52:45-02:52:48*

For developers that choose to use the new alternative payment capabilities, the initial acquisition fee will be 2% on sales of digital goods and services made by a new app user.
*02:52:48-02:52:58*

The initial acquisition fee will be reduced to zero for all the developers enrolled in the small business program, which accounts for the vast majority of developers.
*02:52:58-02:53:09*

This fee will apply for the first six months following an initial download from the app store of an app with the new entitlement, and will apply only to new customers who download an app for the first time through the app store.
*02:53:09-02:53:22*

Let me repeat that.
*02:53:22-02:53:23*

If you are in the small business program, you won't pay the IAF.
*02:53:23-02:53:28*

And no one will pay the IAF for existing customers.
*02:53:28-02:53:34*

As I said, there's also a store services fee on the sale of digital goods and services made via alternative payment methods.
*02:53:34-02:53:41*

In response to the EC's request that we must make non-essential app store services optional, there will be two tiers for this store services fee.
*02:53:41-02:53:50*

Tier 1 includes a limited set of mandatory store services at a price of 5%.
*02:53:50-02:53:56*

Tier 2 includes all of the store services provided by the app store today at a rate of 13%.
*02:53:56-02:54:04*

The tier 2 fee will be reduced to 10% for the developers enrolled in the small business program.
*02:54:04-02:54:10*

It is up to the individual developer to decide what services they want to use, and thus what services they want to pay Apple for.
*02:54:10-02:54:25*

Tier 1 store services include the capabilities needed to distribute on the app store, including app delivery, app management, and customer engagement through the store.
*02:54:25-02:54:36*

Obviously, Apple offers a lot more through the app store.
*02:54:36-02:54:40*

Over the past 15 years, we've vastly expanded the tools, technology, and services available to developers through the app store itself.
*02:54:40-02:54:49*

In some cases, we introduce these services at the request of developers.
*02:54:49-02:54:55*

And we are going to continue to develop and enhance our offerings in the years ahead, both in response to developer demand and based on our own ideas about how to maintain the app store as the very best app marketplace in the world.
*02:54:55-02:55:08*

Looking across the market, no other marketplace offers the breadth and depth of services we offer to developers today.
*02:55:08-02:55:16*

We have set the standard incredibly high.
*02:55:16-02:55:20*

Tier 2 store services include the full suite of offerings, including app analytics, marketing tools, additional customer engagement features, and so much more.
*02:55:20-02:55:31*

These services are not absolutely essential, but they add a lot of value for developers and end users.
*02:55:31-02:55:38*

In short, if developers want these additional store services, they will be able to pay for them.
*02:55:38-02:55:43*

A developer that wants to take advantage of alternatives to our payment processing will no longer pay a 30% commission or a 15% commission if operating under one of our programs available under our longstanding terms.
*02:55:43-02:55:55*

For those developers that want to take advantage of the new flexibility under our original terms, we are immediately introducing the core technology commission of 5%.
*02:55:55-02:56:08*

The CTC is paid on the sale of digital goods and services that are made through the in-app promotion to alternative payment options.
*02:56:08-02:56:16*

In our longstanding business model, the App Store Commission compensated us for both our App Store services and the tools and technologies that developers use to make great apps.
*02:56:16-02:56:27*

Now that we've been required to provide developers the choice to use alternatives to the App Store, we had to split out the services.
*02:56:27-02:56:35*

Specifically, we split out the services, which are compensated by the CTC, from the services which only App Store developers receive.
*02:56:35-02:56:44*

Finally, App Store developers who use alternatives to Apple's payment system can additionally choose whether they want only the basic package or the full package of the remaining App Store services.
*02:56:44-02:56:57*

This may sound more complicated than our original model.
*02:56:57-02:57:00*

It is.
*02:57:00-02:57:01*

We are giving developers an a la carte menu of choices between the many different services we provide versus the one simple model we had for the last 15 years.
*02:57:01-02:57:10*

Again, this is not the model we would have chosen on our own, but it is the one that the Commission mandates the Article 5(4) decision and the issues at play under Article 6(4) demand.
*02:57:10-02:57:22*

As I said, some of the complexity is a function of the fact that we have two different sets of terms in place here in Europe for now.
*02:57:22-02:57:29*

This will get simpler in January when we transition towards a single, unified set of terms in Europe and a single business model, albeit with a lot more choices and options than what we had in place for the last 15 years.
*02:57:29-02:57:43*

Here's the bottom line.
*02:57:43-02:57:44*

Under the new EU terms as of January, the most, the very most, a developer using an alternative payment method could pay across the initial acquisition fee, store services fee, and the CTC is 20%.
*02:57:44-02:57:57*

However, for a majority of developers, these fees can be reduced to as low as 10%.
*02:57:57-02:58:03*

And again, developers will pay nothing for static promotions in their app.
*02:58:03-02:58:08*

We collaborated closely with the European Commission on these elements of the plan to ensure that their perspective on fair pricing for the value that we provide developers was reflected in the final rates.
*02:58:08-02:58:19*

These are significant changes to a model that has worked for consumers and developers for the last 15 years.
*02:58:19-02:58:25*

We are introducing new choices for developers.
*02:58:25-02:58:28*

We do have concerns about the impact of these changes on our store and the experience we have worked so hard to deliver to our users over the last 15 years.
*02:58:28-02:58:38*

A big reason why small developers around the world have been able to reach massive audiences on the App Store is because users trust the App Store.
*02:58:38-02:58:47*

In fact, it's hard to remember what downloading software was like before the App Store.
*02:58:47-02:58:51*

Back then, it was the Wild West of the open web.
*02:58:51-02:58:54*

You never really knew what you were downloading.
*02:58:54-02:58:57*

At Apple, we set out to change all that and build a marketplace that users could trust.
*02:58:57-02:59:01*

To achieve this, Apple has invested significant resources over the last 15 years to create an unparalleled trusted experience for our users.
*02:59:01-02:59:11*

Trust isn't just about protecting our users' privacy and security.
*02:59:11-02:59:15*

Users trust that apps they find on the App Store don't have bugs and are reliable, and users know they can complain to Apple if something goes wrong.
*02:59:15-02:59:24*

They also trust that there is a smooth downloading experience, that the apps will remain up to date through automatic updates happening in the background.
*02:59:24-02:59:31*

They expect to be able to leave and use reviews and much more.
*02:59:31-02:59:35*

Maintaining that trust hasn't been easy and requires constant reinvestment.
*02:59:35-02:59:40*

Year in and year out, we invest heavily in creating the best possible experience for developers and users.
*02:59:40-02:59:46*

Take Apple's integrated payment system, for example.
*02:59:46-02:59:49*

This system has helped protect users from fraud and abuse.
*02:59:49-02:59:53*

In the last five years alone, the App Store has protected users by preventing over $9 billion in fraudulent transactions.
*02:59:53-03:00:02*

IAP offers even more benefits for users.
*03:00:02-03:00:04*

With IAP, users can make transactions in multiple currencies with the payment information connected to their Apple account.
*03:00:04-03:00:11*

They can use Report a Problem to get help directly from Apple about content they purchased or to request a refund.
*03:00:11-03:00:18*

They can manage all of their subscriptions in one place, and so much more.
*03:00:18-03:00:23*

Given the progress we've made, it can be easy to take this trust for granted, especially if you're a big developer with the resources to invest in marketing, security, and the user experience.
*03:00:23-03:00:34*

But this trust is a big part of the reason why the App Store attracts more than 813 million average weekly visitors worldwide.
*03:00:34-03:00:42*

And users are willing to try out apps from smaller, less well-known developers.
*03:00:42-03:00:47*

We're also constantly investing in an ever-expanding suite of tools and technologies that developers use to build and ship great apps in over 40 languages and in 175 regions around the world.
*03:00:47-03:01:01*

I'll give just a couple of examples of the value that developers have gotten on their side of that deal.
*03:01:01-03:01:05*

We make sure that the App Store services are always available, thanks to our hundreds of sustainability and reliability engineers who maintain our content delivery networks.
*03:01:05-03:01:16*

We provide hosting and bandwidth for all apps, updates, in-app purchases, and more.
*03:01:16-03:01:21*

We offer worldwide payment processing, whether it's credit or debit cards, carrier billing, digital wallets, or gift cards.
*03:01:21-03:01:29*

And we assist developers with tax obligations in over 60 regions.
*03:01:29-03:01:33*

On the marketing side, the App Store supports a wide range of marketing opportunities, including pre-orders, in-app events, and custom product pages.
*03:01:33-03:01:43*

As a result, the App Store is a fantastic business opportunity for developers.
*03:01:43-03:01:48*

In fact, the global App Store ecosystem facilitated $1.3 trillion in developer billings and sales in 2024, according to one recent study.
*03:01:48-03:01:59*

Over the last five years in particular, billings and sales facilitated by the App Store ecosystem more than doubled in Europe.
*03:01:59-03:02:09*

I think you all know, from the moment the App Store was created in 2008, all the way until last March, we operated the same business model everywhere in the world.
*03:02:09-03:02:18*

This standardized business model reflected all of the value Apple delivered to developers in a single global commission structure.
*03:02:18-03:02:26*

It's simple, easy to understand, and reflects the distribution, discovery, and promotion services provided by the App Store for each and every developer.
*03:02:26-03:02:35*

As I said before, however, the EC's interpretation of Articles 5.4 and 6.4 has led us to come up with an alternative, revised structure to parse out the wide range of benefits that Apple provides developers.
*03:02:35-03:02:49*

We know there's been some confusion around these changes.
*03:02:49-03:02:52*

That's natural.
*03:02:52-03:02:53*

We continue to think that our simple worldwide model is easy to understand, balances the interests of various stakeholders, and works well for the vast majority of developers, even if some of the biggest named developers who made the most money on our platform don't love it.
*03:02:53-03:03:08*

But in the EU, we're now required to separate all the value we create for developers into ever more separate and specific fees.
*03:03:08-03:03:16*

This was not a model we would have chosen, but for the threat of significant further fines.
*03:03:16-03:03:21*

We've done our best to stay committed to our core values, including making substantial ongoing investments in the App Store and our platform to ensure developers have a trusted, easy-to-use platform that allows them to reach millions of users, even if they're linking out.
*03:03:21-03:03:37*

We believe the App Store will remain a great deal for developers in the EU as we continue to move forward here.
*03:03:37-03:03:43*

With that, I'll take questions.
*03:03:43-03:03:46*

>> Thank you very much, Kyle.
*03:03:46-03:03:47*

So, I will just recall that the new model is under the assessment by the Commission, and I will open the floor to the room, many hands.
*03:03:47-03:03:56*

So, let's try those who haven't spoken, the red glasses, please.
*03:03:56-03:04:00*

>> Thank you so much.
*03:04:00-03:04:03*

I'm Jari-Pekka Kaleva from the European Games Developer Federation.
*03:04:03-03:04:07*

In the United States, Apple also was forced to change their implementation practices, and there you are already allowing direct in-game link outs and payment gateways without paying a commission to Apple, and that's, of course, how we see the Article 5.4 should be implemented.
*03:04:07-03:04:27*

Why are the rules not the same in the EU as they are in the United States?
*03:04:27-03:04:31*

And, of course, from our perspective, digital single market area is our home market for the game developers, and this creates a significant competitive disadvantage for the European SMEs as the US-based companies have access to more favorable terms in their home markets.
*03:04:31-03:04:48*

>> Very good.
*03:04:50-03:04:51*

Next. Please.
*03:04:51-03:04:54*

>> Thank you.
*03:04:54-03:04:56*

My name is Alvar Pinto.
*03:04:56-03:04:57*

I'm from Aptoide, an app store based in Europe that competes in the iOS space.
*03:04:57-03:05:02*

So, I will start just with two quotes because I think this helps us to understand what's going on, and the first one is from a guy called Steve Jobs.
*03:05:02-03:05:12*

I believe you all know him, and he said several things about simplicity, and one of the things he said was, "It takes a lot of hard work to make something simple, to truly understand the underlying challenges and come up with elegant solutions." The solution that Apple is proposing, last week proposed, is neither simple nor elegant.
*03:05:12-03:05:36*

So, this is the mantra of your founder, and this is exactly the opposite.
*03:05:36-03:05:41*

It's really difficult to understand for us, for developers.
*03:05:41-03:05:45*

We spoke with several developers, and it's not linear, it's not transparent, and that's an issue by itself.
*03:05:45-03:05:52*

I will quote a second person, which is Tim Sweeney, that you all probably know from Epic, and he calls these changes to be malicious compliance scheme, and I tend to agree with him, but I think it's more of an hilarious solution, to be honest, and for many reasons, and I have a few questions for Apple.
*03:05:52-03:06:14*

The first one is, okay, if you look into the fees that you are proposing, the minimum that the developers need to pay for external offers is 5%, if I understand it well.
*03:06:14-03:06:27*

It's complex, so maybe I'm wrong, but, well, this is what currently developers have as a fee charged by your competitors in the web pay shops, meaning companies that are offering a solution for payments to developers that include, of course, all the services that you mentioned, like payments in multiple currencies, different payment providers in different geos, merchant of record, fraud, et cetera.
*03:06:27-03:06:56*

They charge 5%, so on top of that, you are charging 5%, and you are not processing the payments, and this is not competitive at all.
*03:06:56-03:07:05*

How can it be competitive, and how can you expect developers to engage in it?
*03:07:05-03:07:11*

The second one is, of course, what's going on in the US, so currently external offers by a court decision are free, and developers can have these offers in your store, and this is not exactly what you are proposing in Europe, so why not having the same model in US and Europe?
*03:07:11-03:07:31*

That's what makes sense.
*03:07:31-03:07:34*

Third, you are announcing new changes in six months.
*03:07:34-03:07:39*

This is a problem, and has been since day one, because, look, we are not engaging into a solution to developers today if we know that Apple already plans to change everything in six months, and we don't know exactly what is going to change, so how can we build, as a company, something that competes in this space if we don't know what one of our competitors is launching in six months' time?
*03:07:39-03:08:06*

This, it's absurd for us.
*03:08:06-03:08:10*

And finally, so it was not discussed here, but, OK, there's a new fee, a commission technology, a core technology commission called CTC, but we also have CTF, and the question is, are app stores still obligated to pay CTF?
*03:08:10-03:08:30*

Is this changing to CTC?
*03:08:30-03:08:32*

Again, it's not clear, and currently, what we see, we have like five or six different app stores on iOS competing with Apple in Europe, and talking with our competitors and these stores and ourselves, we see that CTF is a pain, because, of course, we cannot pay 50 cents from day one, from the first download, to be able to launch or install an app or a game in a user iOS device.
*03:08:32-03:09:02*

So this means that if we do the parallel with Android, where we have millions and millions of users, we will be paying like tens of millions of euros to Apple every single month.
*03:09:02-03:09:17*

This would mean that this was not feasible to us, so we don't scale the business, because we can't scale with the CTF.
*03:09:17-03:09:25*

And that's it, thank you.
*03:09:25-03:09:26*

Thank you, I will take one more.
*03:09:26-03:09:29*

There are lots of questions, one more.
*03:09:29-03:09:32*

Gentleman in the purple shirt.
*03:09:32-03:09:35*

Hello, I'm Hans Christoph Steiner, technical lead of FDroid, a free and open-source software app store.
*03:09:35-03:09:42*

But mostly I'm here as a volunteer, because I believe in democracy.
*03:09:42-03:09:48*

I'll start off by saying I have immense respect for Apple's design, and it has been an inspiration for me, and indeed, the first code I wrote, I'm a developer, was on an Apple in 1980.
*03:09:48-03:10:01*

And so I'm here, representing a small but I think important voice.
*03:10:01-03:10:07*

There's a huge interest in free and open-source software around the world, but Apple makes it difficult to distribute it on iOS.
*03:10:07-03:10:18*

And we really see this with these new requirements, both in the initial round and the current round of proposals.
*03:10:18-03:10:32*

Sorry, I'm not a pro at this, I'm a little nervous.
*03:10:32-03:10:36*

From what I've seen, and from lots of people who work on free and open-source software, these conditions seem almost designed to keep out free and open-source software.
*03:10:36-03:10:48*

But at the same time, if you look at free and open-source software distributions, they share a lot of the same patterns that Apple champions, like requiring review, not allowing porn, things like this.
*03:10:48-03:11:07*

And yet, all of these allow third-party app stores, third-party side-loading, et cetera, et cetera.
*03:11:07-03:11:13*

Indeed, now iOS itself is built on open software, like BSD.
*03:11:13-03:11:23*

So my question to Apple is, why does Apple want to disadvantage free and open-source software?
*03:11:23-03:11:30*

Thank you. So let's go to this free group, and then we take another one, because there was a lot to cover.
*03:11:30-03:11:38*

Yep, and I'll count on everybody to keep me honest, to make sure I respond to especially the 15-part question we got.
*03:11:38-03:11:46*

So in terms of -- there is certainly a theme there in a couple of questions around, why not just give everything away for free?
*03:11:46-03:11:55*

And like I said in my remarks, I get it.
*03:11:55-03:11:57*

Like, it'd be great if Apple provided all the technology, tools, and services that we've invested in and built and created and spent billions of dollars over the last 15 years, and just turned around and gave it all away to free, all of it.
*03:11:57-03:12:12*

It'd be great, when I talk about the app store, in the 15 years we've spent building kind of a trusted marketplace, building out all these services, and then to turn around and say, "We'll give it away for free." It'd be great if the payment processing system that we built, that consumers have come to trust on, was available to everyone for free.
*03:12:12-03:12:33*

That's not competition. That's not innovation.
*03:12:33-03:12:36*

That's not a free-market economy.
*03:12:36-03:12:38*

That's not the world we live in.
*03:12:38-03:12:40*

And so I understand the comparisons to the current U.S. situation.
*03:12:40-03:12:45*

Of course, the matter there is under appeal, but I think you're not comparing apples to apples.
*03:12:45-03:12:51*

These are two different legal regimes.
*03:12:51-03:12:53*

They're two different implementations.
*03:12:53-03:12:56*

Let me just tick off a few examples.
*03:12:56-03:12:58*

For example, in the United States, we can still require the use of in-app purchase.
*03:12:58-03:13:03*

We cannot do that here in Europe.
*03:13:03-03:13:05*

In the United States, we're only required to allow for linking out or web-based transactions.
*03:13:05-03:13:12*

Here in Europe, we're required to allow for in-app experiences.
*03:13:12-03:13:17*

So we're required to ensure that a developer can seamlessly integrate a third-party service provider within its app.
*03:13:17-03:13:24*

That's not something we're doing in the United States.
*03:13:24-03:13:27*

We're allowing developers here to steer to alternative marketplaces, including Aptoide and others.
*03:13:27-03:13:33*

That is something that is not the case in the United States.
*03:13:33-03:13:37*

The court made quite clear that there was absolutely no legal obligation on Apple to enable alternative distribution to the app store in the United States.
*03:13:37-03:13:46*

So there are some significant differences between what we've announced here in Europe and what's in place in Europe.
*03:13:46-03:13:55*

Certainly, I think, from our perspective, we deliver significant value at each layer.
*03:13:55-03:14:01*

We deliver significant value in terms of the tools, technologies, and intellectual property.
*03:14:01-03:14:05*

We supply significant value at the app store level, both in terms of introducing developers to customers, but then all of the services we're providing to developers.
*03:14:05-03:14:16*

We also provide payment processing.
*03:14:16-03:14:19*

What we've done through this plan is to provide choices, and I understand people are still digesting it.
*03:14:19-03:14:26*

Somebody mentioned, you know, quotes, right?
*03:14:26-03:14:28*

Steve obviously loves simplicity.
*03:14:28-03:14:30*

I'm sure he would take one look at what we are required to do and lose his mind.
*03:14:30-03:14:35*

I have no doubt about that, having met the man.
*03:14:35-03:14:38*

I wish it was simpler, but we didn't really have a choice to make it simpler.
*03:14:38-03:14:42*

As for Tim Sweeney, I'd note that he made his comment after about two minutes after posting it.
*03:14:42-03:14:46*

So I'm not sure he had -- he's a brilliant man, but I'm not sure he had enough time to read through what we announced before he posted his -- or reposted his original app or tweet, whatever we call it these days.
*03:14:46-03:14:58*

[ Laughter ]
*03:14:58-03:15:02*

Looking at some of the other issues -- ah, you asked the Aptoide gentleman -- I'm sorry, I forgot your name.
*03:15:02-03:15:08*

Alvaro. You asked about how the changes -- these changes are coming in six months.
*03:15:08-03:15:15*

I think one of the things that we've tried to do is make it clear that we're on a journey, right?
*03:15:15-03:15:20*

Yes, we have terms in place today that require the core technology fee and allows you to take advantage of all -- whether it's alternative distribution, alternative payments, those are going to be sunset.
*03:15:20-03:15:30*

So we're not going to be enforcing those terms after January 1st.
*03:15:30-03:15:34*

There will be no CTF applied to any developer, whether it's a third-party app marketplace or otherwise.
*03:15:34-03:15:39*

We will have a single set of terms, and it will be a CTC that is applicable to everyone.
*03:15:39-03:15:45*

How does that work for an app marketplace such as yourselves?
*03:15:45-03:15:49*

One, we are not going to charge a 5% fee on all of the revenues created by a third-party app marketplace.
*03:15:49-03:15:57*

What we will do, consistent with how we're treating every other single developer, is say, okay, is this -- and we know there are marketplaces that do this, that sell digital goods on their website that can be consumed in the apps, like virtual currency.
*03:15:57-03:16:09*

Those will be subject to a 5% CTC payable by the app marketplace.
*03:16:09-03:16:16*

In terms of downloading an app, let's use a hypothetical.
*03:16:16-03:16:19*

Say they can buy an app for $5.
*03:16:19-03:16:21*

There will be a CTC levied on that, but that is not something necessarily that will be paid by the marketplace.
*03:16:21-03:16:27*

But there's the principle of, like, if you're selling a digital good, if you're selling an app, there will be a CTC applied to that.
*03:16:27-03:16:34*

And so we've thought carefully, because, listen, we've seen Aptoide.
*03:16:34-03:16:37*

We've seen others emerge.
*03:16:37-03:16:39*

We have no interest in stifling that emergence.
*03:16:39-03:16:42*

In fact, we welcome that competition, and I think you'll see in the coming years, we're going to become very kind of aggressive in how we can compete on a service-level offering.
*03:16:42-03:16:51*

We're not looking to use fees as an advantage in that, but we do believe that we provide significant value to developers to create these digital experiences.
*03:16:51-03:17:00*

And so we have priced that through the Core Technology Commission going forward.
*03:17:00-03:17:04*

My friend from the free and open-source software, trust me, it gets a lot easier over time to do this.
*03:17:04-03:17:12*

So if you're a repeat player, you'll get used to talking.
*03:17:12-03:17:14*

But I'll say I don't know the particulars around some of the challenges you're facing, and I'm more than happy to connect with you after this to understand where you are running into roadblocks and challenges.
*03:17:14-03:17:27*

You know, Apple has worked with the open-source community on projects throughout its history.
*03:17:27-03:17:32*

I just don't know enough about your particular situation sitting here right now, but happy to follow up after this.
*03:17:32-03:17:40*

>> Yes, very good.
*03:17:40-03:17:42*

It seems so.
*03:17:42-03:17:43*

Thank you.
*03:17:43-03:17:44*

We take three from the slide, Lubben.
*03:17:44-03:17:48*

>> Yes. There's a few questions on slide, though.
*03:17:48-03:17:53*

So first one, first two actually coming from Alba Ribeira Martinez from the University of Villanueva.
*03:17:53-03:18:02*

The question is whether the new proposed measures on steering apply to both free and paid apps available on the App Store, and whether for the developers who already opted into the alternative terms addendum, what terms will apply to them?
*03:18:02-03:18:17*

Whether they will also be automatically opted into the terms of the store kit external purchase link entitlements addendum or something else?
*03:18:17-03:18:25*

And then the third question comes from Mr. Smith.
*03:18:25-03:18:29*

The question is whether once the new terms are in place, whether developers are able to offer both linking out as well as Apple's IAP, or do they have to choose between the two?
*03:18:29-03:18:42*

>> Yes, I will repeat again, please on slide, though, put always your organization.
*03:18:46-03:18:52*

It's very difficult to take questions from unaffiliated people.
*03:18:52-03:18:58*

So, yeah. So from now on, we will not take questions from people who did not put affiliation.
*03:18:58-03:19:07*

All right.
*03:19:17-03:19:18*

So on the first question, let me, on the CTC, it applies, or is this on steering?
*03:19:18-03:19:26*

Sorry. Was it steering or on the CTC, Lubin?
*03:19:26-03:19:28*

I'm sorry.
*03:19:28-03:19:30*

>> It's on steering.
*03:19:30-03:19:31*

>> Steering.
*03:19:31-03:19:32*

If there is a pay, there's a free app that is steering outside of that app, whether it's to a website, whether it's to an in-app payment system that they've built into it, whether it's to an alternative app marketplace, and they're steering for the purposes of selling the user something, then the steering model that I outlined applies.
*03:19:33-03:19:57*

If the steering is simply to something else where there's no transaction, there's no ability to purchase, say you're just steering to a marketplace and saying, hey, download this app, and there's no fee associated with it.
*03:19:57-03:20:09*

Apple is not charging for that.
*03:20:09-03:20:12*

So hopefully that clarifies to some extent.
*03:20:12-03:20:14*

He asked about the new terms, the IUDA, here in Europe, the terms we announced last year.
*03:20:14-03:20:22*

Starting immediately, those developers have the ability to apply for this new entitlement for using these alternatives and steering.
*03:20:22-03:20:32*

So starting now, you can apply for this, and you'll be able to have static promotions free of charge.
*03:20:32-03:20:41*

You'll be able to have, include links or buttons or web views or in-app payments to sell digital goods and services, and it will be the model we've talked about.
*03:20:41-03:20:56*

And so that entitlement is live.
*03:20:56-03:20:58*

So this is the complicating factor I talked about in my remarks.
*03:20:58-03:21:01*

Given we have these two agreements side by side for the next six months, there will be different terms.
*03:21:01-03:21:08*

So on the existing or the original longstanding 30% commission terms, there will be a CTC.
*03:21:08-03:21:15*

For the new terms we announced last year, there will be a CTF.
*03:21:15-03:21:18*

But for all other intents and purposes, those models are the same when it comes to the IAF, the store services fee, and the other elements we talked about.
*03:21:18-03:21:28*

Choosing between in-app purchase.
*03:21:28-03:21:31*

So this is something we've done from the very beginning, which is we've invested significant time and effort in building Apple's IEP system in terms of making it the most trusted, at least from our perspective, the most trusted place for consumers to make these purchases.
*03:21:31-03:21:48*

And we want to continue to make that being the case going forward.
*03:21:48-03:21:51*

And so if a developer decides that he or she wants to use IEP, then in that instance we say you're not going to use, you know, linking out or buttons or web views or other things.
*03:21:51-03:22:04*

We're seeing a lot of kind of manipulative and deceptive behavior in the United States with these two things side by side, which only reinforces our concerns.
*03:22:04-03:22:12*

And so here in Europe we're going to maintain the policy that we've had where there will be a choice.
*03:22:12-03:22:18*

The default is you're using some other alternative.
*03:22:18-03:22:21*

If you want to use IEP, that's a choice for you.
*03:22:21-03:22:25*

>> Thank you.
*03:22:25-03:22:32*

No, actually I'm responding about the Slido.
*03:22:32-03:22:34*

So I will say it seems that in the Slido the questions come at the bottom.
*03:22:34-03:22:40*

So for those who want to follow what questions are on the Slido you need to go in the tab recent so that you see what is actually happening.
*03:22:40-03:22:46*

Because I'm getting emails about not seeing the questions.
*03:22:46-03:22:49*

So you don't see them because they're at the bottom.
*03:22:49-03:22:51*

But if you, there is a tab which is recent, then you should be able to see them.
*03:22:51-03:22:57*

Very good.
*03:22:57-03:22:58*

So back to the room.
*03:22:58-03:23:01*

No ladies.
*03:23:01-03:23:03*

This is hard.
*03:23:03-03:23:04*

Okay. Please.
*03:23:04-03:23:06*

>> Yes, I'm Geoffrey Kretz, founder of Kuit.
*03:23:06-03:23:11*

At Kuit we make a mobile app helping people to live better.
*03:23:11-03:23:15*

So in the digital health field.
*03:23:15-03:23:17*

And so privacy is super important for us and for our users.
*03:23:17-03:23:21*

And how can we in the future if you have many app stores and different stores, how can we keep the trust of the people?
*03:23:21-03:23:30*

And we, because we noticed that we make some survey and user on iOS have higher trust than user on Android.
*03:23:30-03:23:38*

And so just to, how do you keep that in a world with many stores on the same phone?
*03:23:38-03:23:44*

>> Hi. John from Open Web Advocacy here.
*03:23:44-03:23:50*

Kyle, you spoke at length about the app store as if every app is carefully reviewed, safe and secure.
*03:23:50-03:23:55*

But that doesn't simply match the reality.
*03:23:55-03:23:58*

We use the app store daily.
*03:23:58-03:24:00*

And every single week we're served ads, often directly from Apple, for apps that are alive in the store right now.
*03:24:00-03:24:06*

And clearly designed to scam users out of money.
*03:24:06-03:24:09*

These are called fleece wear apps.
*03:24:09-03:24:11*

And they rely on deceptive subscription models and dark patterns to exploit users.
*03:24:11-03:24:16*

And Apple's review process is ineffective at solving this.
*03:24:16-03:24:20*

So some facts are pretty striking.
*03:24:20-03:24:23*

Apple has just 500 reviewers looking at over 130,000 apps every week.
*03:24:23-03:24:29*

And most of them only spend a few minutes per app if you divide and do the math.
*03:24:29-03:24:34*

So few have technical backgrounds and mainly just click around the interface from what we're understanding.
*03:24:34-03:24:40*

And they work 10-hour shifts.
*03:24:40-03:24:42*

And even Apple's own executives once worried it might resemble sweatshop conditions, according to what's come out.
*03:24:42-03:24:48*

But the real eye-opener for me comes from internal emails revealed during the Epic versus Apple case.
*03:24:48-03:24:54*

Senior Apple staff were openly frustrated in some quotes, and some of my favorites are, is no one reviewing these apps?
*03:24:54-03:25:01*

This is insane.
*03:25:01-03:25:02*

A bunch of explanation points.
*03:25:02-03:25:04*

App review is bringing a plastic butter knife to a gun flight.
*03:25:04-03:25:08*

They're more like greeters at a Hawaiian airport than drug-sniffing dogs.
*03:25:08-03:25:13*

Just like in October, app review fails to review properly.
*03:25:13-03:25:17*

So my question is, if Apple's own internal communications acknowledge that human app review is ineffective and the App Store continues to host widespread fraud and abuse, how can Apple credibly use the system as a defense against third parties who might actually offer more effective safeguards?
*03:25:17-03:25:34*

And to tack onto this, my second very short question is to clarify that websites and web apps run or install from any browser, they will be exempt from CTC.
*03:25:34-03:25:44*

Is that correct?
*03:25:44-03:25:45*

Thank you.
*03:25:45-03:25:45*

Thank you.
*03:25:45-03:25:58*

Emre Kaya from the Coalition for Open Digital Ecosystems.
*03:25:58-03:26:02*

We are a coalition of companies, big, small, some of them gatekeepers under the DMA, MetaGoogle, also challengers, European and non-European, who all believe that openness and interoperability are good for innovation, consumers, and businesses.
*03:26:02-03:26:22*

In the context, we believe that developers should have effective autonomy to distribute apps to alternative stores or websites, fostering competition and innovation and expanding consumer choice.
*03:26:22-03:26:38*

A year on from the commencement of the DMA, we still do not see most iOS devices having multiple app stores or users side loading effectively.
*03:26:38-03:26:48*

When will Apple address that concretely, if we can have a timeline?
*03:26:48-03:26:53*

Thank you.
*03:26:53-03:26:54*

Emre?
*03:26:55-03:26:55*

Hi.
*03:26:55-03:27:05*

My name is Michiel Volkring.
*03:27:05-03:27:07*

I am the founder of Ficod, and I am a member of the X Association.
*03:27:07-03:27:12*

My question would be regarding these changes, is what I'm kind of concerned of-- and I sent a bunch of letters also to the commission that I would still look forward to having a reply on-- is dark patterns being used outside of the store, and people, well, having an experience on their devices that is ultimately going to degrade trust in the device itself, meaning that people will often also start distrusting third party developers on the entire platform as well.
*03:27:12-03:27:48*

I feel like-- I hope Apple has a plan.
*03:27:48-03:27:54*

And they say they're appealing, so that's great.
*03:27:54-03:27:57*

But it has a plan to hopefully make some changes that can ensure that these parties using dark patterns outside of the store with these links that look like in-app purchases links will be removed or have any penalty, something like that.
*03:27:57-03:28:17*

Thank you.
*03:28:17-03:28:18*

Good, I propose that Kelly answer those.
*03:28:18-03:28:23*

I'll take up that proposal.
*03:28:23-03:28:26*

So I think the gentleman here raised the question of, how do users know what to trust?
*03:28:26-03:28:32*

And I think the great thing is the App Store will still be available to our users on our devices.
*03:28:32-03:28:39*

I think what we're worried about is not only-- there is a concern we have around undermining the trust in the store.
*03:28:39-03:28:46*

And I do think there is that risk.
*03:28:46-03:28:49*

The gentleman on the other side claims, oh, there's lots of problems.
*03:28:49-03:28:52*

There are always problems.
*03:28:52-03:28:53*

I think what sets us apart is we listen and we take action very, very quickly to address them.
*03:28:53-03:29:00*

And so that is our commitment to continue.
*03:29:00-03:29:02*

Even though this is a more complicated world with all these different links and different directions, and yes, we're concerned about consumers not really fully understanding what they're doing, we're going to continue to watch this space.
*03:29:02-03:29:13*

We're not just going to simply, as some companies do, just launch it and see what happens.
*03:29:13-03:29:17*

I think we're going to be very vigilant to make sure that our users-- and we're going to conduct study after study to see that, are they understanding what's happening?
*03:29:17-03:29:26*

What do we need to do to make sure they're making informed choices?
*03:29:26-03:29:30*

This is something that you've seen us innovate on for years.
*03:29:30-03:29:33*

I mean, I look at app tracking transparency as a great example where there was a lot of activity going on that we felt that users didn't fully appreciate or understand.
*03:29:33-03:29:41*

And so we introduced app tracking transparency in an effort to provide more transparency to users about what's going on.
*03:29:41-03:29:48*

And the studies that we've done since have said, users really appreciate this feature.
*03:29:48-03:29:53*

And we've done that time and time again.
*03:29:53-03:29:55*

And I think we're going to have to do it as we all move into this new era.
*03:29:55-03:29:59*

So it is an issue we're concerned about.
*03:29:59-03:30:02*

I know John loves this stuff.
*03:30:02-03:30:05*

Listen, I appreciate the criticism.
*03:30:05-03:30:08*

We appreciate the criticism.
*03:30:08-03:30:09*

That's what makes Apple better.
*03:30:09-03:30:11*

And so yes, you can point to emails from eight years ago.
*03:30:11-03:30:15*

Yes, you can point to things that you found on the App Store and say, this is a big problem.
*03:30:15-03:30:20*

I'm not here to deny that there are problems.
*03:30:20-03:30:22*

What I am here to say is we take those problems incredibly seriously, that we have thousands of people at Apple who are focused on, how do we solve those problems?
*03:30:22-03:30:32*

When it comes to app review, I think we're on record as saying it's not perfect.
*03:30:32-03:30:35*

But it's certainly better than what we see in the marketplace.
*03:30:35-03:30:38*

Could we invest more?
*03:30:38-03:30:40*

Yes, and we are.
*03:30:40-03:30:41*

Could we do more?
*03:30:41-03:30:42*

Yes, we are.
*03:30:42-03:30:43*

We're introducing artificial intelligence.
*03:30:43-03:30:45*

We're introducing all sorts of tools and technologies to ensure that we continue to be the very best.
*03:30:45-03:30:51*

We're not perfect.
*03:30:51-03:30:52*

I think in a marketplace in which you have hundreds of thousands, millions of people, you're never going to have perfection, as much as I would like it.
*03:30:52-03:31:01*

But what our commitment is, is you're going to have our commitment to always try to do what's best for the user.
*03:31:01-03:31:06*

And so if there are issues, if there are problems, and you're like, look, this is bad, bring it to us.
*03:31:06-03:31:11*

Our door is open.
*03:31:11-03:31:13*

Whether you agree with us on everything or not, I'd encourage you to say, I see a problem.
*03:31:13-03:31:17*

This isn't good.
*03:31:17-03:31:19*

So there's lots of questions.
*03:31:19-03:31:20*

You'll have plenty of time.
*03:31:20-03:31:22*

But we encourage that.
*03:31:22-03:31:24*

I think looking at-- oh, the code team.
*03:31:24-03:31:34*

There are multiple app stores today on iOS.
*03:31:34-03:31:38*

We have eight, nine different stores that are active.
*03:31:38-03:31:42*

If you look at the data, all of those are growing.
*03:31:42-03:31:45*

They're growing in terms of number of installs, growing in terms of number of apps in their library.
*03:31:45-03:31:52*

We expect in January, when we move to a single model, there'll be more growth.
*03:31:52-03:31:57*

Certainly, if you look at the implementation that we have-- and I think Aptoide has been very public on this-- it's a much better implementation than what you see on your client Google.
*03:31:57-03:32:06*

Google has had a lot more screens, a lot more challenge to make it really hard for people to download alternatives.
*03:32:06-03:32:13*

And so at this point, I think we're at the leading edge in terms of making it simple.
*03:32:13-03:32:16*

We made a bunch of announcements last week about different, more streamlined flows.
*03:32:16-03:32:22*

It's something that we continue to have a laser focus on.
*03:32:22-03:32:25*

And we're going to work to make sure that the flows that we have in place are informing consumers.
*03:32:25-03:32:31*

I think there's evidence out there that some of the flows being used by some of our competitors are designed to frustrate alternatives.
*03:32:31-03:32:38*

That's not our focus.
*03:32:38-03:32:39*

Our focus is ensuring that our consumers have the information they need to make informed choices.
*03:32:39-03:32:44*

And that's our commitment.
*03:32:44-03:32:46*

The last question was around, how do we protect users in this more complicated environment?
*03:32:46-03:32:52*

I think it's an incredibly important question.
*03:32:52-03:32:54*

One of the things I've talked about a lot with my commission colleagues is, we're going to need help.
*03:32:54-03:33:01*

I think that we have not seen the same focus on consumer protection here that perhaps we've seen in the United States.
*03:33:01-03:33:08*

One great example is the FTC's action against Epic Games, where they found that Epic Games was deceiving children, manipulating users to make purchases they didn't want.
*03:33:08-03:33:18*

That's a massive problem.
*03:33:18-03:33:19*

And it's never been addressed here.
*03:33:19-03:33:21*

And so those problems need to be addressed.
*03:33:21-03:33:23*

Those are very real concerns, because I think we're opening up a Pandora's box here, particularly with some of the changes we announced last week.
*03:33:23-03:33:31*

And we need to have-- it's not just going to be us on the front lines.
*03:33:31-03:33:34*

We're going to need colleagues in government, both at the commission level and the national authorities, to make sure that they are acting, because to date, they have not.
*03:33:34-03:33:43*

Very good.
*03:33:43-03:33:47*

On slide, we have only anonymous questions.
*03:33:47-03:33:50*

So we are not taking those.
*03:33:50-03:33:51*

So hands up in the room.
*03:33:51-03:33:53*

I will take the last three questions from people who haven't-- so everyone who already has a question, hands down.
*03:33:53-03:33:59*

And keep only the hands of those who haven't asked questions.
*03:33:59-03:34:02*

Please, go.
*03:34:02-03:34:04*

Sure.
*03:34:04-03:34:08*

I'm James Seppel from Open Web Advocacy.
*03:34:08-03:34:11*

It's great to be here.
*03:34:11-03:34:12*

I wanted to bring up a couple points from our previous questions, where I think maybe you slightly misunderstood the question.
*03:34:12-03:34:18*

The first one was way back in the first part.
*03:34:18-03:34:23*

But the sounds that you had six, seven months to implement, or at least to know that you had to implement the interoperability system.
*03:34:23-03:34:34*

And sure, maybe it's hard to create a new system in that time.
*03:34:34-03:34:38*

But we're not saying you have to make something from scratch.
*03:34:38-03:34:41*

There's lots of existing systems, like GitHub, like Bugzilla for WebKit, like all of these things you use internally that you could have used, which would have been much, much more helpful to developers than the PDF.
*03:34:41-03:34:52*

In reference to the App Store thing, you say you're very contactable, that we can come to you with these problems.
*03:34:56-03:35:01*

But there is actually a button in the App Store to report scams.
*03:35:01-03:35:06*

When people try and get in touch with you, it's a bit of a joke.
*03:35:06-03:35:10*

And the website stuff and the browser stuff, sometimes there's the black hole of the Apple interoperability thing, because we just don't get back answers sometimes.
*03:35:10-03:35:18*

There's mugs.
*03:35:18-03:35:18*

Bruce had the question about 16 mugs.
*03:35:18-03:35:21*

Reply is, it's not really workable.
*03:35:21-03:35:24*

Thank you.
*03:35:24-03:35:25*

Thank you.
*03:35:25-03:35:27*

Please.
*03:35:27-03:35:29*

Hi, Francesco Versace from Spotify.
*03:35:29-03:35:32*

First of all, thank you for the honorable mention earlier.
*03:35:32-03:35:34*

Really happy that we're able to grow as a successful company, in some cases, despite of the restrictions that we encountered from Apple.
*03:35:34-03:35:43*

And I think the US case was mentioned before.
*03:35:43-03:35:46*

We are seeing very positive results from the freedom that we see in the US right now.
*03:35:46-03:35:51*

Two questions.
*03:35:51-03:35:52*

Obviously, we have a very different interpretation of free of charge steering.
*03:35:52-03:35:56*

I won't mention that.
*03:35:56-03:35:58*

My first question is on the initial acquisition fee.
*03:35:58-03:36:01*

That's set for six months at 2%.
*03:36:01-03:36:04*

It seems to us has been very long for compensating the initial matchmaking service.
*03:36:04-03:36:11*

So I would really appreciate any clarity on how that time frame was set up.
*03:36:11-03:36:17*

And the second question is on the other fees, so the CTC and the store services fee.
*03:36:17-03:36:23*

It seems from my reading of the rules that these are to compensate services that are provided across the board, not only to digital goods and services developers.
*03:36:23-03:36:34*

So I'm really curious to understand why they're set in a way that they're payable only by digital goods and services developers that avail of the option of steering, because it doesn't seem to make sense to me.
*03:36:34-03:36:45*

Thank you.
*03:36:45-03:36:46*

Thank you.
*03:36:46-03:36:48*

Who has the last questions, please?
*03:36:48-03:36:49*

Hello.
*03:36:52-03:36:53*

My name is Frederick Riedel.
*03:36:53-03:36:55*

I'm from the company called Riedel.WTF, and I make an app called OneSec, which is always much easier to show than to explain.
*03:36:55-03:37:05*

So whenever you open social media apps, it forces you to take a deep breath and helps you to spend a little less time on social media.
*03:37:05-03:37:13*

So it's quite popular right now, because a lot of people want to spend less time on social media, but that's not what we are here for today.
*03:37:13-03:37:20*

My question is more about building apps like this.
*03:37:20-03:37:25*

This is an indie app, so I'm an independent developer.
*03:37:25-03:37:29*

I've been making apps since I was 15, and I've been using the App Store to build up a living from it and to build up a company.
*03:37:29-03:37:40*

I have hired around 15 employees now, and I'm just very happy to have this opportunity.
*03:37:40-03:37:47*

But at the same time, of course, that means I'm also a bit scared, because as Kyle has mentioned earlier as well, users on Apple platforms, they are very happy to try out smaller apps by smaller developers, because they trust the platform, the App Store, the ecosystem.
*03:37:47-03:38:08*

They prefer the interconnectedness and the integration of Apple platforms, and I'm just a little bit scared that now, with all these new rules coming in, it's all becoming much more complicated, both for me as a small independent developer, but also for my potential customers that might have bad experiences and might be less open to try out new apps in general, because they might have bad experiences here and there when they leave this more controlled, integrated ecosystem that Apple provides.
*03:38:08-03:38:46*

Thank you.
*03:38:46-03:38:48*

Thank you.
*03:38:48-03:38:48*

You will have to hire a lawyer, I think.
*03:38:48-03:38:51*

I'll take one last one, and then we break for lunch.
*03:38:51-03:38:54*

Please, you've been very patient.
*03:38:54-03:38:56*

Me?
*03:38:56-03:38:56*

Yeah.
*03:38:56-03:38:57*

Thank you very much.
*03:38:57-03:38:58*

I'm Stefan from Cranberry Apps, also a small indie studio from Berlin.
*03:38:58-03:39:04*

My question goes into the same direction.
*03:39:04-03:39:06*

I think the App Store is amazing for small developers.
*03:39:06-03:39:09*

It gives a chance to reach the world where just having to code and not have all this information about legal and everything.
*03:39:09-03:39:16*

Just wanted to clarify, what is the new standard?
*03:39:16-03:39:19*

If you want to dive into this market as a new developer, what is the standard fee, the standard rules that apply to me without having any knowledge about tier 1, tier 2, legal information, legal support?
*03:39:19-03:39:34*

I just want to dive in, sell my app, and do what I can do best.
*03:39:34-03:39:38*

Well, that's it.
*03:39:38-03:39:41*

Thank you, Kyle.
*03:39:41-03:39:42*

Floor is yours.
*03:39:42-03:39:43*

I think I'll give Kyle a break for a quick moment.
*03:39:46-03:39:49*

And were you offering yourself there, Lucia, as a job?
*03:39:49-03:39:53*

As a lawyer?
*03:39:53-03:39:53*

[LAUGHTER]
*03:39:53-03:39:56*

This is for-- to James.
*03:39:56-03:39:59*

Open Web Apps-- Open Web Advocacy is getting a good run of that today.
*03:39:59-03:40:05*

I will say our ability to know at the start of the interoperability specification process what the outcome was was kind of hard to manage.
*03:40:05-03:40:14*

I think I would have needed to know a lot to work out by the end of it what precisely we were supposed to do.
*03:40:14-03:40:20*

So I think one needs to take account of the time period, the discussion, the correct outcome, what the commission had in mind, what we could agree to before one could work towards an acceptable outcome.
*03:40:20-03:40:33*

But I believe the process is working really well now.
*03:40:33-03:40:37*

I believe requests are coming in.
*03:40:37-03:40:39*

We are responding within the allotted time.
*03:40:39-03:40:41*

We have some very specific times that we need to respond by.
*03:40:41-03:40:46*

All of those times have been met.
*03:40:46-03:40:47*

Not one single one of those has been missed in the time period in which we've been asked to respond then.
*03:40:47-03:40:57*

I think there was a second part to your question.
*03:40:57-03:41:00*

Yeah.
*03:41:00-03:41:01*

Yeah.
*03:41:01-03:41:01*

Thank you, James.
*03:41:01-03:41:08*

OK.
*03:41:08-03:41:09*

OK.
*03:41:09-03:41:12*

You ask over lunch.
*03:41:12-03:41:14*

I can hop in quickly.
*03:41:14-03:41:15*

We wanted to say that, Kyle, you were saying that we're open for comments and please reach out to us.
*03:41:15-03:41:20*

The App Store does not have a report scam button, so we can't reach out to you.
*03:41:20-03:41:24*

So in-- In the time while I was sitting here, I typed in the phrase, report App Store abuse to Apple.
*03:41:24-03:41:36*

And I very helpfully got to report App Store abuse to Apple, navigate to the Apps page on the App Store, scroll to the bottom and select Report a Problem.
*03:41:36-03:41:45*

Then choose the appropriate reason for your report, such as report a scam or fraud, or report offensive, illegal, or abusive content.
*03:41:45-03:41:54*

It's on every single product page for every single app that's available on the App Store, very prominently.
*03:41:54-03:42:01*

So I guess I get to-- I'm supposed to OWA, I get to talk to Spotify.
*03:42:01-03:42:10*

First, I get it.
*03:42:10-03:42:13*

You've been very clear over the years that you would like to have access to everything for free.
*03:42:13-03:42:17*

And we understand that.
*03:42:17-03:42:19*

I think you asked two specific questions around the IAF and the SSF.
*03:42:19-03:42:24*

The IAF, the initial acquisition fee, applies to brand new users, not the tens of millions or hundreds of millions of users you've acquired on iOS already, but rather the new users you may acquire on iOS.
*03:42:24-03:42:37*

And we've charged a very low 2% fee over six months.
*03:42:37-03:42:42*

If it's compared to other referral fees-- and I know Spotify has dozens of these agreements with carriers and with retailers and others, all of which are much richer than that.
*03:42:42-03:42:52*

And so we think it's a great deal.
*03:42:52-03:42:54*

In terms of the store services fee, I think it's important to remember that Spotify has been downloaded, redownloaded, updated more than 119 billion times across the app stores in the world.
*03:42:54-03:43:09*

It's available in the app store in over 160 different countries and it always has been.
*03:43:09-03:43:14*

Spotify has used our beta testing tool over and over and over again to test over 500 versions of its app.
*03:43:14-03:43:21*

Our app review team has reviewed over 400 versions of Spotify's app.
*03:43:21-03:43:28*

The amount of work and amount of effort that we go into supporting Spotify is almost unequaled.
*03:43:28-03:43:35*

And so yes, in the context here, if Spotify decides to take advantage of this, they will pay a store services fee.
*03:43:35-03:43:43*

But there are choices here.
*03:43:43-03:43:45*

For example, if Spotify simply wants to have a static promotion without a commission, they can do that without paying us.
*03:43:45-03:43:52*

And so we've provided a range of different options, including for the wealthiest, most successful, dominant companies here in Europe.
*03:43:52-03:43:59*

And so that is available.
*03:43:59-03:44:03*

I'm going to talk to my friend who's-- please don't get a lawyer, trust me.
*03:44:03-03:44:06*

And I am a lawyer.
*03:44:06-03:44:07*

Don't get a lawyer.
*03:44:07-03:44:09*

If there is complexity, we are going to look to make it as simple as possible.
*03:44:09-03:44:15*

And I understand that change is hard and change can be scary, particularly when you've had success in building your business.
*03:44:15-03:44:21*

That's in part why we wanted as long a transition period as possible.
*03:44:21-03:44:24*

It's in part why we've introduced terms on both sets of terms that we have live here in Europe.
*03:44:24-03:44:30*

We're going to be as transparent as possible about what is the path from here to January 1st.
*03:44:30-03:44:35*

I'd encourage you to reach out to our developer relations team.
*03:44:35-03:44:39*

Happy to get that contact for you to answer specific questions.
*03:44:39-03:44:42*

We want to be in a place where this is as simple as possible, given the box that we're operating under.
*03:44:42-03:44:48*

And so this is particularly important for us in terms of small and medium-sized businesses, because this is a place where we've leaned in over the last couple of years.
*03:44:48-03:44:58*

We are concerned about having an app store for the few as opposed to the app store for the many.
*03:44:58-03:45:02*

And so we're going to continue to lean in on that in terms of how can we make this as simple as possible.
*03:45:02-03:45:07*

It's in part why we took the IAF down to zero for small businesses.
*03:45:07-03:45:11*

It's in part why we've reduced the store services fee to 5% for small businesses.
*03:45:11-03:45:16*

And we want to look for other ways to make this as seamless and easy as possible.
*03:45:16-03:45:20*

What I can say is the prices for small and medium-sized businesses will not go up as a result of these changes.
*03:45:20-03:45:28*

But I know there's going to be business changes.
*03:45:28-03:45:30*

I know there's process changes.
*03:45:30-03:45:33*

We're here to help you and the other gentleman from Berlin through this transition.
*03:45:33-03:45:39*

And we've also-- I think what we demonstrated last year at this workshop, when a concern is raised, particularly from the perspective of somebody small or somebody independent, we are very receptive to figuring out how can we make things better, how can we make this easier.
*03:45:39-03:45:52*

And so I'd encourage you to reach out and let us know as you dig into this.
*03:45:52-03:45:55*

And again, I know a lot of this is brand new.
*03:45:55-03:45:58*

It can be complicated at first glance.
*03:45:58-03:46:00*

But our commitment over the next six months is to try and make that as simple as possible.
*03:46:00-03:46:04*

Excellent.
*03:46:04-03:46:10*

So with this, we are a quarter past 1.
*03:46:10-03:46:13*

So only 15 minutes behind the schedule.
*03:46:13-03:46:16*

I invite everyone in the room for the lunch.
*03:46:16-03:46:18*

Those who are on the slide, though, please have something as well.
*03:46:18-03:46:21*

And the price must be even more difficult to follow, I think, online.
*03:46:21-03:46:29*

We will be back in the room at 2.
*03:46:29-03:46:30*

Let's try to shorten the lunch by 15 minutes so that we are not too much behind the schedule on the back end, because some people are traveling back home.
*03:46:30-03:46:39*

Thank you, and see you at 2.
*03:46:39-03:46:43*

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I should say that the lunch break-- so the food.
*03:47:24-03:47:29*

Super important information for people in the room, please.
*03:47:29-03:47:33*

Quiet.
*03:47:33-03:47:34*

The lunch is on the fifth floor.
*03:47:34-03:47:36*

So don't think that the commission doesn't give you lunch.
*03:47:36-03:47:39*

So the lunch is on the fifth floor.
*03:47:39-03:47:42*

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*04:31:30-04:31:31*

Welcome back.
*04:31:31-04:31:32*

[SIDE CONVERSATION]
*04:31:32-04:31:35*

Can we please start settling down?
*04:31:35-04:31:46*

We'll start in two minutes.
*04:31:46-04:31:48*

Excellent.
*04:31:48-04:31:51*

Kyle is back.
*04:31:51-04:31:56*

Very good.
*04:31:56-04:31:57*

I just wanted to make sure I didn't [INAUDIBLE]
*04:31:58-04:32:00*

[SIDE CONVERSATION]
*04:32:00-04:32:03*

So welcome back.
*04:32:03-04:32:09*

After lunch, sorry about the small excursion to the fifth floor.
*04:32:09-04:32:16*

It was good to have a little sport.
*04:32:16-04:32:19*

So we are back.
*04:32:19-04:32:20*

And this afternoon, we will have two sessions.
*04:32:20-04:32:23*

One is on choice architecture for browsers and browsers more generally.
*04:32:23-04:32:29*

And then we will have one on data portability after the coffee break, I believe.
*04:32:29-04:32:36*

We will start now with the browser choice screen.
*04:32:36-04:32:39*

And my colleague, Kasia, will introduce the commission background to the discussion.
*04:32:39-04:32:48*

Thank you.
*04:32:48-04:32:50*

Thanks, Lucia, and good afternoon, everyone.
*04:32:50-04:32:54*

So Article 6.3 is about empowering users with the freedom of choice for the browser and other apps on their devices.
*04:32:54-04:33:03*

This provision aims at making switching of default settings and an installation of apps easy, allowing users to quickly tailor the device according to their and not gatekeepers' preferences.
*04:33:03-04:33:16*

It also helps providers of apps which are not pre-installed on devices out of the box to become more visible to users.
*04:33:16-04:33:23*

For Apple specifically, Article 6.3 imposes an obligation to display a choice screen for browsers.
*04:33:23-04:33:31*

Furthermore, it obliges Apple to enable end users to switch default applications which are initially set in favor of Apple's apps and to uninstall Apple's pre-installed apps on iOS and iPadOS devices.
*04:33:31-04:33:44*

So let's see how it played out in practice.
*04:33:44-04:33:50*

We have been engaging with Apple on their compliance measures for Article 6.3 since their designation.
*04:33:50-04:33:56*

Following discussions, we identified several concerns which led us to open a non-compliance investigation on 25th of March, 2024.
*04:33:56-04:34:06*

We were particularly concerned about Apple's choice screen for browsers.
*04:34:06-04:34:12*

The choice screen was not only shown to users who had Safari set as default, but also to the users who had set other browsers as default.
*04:34:12-04:34:22*

So rather than increasing the contestability of Safari, this weakened third-party browsers and user choices.
*04:34:22-04:34:28*

The choice screen operated on a per-user basis, meaning that users potentially would have made the choice in a choice screen only once in their lifetime.
*04:34:28-04:34:38*

There were also instances of unequal treatment of Safari and alternative browsers.
*04:34:38-04:34:45*

So this could exploit users' biases in favor of Safari.
*04:34:45-04:34:50*

In addition, users couldn't change defaults in relation to many Apple's applications.
*04:34:50-04:34:55*

And some applications couldn't be uninstalled.
*04:34:55-04:34:58*

They could only be removed from the home screen.
*04:34:58-04:35:00*

However, during the proceedings and following intense regulatory dialogue, without the issuance of preliminary findings, we have seen a lot of changes.
*04:35:00-04:35:16*

Apple announced a new 6.3 compliance plan on 27th of August, 2024, which changed the setting.
*04:35:16-04:35:25*

So first, there were a few updates to the choice screen, which allowed for an easier and more neutral browser selection.
*04:35:25-04:35:35*

So the choice screen is displayed to users in a targeted way, so it is addressed only to Safari users.
*04:35:35-04:35:44*

Then it is displayed each time a user buys a new device.
*04:35:44-04:35:47*

In addition, it puts Safari and alternative browsers on equal footing.
*04:35:47-04:35:55*

So we have the same number of clicks, the same download process for each browser, no matter what is their provider.
*04:35:55-04:36:03*

The choice screen is also improved in terms of its design and removing status quo biases.
*04:36:03-04:36:10*

So the choice screen is not skippable.
*04:36:10-04:36:12*

The users truly need to engage with it.
*04:36:12-04:36:15*

They also need to engage with all the providers.
*04:36:15-04:36:18*

So the users need to scroll through the whole list before making a selection.
*04:36:18-04:36:25*

They can also find out more about different options by accessing contextual information.
*04:36:25-04:36:32*

Moreover, selected default browser takes Safari place in the doc once the user made selection.
*04:36:35-04:36:42*

So the chosen browsers are, in fact, also used according to the user's preferences.
*04:36:42-04:36:50*

There are also no prompts, which request users to change the default browser back to Safari.
*04:36:50-04:36:56*

And finally, speaking about browser providers, they have access to an API, which enables developers to verify whether the browser is set as default and how it generally performs in the choice screen.
*04:36:56-04:37:08*

Apple also improved other compliance measures.
*04:37:08-04:37:13*

So it made it easier for users to change default settings for other apps, such as calling, messaging, and password managers.
*04:37:13-04:37:20*

There is also a new menu, which allows users to change their default settings in one centralized location, streamlining the user customization process.
*04:37:20-04:37:33*

In addition, EU users can now uninstall several Apple pre-installed apps, such as App Store or Photos, a functionality which was previously unavailable.
*04:37:33-04:37:46*

In light of this, the commission decided to no longer pursue the proceedings and to close them.
*04:37:46-04:37:53*

We are, however, closely monitoring the implemented measures and continue our regulatory dialogue with Apple.
*04:37:53-04:38:00*

If necessary, we stand ready to use the available enforcement tools under the DMA.
*04:38:00-04:38:07*

And with this, I will pass the floor to Apple.
*04:38:07-04:38:10*

But before, I would like to take the opportunity to thank all the third parties for their valuable input into the investigation.
*04:38:10-04:38:19*

On this note, we encourage you to listen to Apple's presentation and share any questions you may have for Apple in the upcoming Q&A session.
*04:38:19-04:38:27*

Thank you.
*04:38:27-04:38:27*

Great, thank you.
*04:38:30-04:38:31*

And congratulations to the hearty few that made it through the lunch break and are here for the afternoon.
*04:38:31-04:38:37*

For anyone who wasn't here this morning, my name is Kyle Landier.
*04:38:37-04:38:41*

I'm the vice president for products and regulatory law at Apple.
*04:38:41-04:38:44*

I'm joined by my friend and colleague Gary Davis, a senior director on our team.
*04:38:44-04:38:49*

The commission has asked us to provide an update on the first year of compliance with Article 6(3)'s requirements with regard to browser choice and defaults.
*04:38:49-04:38:59*

At last year's workshop in March, we explained our initial approach to the choice screen, which was adopted for EU users in response to the DMA.
*04:38:59-04:39:09*

Since then, we've had a number of conversations with the European Commission, developers, and other stakeholders, some of whom are in this room.
*04:39:09-04:39:18*

And we made a number of changes, including some that directly respond to questions and concerns raised last year.
*04:39:18-04:39:25*

These workshops are only one opportunity for us to hear from developers, who have taken advantage of the numerous avenues for feedback and engagement we've made available.
*04:39:25-04:39:34*

We continuously listen to and engage with developers' concerns, and the latest design of the choice screen implements many suggestions that came directly from developers.
*04:39:34-04:39:45*

In particular, we made significant changes with iOS and iPadOS 18.2 this past December in an effort to continue to be responsive to the European Commission and the specific feedback we've heard from developers.
*04:39:45-04:39:59*

These are changes that go significantly further than the other designated companies who are subject to the obligations of Article 6.3.
*04:39:59-04:40:07*

One example is the fact that Apple, and Apple alone amongst all designated gatekeepers for browsers, has been required to replace Safari on the dock or in the home screen for the browser selected on the choice screen.
*04:40:07-04:40:20*

Our implementation also ensures that the choice screen is rolled out to the vast majority of iPhones and iPads in Europe.
*04:40:20-04:40:28*

That also makes us unique.
*04:40:28-04:40:31*

Our conversations with the Commission resulted in us enabling the deletion of more native apps than any other regulated company.
*04:40:31-04:40:39*

And our changes were completed months earlier than other regulated companies were required to do so.
*04:40:39-04:40:45*

To put it plainly, these amount to special rules just for Apple.
*04:40:45-04:40:49*

And their result?
*04:40:49-04:40:51*

A markedly unlevel playing field.
*04:40:51-04:40:53*

And to be frank, an increase in Chrome's dominance.
*04:40:53-04:40:57*

Beginning with the choice screen, a year in, we have some real data about how it actually operates in practice and how users are interacting with the choice screen.
*04:40:57-04:41:07*

While we think we understand the Commission's goal with the choice screen of encouraging users to give browsers from smaller developers a chance, what the statistics show, as I'll get into more later, is that the choice screen has not resulted in significant growth for smaller browsers.
*04:41:07-04:41:22*

But instead, Chrome growing only more dominant.
*04:41:22-04:41:26*

This illustrates the very real unintended consequences of regulation that can materialize, which is something we encourage everyone to keep in mind, both today and in compliance discussions to come.
*04:41:26-04:41:38*

When we first introduced Safari on iPhone, it revolutionized the mobile web.
*04:41:38-04:41:43*

But Safari has never been dominant.
*04:41:43-04:41:45*

And we've consistently had a significantly smaller share of the EU mobile browser market than Chrome.
*04:41:45-04:41:52*

This is what browser market share looked like two years ago, according to StatCounter.
*04:41:52-04:41:57*

Chrome, around 55% of the market.
*04:41:57-04:41:59*

Safari, around 34%.
*04:41:59-04:42:02*

And everyone else together, around 10%.
*04:42:02-04:42:05*

Apple also has a history of making it easy for users to choose their own defaults and customize their user experience.
*04:42:05-04:42:13*

Going back as far as iOS 14, users could set a default browser in email apps.
*04:42:13-04:42:19*

With iOS 11, users could customize their dock.
*04:42:19-04:42:23*

With iOS 10, users could delete pre-installed apps like Watch, Calculator, Reminders, and others.
*04:42:23-04:42:31*

And going back to iOS 8, more than 10 years ago, users could set customized keyboards.
*04:42:31-04:42:36*

These are just a few examples.
*04:42:36-04:42:39*

Users could easily choose to set a browser other than Safari as their default long before the DMA.
*04:42:39-04:42:46*

A report commissioned by the UK Competition and Market Authority found that even before our DMA-related changes, 8 in 10 users felt confident in switching default browsers.
*04:42:46-04:42:57*

And 9 in 10 felt the process was easy.
*04:42:57-04:43:01*

So the beauty of the software revolution at the App Store created in 2008 is that users have a wide variety of choices for almost every technology imaginable that works on a mobile phone.
*04:43:01-04:43:11*

Now, I'll turn it over to Gary to give you more specifics on our updated approach under the DMA.
*04:43:11-04:43:18*

Thank you, Kyle.
*04:43:18-04:43:19*

And I particularly commend anybody who's still wearing a jacket in the room.
*04:43:19-04:43:24*

So well done on doing so.
*04:43:24-04:43:27*

So I'm going to go through a little bit more of the detail.
*04:43:27-04:43:29*

So under the DMA, Apple continues to make it easy for users to choose a browser as a default.
*04:43:29-04:43:36*

When Article 6(3) came into effect, Apple taught carefully about how it should implement the choice screen requirement.
*04:43:36-04:43:43*

Since the end of last year, all EU users have seen the choice screen when opening Safari for the first time after they update their devices to iOS and iPadOS 18.2 if they have set Safari as their default browser.
*04:43:43-04:44:00*

At the Commission's request, we actually don't show this choice screen after a user updates their device to iOS and iPadOS 18.2 if a user already has a browser other than Safari set as their default.
*04:44:00-04:44:16*

So if a user has already selected another browser as their default, even if it is the dominant mobile browser Chrome, they are not asked whether they want to change the browser.
*04:44:16-04:44:27*

In fact, Chrome can, like any other browser on iOS, continue to prompt users to choose their browser app as the default, even if they've already selected another browser.
*04:44:27-04:44:39*

Additionally, the choice screen is shown once per device instead of once per user.
*04:44:39-04:44:44*

A user's browser selection is not carried across all of their devices or migrated into a new device.
*04:44:44-04:44:52*

Instead, a user will be presented with the choice screen when launching Safari and required to make a decision again.
*04:44:52-04:45:01*

There is no prompting if a user had selected a browser other than Safari as their default.
*04:45:01-04:45:07*

This creates an experience in which, if you choose Safari, we keep asking you over and over again if you want to keep using Safari.
*04:45:07-04:45:17*

We have taken a number of steps to require users to make a decision about browser selection on the choice screen itself, even when it might make it less convenient and more frustrating for the user.
*04:45:17-04:45:29*

And the design goes out of its way to ensure that it in no way preferences Safari.
*04:45:29-04:45:35*

Now, let's walk through what the process looks like step by step.
*04:45:35-04:45:38*

When a user first opens Safari and encounters the choice screen process, whether they're setting up a new iPhone or iPad or they're updating an existing device that has Safari set as the default browser, the screen will show a neutral education page to inform the user about the choice they're being asked to make.
*04:45:38-04:46:02*

In a few minutes, I'll show you exactly how easy we've made it for users to do that.
*04:46:02-04:46:07*

The user then clicks Continue and moves from the About Your Default Browser page on the choice screen itself.
*04:46:07-04:46:13*

As you can see, when the user taps on a browser option, a blue check mark appears next to the selected application.
*04:46:13-04:46:21*

And then the user needs to scroll down and tap Set as Default Browser.
*04:46:21-04:46:26*

Users can only select one option.
*04:46:26-04:46:28*

They can change their choice if they wish by tapping another application.
*04:46:28-04:46:34*

Users don't have the option to skip this screen.
*04:46:34-04:46:38*

So we have also been working to make sure that they have enough information to make an educated choice.
*04:46:38-04:46:44*

That's what users expect from Apple, mechanisms that enable them to make informed decisions.
*04:46:44-04:46:51*

And that's consistent with the text and purpose of the DMA, which is not about achieving a particular outcome, but about facilitating user choice and autonomy.
*04:46:51-04:47:03*

As of iOS and iPadOS 18.2, the browser descriptions on the choice screen now also include the app's subtitle from the browser's App Store product page.
*04:47:03-04:47:14*

Developers can write copy, including the browser's advertised speed and security, or whatever else the browser developer chooses, in fact.
*04:47:14-04:47:24*

You can see an example here of Firefox.
*04:47:24-04:47:29*

If a user wants more information about the browser, they can tap the chevron, the little arrow to the right, which will let them view the browser's App Store product page, which we're on there.
*04:47:29-04:47:40*

On the App Store product page, a user can see user reviews and what's new about the latest version, among all the other information available on the page.
*04:47:40-04:47:49*

Developers can also add text to educate users about what distinguishes their service from others.
*04:47:49-04:47:56*

At the bottom of the App Store page, users can see the privacy nutrition labels, which facilitate informed user consent to the collection and use of their data, which we know is a cause near and dear to the commission's heart, as well as our own.
*04:47:56-04:48:12*

Safari continues to be treated exactly the same on the choice screen as any other browser, as you can see on the slide.
*04:48:12-04:48:21*

Apple displays up to 11 of the top downloaded browsers in any given country, in addition to Safari, in a fully randomized order for each user.
*04:48:21-04:48:32*

This means there's as much of a chance of Firefox, DuckDuckGo, Edge, Ecosia, or Chrome coming up first on your device as there is Safari.
*04:48:32-04:48:43*

To select the 11 browsers to include for a given country, we select the most downloaded browsers that meet certain minimum criteria.
*04:48:43-04:48:54*

If there are fewer than 11 qualifying browsers, Apple will supplement with additional browsers in the country based on EU-wide downloads.
*04:48:54-04:49:05*

We update the list of browsers eligible to be shown on the choice screen once a calendar year.
*04:49:05-04:49:12*

We continue to require users to scroll through the full list of browser options on the choice screen before they can select any browser as their default.
*04:49:12-04:49:22*

Users can select their default browser directly on the choice screen without necessarily seeing descriptive information on the App Store product page for the browser, as we just saw, meaning they may be making the decision based only on name recognition.
*04:49:22-04:49:37*

And now, if the default browser that a user selects is already downloaded on their device, the chosen browser will automatically open once chosen.
*04:49:37-04:49:45*

If the chosen browser is not already downloaded on the user's device, the choice screen will show the selected browser's download progress before automatically opening without directing the user to the App Store.
*04:49:45-04:50:03*

We've also made significant efforts to share information and data with developers.
*04:50:03-04:50:08*

In line with the comments we heard from many developers and stakeholders, like DuckDuckGo, Ecosia, and Buick on this topic at last year's workshop, and since then through our ongoing engagement.
*04:50:08-04:50:20*

As illustrated by the hypothetical data here-- don't worry, I'm not about to take you through each line-- since August 2024, Apple has made a new set of data available to developers about their browser's performance on the choice screen.
*04:50:20-04:50:34*

As you can see on this slide, the data includes metrics such as selection rates and information about default selection.
*04:50:34-04:50:40*

This is accessible via a dedicated API in App Store Connect.
*04:50:40-04:50:47*

For example, Ecosia raised their concern that they could not detect if their app is a default browser.
*04:50:47-04:50:53*

Now you can.
*04:50:53-04:50:54*

We have offered a new API that allows browser apps to check four times per year whether they have been set as a default. Developers now have extensive data, including, for example, how many users selected a browser they did or did not already have on their device, and how many users selected a browser with or without viewing its product page.
*04:50:54-04:51:14*

We've also undertaken significant efforts to ensure developers understand this information is available to them.
*04:51:14-04:51:21*

For example, last October, we proactively reached out to developers to inform them of the new choice screen data report and seek their feedback.
*04:51:21-04:51:30*

And our engagement with developers on these issues was not a one-time initiative.
*04:51:30-04:51:34*

It remains ongoing.
*04:51:34-04:51:37*

Apple has a dedicated team to respond to and work with developers to understand their needs in this space.
*04:51:37-04:51:43*

Kyle?
*04:51:43-04:51:46*

So that's what browser choice looks on iPhone and iPad and EU today.
*04:51:46-04:51:51*

But before we move on, we want to give an update on the impact of the choice screens one year into compliance.
*04:51:51-04:51:57*

We think it's important to see how it's actually playing out in the real world.
*04:51:57-04:52:02*

We rolled out these changes on all eligible devices in the EU in contrast to other gatekeepers.
*04:52:02-04:52:09*

Every device that updates to iOS or iPadOS 18.2 or later will see the choice screen.
*04:52:09-04:52:16*

But as a number of you in the room have noted, other companies have not completely rolled out their choice screens.
*04:52:16-04:52:23*

That means there may be hundreds of millions of our competitors' devices that aren't subject to this requirement.
*04:52:23-04:52:29*

And we don't really understand how this can be the case.
*04:52:29-04:52:32*

And as I mentioned at the start, what we've seen over the course of the year of users interacting with this choice screen is an unintended consequence.
*04:52:32-04:52:40*

The dominant player in the browser market is becoming even more dominant.
*04:52:40-04:52:45*

Between December 2024 and April 2025, following our latest changes on iOS and iPadOS 18.2, of users who switched to fault browsers when faced with the choice screen, by far the largest percentage, nearly nine of every 10 users who did not choose Safari chose another regulated company's browser.
*04:52:45-04:53:08*

The next tranche of browsers are longstanding browser options not run by other designated companies, like Firefox and Opera.
*04:53:08-04:53:16*

Less than 8% of users who moved away from Safari chose those options.
*04:53:16-04:53:21*

And if you combine all the other browsers which have been given the benefit of free advertising space and a slogan of their choice, and a direct link to their App Store page for the easiest possible selection, they are seeing a combined take-up rate of less than 5% of switchers.
*04:53:21-04:53:37*

Meanwhile, Apple, through extensive feedback from the commission, has designed a solution and other regulated companies haven't been required to fully roll out.
*04:53:37-04:53:46*

And while our solution gives users plenty of opportunity to change their default browser at any time, the overarching end result has been an increase in the market share of the dominant browser.
*04:53:46-04:53:57*

Earlier, I showed you this chart from May of 2023, two years ago, of StatCounter's mobile and tablet browser market share in the EU before the DMA.
*04:53:57-04:54:07*

Now, here's what it's looked like two years later.
*04:54:07-04:54:10*

In May of 2025, several months after our implementation of the revised choice screen, the smaller browsers have the same overall share as they did before.
*04:54:10-04:54:20*

And Chrome's increased about 4%.
*04:54:20-04:54:24*

Many of the Safari choice screen design changes that you have just now seen are taken directly from Google's choice screen for Chrome at the commission's request.
*04:54:24-04:54:32*

But as the data shows, this design has not led to the growth of smaller browsers.
*04:54:32-04:54:37*

It has just increased the dominant player's share of the market.
*04:54:37-04:54:40*

Now, let's proceed to the next stage of the user experience.
*04:54:44-04:54:48*

They've selected their default browser from the choice screen.
*04:54:48-04:54:51*

Now, let's examine how it's displayed on their device.
*04:54:51-04:54:56*

With the changes with iOS and iPadOS 18.2, the EC has asked us, from what we understand, alone among designated companies, to make some significant changes to how the selected default browser is displayed on users' devices.
*04:54:56-04:55:11*

We've made those changes, which also reflect feedback from consumer organizations, feedback we take very seriously.
*04:55:11-04:55:19*

In short, these changes mean that in almost every situation where a user does not choose Safari as the default option, Safari will be removed from the dock or first page of the home screen.
*04:55:19-04:55:32*

For example, if Safari is in a user's dock or on the first page of the home screen, and the user selects a browser that is not currently installed on the device from the choice screen, then the selected browser-- in this case, DuckDuckGo-- is downloaded and immediately replaces Safari in the user's dock or home screen.
*04:55:32-04:55:53*

No action is needed from the user, and this replacement happens even if the user would have preferred to keep Safari in the dock or on the home screen.
*04:55:53-04:56:02*

If the user selects a browser from the choice screen that is currently installed on the device, but is not on the first page of the home screen or the dock, the selected browser will likewise be promoted and automatically replace the Safari icon in the user's dock or on the home screen, as we can see here.
*04:56:02-04:56:21*

And the last permutation is if, before updating to iOS 18.2, Safari was in the user's dock or on the first page of the home screen, the user had selected another browser as their default, and the default browser is not already on the first page of the home screen or the dock.
*04:56:21-04:56:37*

In that case, the user is now asked, as you can see in this slide, upon first launch of Safari, about whether they want to swap Safari with their default browser.
*04:56:37-04:56:47*

The bottom line is this.
*04:56:47-04:56:50*

Once a user chooses a default browser app, unless that default is Safari, it will automatically appear on their home screen or dock with no additional action needed from the user.
*04:56:50-04:57:05*

Now, let's talk about defaults and uninstallation more broadly.
*04:57:05-04:57:10*

For years, we made it possible for users to remove Apple apps from the home screen.
*04:57:10-04:57:15*

We had this capability and did this affirmatively.
*04:57:15-04:57:19*

But after the DMA, we were pushed to go further, further than any other gatekeeper, to not only allow users to remove native apps, but delete them altogether.
*04:57:19-04:57:29*

And we're going to talk about the consequences of that.
*04:57:29-04:57:33*

But first, we've made it easy for users to change the default browser to the dedicated defaults page and settings.
*04:57:33-04:57:40*

They can also set their default apps for categories like app installation, messaging, calling and call filtering, navigation, translation, and passwords and codes.
*04:57:40-04:57:52*

For example, password managers, which offer enormous security benefits, allowing users to securely store and retrieve their credentials by complex master password or biometric security features.
*04:57:52-04:58:05*

Users can install their preferred password manager app, such as 1Password, Bitwarden, or LastPass.
*04:58:05-04:58:12*

Then on the dedicated defaults page, users can select their preferred password manager, apps or apps of their choice, including Apple passwords.
*04:58:12-04:58:22*

After setting their preferred default app, that password manager will automatically initiate when a user is asked to enter a password for an app marked for password autofill.
*04:58:22-04:58:35*

This is just one example of functions that make it even easier for users to use their iPhone.
*04:58:35-04:58:40*

Of course, and long before the DMA, users can remove apps from the home screen, and now delete even more apps as well.
*04:58:40-04:58:51*

The EC asked us to give users the ability to delete Apple services and platforms preloaded onto phones.
*04:58:51-04:58:58*

So as another change we made with iOS and iPadOS 18.2, Apple users in the European Union can now delete certain built-in apps for the first time, including Safari, as well as messages, the App Store, camera, and photos.
*04:58:58-04:59:13*

From what we understand, as of today, Apple is the only gatekeeper that enables users to completely uninstall these apps.
*04:59:13-04:59:24*

I'll just take you through the process now.
*04:59:24-04:59:27*

In order to delete a Safari app from an iPhone or iPad, a user will first need to install an alternative web browser and set it as their default browser app using the process we discussed.
*04:59:27-04:59:37*

That step is necessary so that user is not left without a browser app on their device.
*04:59:37-04:59:42*

We cannot cut users off from the internet.
*04:59:42-04:59:45*

That would fundamentally break their device experience.
*04:59:45-04:59:49*

Then on the iPhone or iPad, the user can touch and hold the app, tap Remove App or Delete App from the shortcut menu, and tap Delete App or Delete from the submenu.
*04:59:49-05:00:00*

Deleting Safari will also delete browsing history and website data stored on the device.
*05:00:00-05:00:08*

In order to delete a Messages app from an iPhone or iPad, a user will first need to install an alternative messaging service.
*05:00:08-05:00:15*

Then the user sets the alternative as their default messaging app on the Apps page in Settings.
*05:00:15-05:00:21*

To do so, the user simply needs to tap the Default Apps icon at the top of the list and change their current default to a different app.
*05:00:21-05:00:30*

Again, it is critical for users that they have a means to send and receive messages, including in emergency situations.
*05:00:30-05:00:37*

Deleting the Messages app will impact certain user experiences.
*05:00:37-05:00:41*

For example, if the user is not using Messages in iCloud, all photos, video, and other items shared with the user via Messages will be deleted.
*05:00:41-05:00:51*

The device will also not be able to send or receive text messages.
*05:00:51-05:00:55*

For example, a user might have trouble receiving two-factor authentication messages sent over SMS, used commonly across websites and apps, and even the public Wi-Fi system here in Brussels.
*05:00:55-05:01:07*

To set up and log into accounts or otherwise authenticate themselves.
*05:01:07-05:01:11*

Users can also delete the App Store from their phone or iPad.
*05:01:11-05:01:18*

Like with Messages and Safari, a user will first have to download an alternative app marketplace and set it as their default for downloading apps.
*05:01:18-05:01:27*

Again, the reason for this first step is that the absence of any app marketplace on a user's device would obviously severely inhibit a user's ability to use that device.
*05:01:27-05:01:36*

It is not what a user would expect.
*05:01:36-05:01:38*

After deleting App Store, users can still manage alternative app installation features at Settings, then tap Apps, then tap App Installation.
*05:01:41-05:01:50*

However, users might notice changes to certain system features.
*05:01:50-05:01:55*

If they've downloaded an app from the App Store and delete the App Store, that app will not be able to be updated.
*05:01:55-05:02:03*

Users can delete camera and photos also.
*05:02:03-05:02:07*

As you might suspect, we have concerns about going too far here.
*05:02:07-05:02:11*

Now everything but phone and settings can be wiped from an iPhone.
*05:02:11-05:02:15*

We are concerned that this capability, which users have not been asking for, has the potential to confuse them.
*05:02:15-05:02:21*

Kyle, I turn it back to you to close our presentation.
*05:02:21-05:02:26*

Look, we've done everything that's been asked of us.
*05:02:26-05:02:30*

I talked about it this morning, but I want to thank the engineers and acknowledge the staggering number of hours that go into building these kind of capabilities.
*05:02:30-05:02:39*

For example, to create so many new default settings and to make apps automatically appear on Docs and home screens.
*05:02:39-05:02:47*

Apple can do these things, and we will follow the law.
*05:02:47-05:02:50*

But we do so with the expectation of parity.
*05:02:50-05:02:54*

That's what we'd like to see.
*05:02:54-05:02:55*

We're pretty confused about that when we're being forced to wipe all trace of Apple apps away, which we think risks a negative user experience, when other gatekeepers are not being required to do the same thing.
*05:02:55-05:03:08*

As for us, at the end of the day, users choose Apple because our devices provide a seamless experience that works right out of the box.
*05:03:08-05:03:16*

And we've done our best to maintain that here.
*05:03:16-05:03:19*

As we've said throughout the workshop today, Apple's approach to the DMA has remained consistent, delivering the best possible experience we can to users while complying with the law.
*05:03:19-05:03:28*

And that's what we'll continue to do.
*05:03:28-05:03:30*

With that, we can take your questions.
*05:03:30-05:03:33*

Thank you very much, Kyle.
*05:03:33-05:03:34*

I will open the floor soon.
*05:03:34-05:03:36*

I'll just clarify one thing, because I would like to avoid that we have questions asked on the wrong premises.
*05:03:36-05:03:43*

So just the figures which were shown were, of course, based on stat counter.
*05:03:43-05:03:48*

And as many people in the room know, stat counter does not report small privacy-based browsers.
*05:03:48-05:03:55*

So based on our data, the small browsers actually increased their market share by 11.5%.
*05:03:55-05:04:02*

So that's actual data.
*05:04:02-05:04:03*

So I just want to clarify that before a discussion starts.
*05:04:03-05:04:06*

But with that, I will open the floor.
*05:04:06-05:04:09*

I will recall the rules of engagement.
*05:04:09-05:04:11*

Clear, short, to the point questions, please.
*05:04:11-05:04:14*

Relevant on topic, constructive.
*05:04:14-05:04:17*

And we will carry on like this throughout the afternoon.
*05:04:17-05:04:21*

Kush, you've been very quiet until now.
*05:04:21-05:04:24*

Thank you.
*05:04:24-05:04:25*

And thanks for making the point about the browser data.
*05:04:25-05:04:28*

Thanks for your presentation as well, first of all.
*05:04:28-05:04:30*

Yeah, our story is slightly different to the one that was presented up there.
*05:04:30-05:04:33*

As Lucia said, we've seen daily active users-- sorry, I've dropped it.
*05:04:33-05:04:38*

Mozilla, I should say.
*05:04:38-05:04:39*

We've seen daily active users in some countries grow by 100%, despite an accordingly bad first choice screen and a much improved one second time around.
*05:04:39-05:04:48*

I noticed you mentioned in the last session that you talked about consent fatigue and also that you test and test to improve user experience.
*05:04:48-05:04:55*

I think those were your words.
*05:04:55-05:04:56*

Looking to app stores, I wondered what testing was done of the choice screens and of the default apps experience and whether you can share what that testing showed.
*05:04:56-05:05:04*

Next question, please.
*05:05:04-05:05:09*

Ladies.
*05:05:09-05:05:12*

Thank you.
*05:05:12-05:05:12*

I think it's a follow-up question.
*05:05:12-05:05:14*

Just the name and affiliation, please.
*05:05:14-05:05:16*

Natasha Gala with CIPL.
*05:05:16-05:05:21*

I think it's a follow-up question to Kush's question.
*05:05:21-05:05:23*

I found the slide you had on the changes made or the choices people made after the change of the choice screen.
*05:05:23-05:05:34*

This is a question I actually asked in one of the choice screen workshops for a different gatekeeper on can we tell whether people are changing their choice because they're interacted with the information given about the other browsers?
*05:05:34-05:05:50*

Are they making changes because now with the choice screen, there are these heat maps that show people choose the first five, for instance, of the ones that are given.
*05:05:50-05:06:01*

And so do they make now choices based on the fact that there are different ones in the top five?
*05:06:01-05:06:08*

And do we have any-- is there any testing, any data of that?
*05:06:08-05:06:11*

So I found the slide also showing that people and if people interacted with the information given about the browsers there.
*05:06:11-05:06:17*

But I find this question really interesting to find out are they changing, for instance, to Mozilla because we all know Mozilla by name.
*05:06:17-05:06:24*

Is this part of the name recognition?
*05:06:24-05:06:26*

Or is it Chrome because it's now high up or in the choice screen?
*05:06:26-05:06:33*

Just wanting to know if there's more data available on that.
*05:06:33-05:06:38*

Thank you.
*05:06:38-05:06:39*

Next question.
*05:06:39-05:06:41*

Please.
*05:06:41-05:06:42*

Thank you.
*05:06:42-05:06:47*

Yeah, first I want to stress also that we've seen very real benefits as a small browser.
*05:06:47-05:06:58*

Name and affiliation, please.
*05:06:58-05:07:00*

I'm sorry.
*05:07:00-05:07:00*

Yeah.
*05:07:00-05:07:01*

Aurelien Mel from DuckDuckGo.
*05:07:01-05:07:04*

So we're seeing that as a small browser, we did see very real benefits from the changes that Apple had to do following the investigation, such as higher level of selections from the second time around.
*05:07:04-05:07:17*

That shows, we believe, a persistent pent-up demand for alternatives, but also higher retention and app usage thanks to, we think, doc placement.
*05:07:17-05:07:28*

Now, among the things that we think still undermine user choice on iOS are the aggressive use of prompt by Google on popular apps like Gmail, Google Maps, and others to push users to use Chrome or Google Search.
*05:07:28-05:07:46*

And this is all the while, as has been said, Android has so far stayed off the hook of an investigation, despite having the same or worse practices found to be non-compliant on iOS.
*05:07:46-05:07:59*

So my question to Apple, can Apple quantify the impact of Google overriding the iOS browser default on apps like Google Maps and Gmail?
*05:07:59-05:08:09*

And can Apple also simply ban this practice?
*05:08:09-05:08:12*

Thank you.
*05:08:12-05:08:16*

Please.
*05:08:16-05:08:19*

Hi, I'm Roger Gadella, Open Web Advocacy.
*05:08:19-05:08:23*

First of all, we would like to say that we agree with Apple that the hot seat should be default on Android as well.
*05:08:23-05:08:34*

So we will be raising this tomorrow.
*05:08:34-05:08:39*

Then on to my question.
*05:08:39-05:08:40*

The DMA has been in force now for 15 months.
*05:08:40-05:08:43*

Despite this, not a single browser vendor has been able to port their browser using its own engine to iOS.
*05:08:43-05:08:50*

It's not because they're incapable or they don't want to or because Apple's strange policies are making this-- sorry, it's because Apple's strange policies are making this nearly impossible.
*05:08:50-05:09:00*

One of the key issues slowing progress is that Apple is not allowing browser vendors to update their existing browser app to use their own engine in the EU and Apple's WebKit engine elsewhere.
*05:09:00-05:09:11*

This means that browser vendors have to ship a whole new app just for the EU and tell their existing EU customers to download their new app and start downloading-- start building their user base from scratch.
*05:09:11-05:09:24*

Now, we would love for Apple to allow competing browsers to ship their own engines globally.
*05:09:24-05:09:28*

But if they insist on allowing this only in the EU, Apple can easily resolve this problem.
*05:09:28-05:09:35*

Here's how.
*05:09:35-05:09:36*

They can allow browsers to ship two separate versions of their existing browser to the App Store, one version for the EU and one for the rest of the world, something which is currently possible in other app stores.
*05:09:36-05:09:47*

This would allow existing European users to get the European version of the app without having to download a separate app simply by receiving a software update.
*05:09:47-05:09:54*

But it seems Apple doesn't want that, and they make this very clear in their browser engine entitlement contract.
*05:09:54-05:10:01*

Given that Apple can easily resolve this problem simply by allowing browsers to ship a separate version of the app to the EU under the same bundle ID, why is Apple still insisting that browser vendors lose all their existing EU customers in order to take advantage of the rights granted under the DMA?
*05:10:01-05:10:18*

Thank you.
*05:10:18-05:10:19*

Thank you.
*05:10:19-05:10:20*

One more, please.
*05:10:20-05:10:22*

Thank you.
*05:10:22-05:10:28*

Thank you.
*05:10:28-05:10:28*

[INAUDIBLE] from Code.
*05:10:28-05:10:31*

Our membership, again, as Chrome, but also Opera as browsers, and we see through our members that Apple doesn't allow browser users to set the default from within the browser app, which was brought up during last year's workshop already, and is possible with other operating systems.
*05:10:31-05:10:49*

Users are still forced to go to iOS settings, which is cumbersome, which is a cumbersome process, and adds up on your friction.
*05:10:49-05:10:56*

What is Apple doing to address this?
*05:10:56-05:10:59*

Second, Apple has made some changes to its rule governing third-party browsers and the ability to use other browsers engine in the EU.
*05:10:59-05:11:08*

However, as was already mentioned, there are various restrictions, including having two different versions of the app, limitations on testing, cumbersome contract requirements, still making it onerous to meaningfully take advantage of the browser engine interoperability, which is why no one has really successfully launched on iOS using an alternative browser engine.
*05:11:08-05:11:33*

What is Apple going to do to enable the third parties to launch a browser on iOS via an alternative engine?
*05:11:33-05:11:39*

Thank you.
*05:11:39-05:11:40*

[END PLAYBACK]
*05:11:41-05:11:42*

Very good, Kyle.
*05:11:42-05:11:45*

I'll take a bit of that, and then I'll turn it over to Gary.
*05:11:45-05:11:48*

So I think-- let me take the browser engine first.
*05:11:48-05:11:56*

I know this is all-- this conversation is supposed to be about browser choice screens and defaults, but I know some of you, many of you at the same group, have traveled very far to have this conversation.
*05:11:56-05:12:05*

And so I'll take a question on that, which is, listen.
*05:12:05-05:12:08*

As everyone knows, when we designed and released iOS and iPadOS over 15 years, we were hyper-focused on how do we create the most secure computing platform in the world.
*05:12:08-05:12:19*

We built it from the ground up with security and privacy in mind.
*05:12:19-05:12:23*

The browser engine was a critical aspect of that design.
*05:12:23-05:12:27*

WebKit was that aspect of the design.
*05:12:27-05:12:29*

And that has worked for 18 years.
*05:12:29-05:12:32*

We recognize under the DMA that we've been forced to change.
*05:12:32-05:12:35*

And we have created a program that keeps security and privacy in mind, that keeps the integrity of the operating system in mind, and allows third parties to bring their browser engine-- Google, Mozilla-- to the platform.
*05:12:35-05:12:52*

And for whatever reason, they've chosen not to do so.
*05:12:52-05:12:55*

And so we remain open.
*05:12:55-05:13:00*

We remain open to engaging.
*05:13:00-05:13:01*

We have had conversations, constructive conversations, with Mozilla.
*05:13:01-05:13:05*

Less constructive engagement from the other party.
*05:13:05-05:13:09*

But we are working to resolve those differences and bring them to iOS in a way that we feel comfortable with in terms of a security, privacy, and integrity perspective.
*05:13:09-05:13:20*

There was a question from DuckDuckGo about the never-ending series of prompts that you get on iOS when you're using a Google property.
*05:13:20-05:13:31*

It annoys me as a user.
*05:13:31-05:13:34*

That said, I don't think you're going to see Apple suddenly telling Google or any other developer what they can do within their app.
*05:13:34-05:13:41*

That's not the environment we are in right now.
*05:13:41-05:13:45*

I think our focus is on how can we protect our users.
*05:13:45-05:13:47*

And we certainly get a lot of complaints about those sorts of prompts.
*05:13:47-05:13:51*

And I think there are questions there from a regulatory perspective that need to be answered.
*05:13:51-05:13:57*

But there is an impact.
*05:13:57-05:13:58*

And I think some of what we're seeing on the browser engine side, some of what we're seeing here on the browser choice screen, are designed to reinforce the dominance of one player.
*05:13:58-05:14:07*

And I think we need to be careful about that.
*05:14:07-05:14:09*

In terms of the ease of choosing-- the code representative asked about how easy it is for defaults or for a user to change defaults.
*05:14:09-05:14:24*

I referenced a study by the Competition Markets Authority in the UK, which the study they conducted found it was very easy on iOS, very simple on iOS to change default browsers.
*05:14:24-05:14:36*

We also have put in an implementation in which every single user, when they upgrade to 18.2 or later, are presented with the choice screen at device setup.
*05:14:36-05:14:47*

Unequaled.
*05:14:47-05:14:48*

No other gatekeeper does that.
*05:14:48-05:14:50*

No one.
*05:14:50-05:14:51*

That's why the vast majority of iOS and iPad OS users have been presented with that choice screen here in Europe.
*05:14:51-05:14:58*

That is not true with other gatekeepers.
*05:14:58-05:15:00*

Simply not true.
*05:15:00-05:15:02*

The numbers are far, far lower.
*05:15:02-05:15:04*

And I encourage your membership to take a look at that.
*05:15:04-05:15:06*

I think that probably covers the points I can address.
*05:15:06-05:15:11*

Gary?
*05:15:11-05:15:12*

Well, first of all, I'm a little bit upset that Lucia thought I wouldn't be able to go first.
*05:15:12-05:15:17*

But we can address that later.
*05:15:17-05:15:20*

I also wonder-- there's a lot of OWA people here in the room.
*05:15:20-05:15:24*

So well done on that.
*05:15:24-05:15:26*

I also-- half the questions, at least, were about browser engines, which is obviously an Article 5.7 issue as opposed to a 6.3 issue.
*05:15:27-05:15:37*

More than happy, as Kyle already did, to address the question.
*05:15:37-05:15:41*

But I think it would be a shame that a session that is about choice screens and on installation and defaults become a browser engine discussion.
*05:15:41-05:15:51*

I was pleased that Koush was nodding when Kyle was pointing out the ongoing engagements with Google and Mozilla, which are continuing right up even to last week, and I think just some more this week.
*05:15:51-05:16:04*

There was a bottom line issue, however, which is that both Google and Mozilla have everything they need to build their engines and ship them on iOS today.
*05:16:04-05:16:16*

We heard some other issues mentioned.
*05:16:16-05:16:18*

We are happy to engage in those issues.
*05:16:18-05:16:19*

We are engaging in those issues.
*05:16:19-05:16:21*

But everything is in place to ship here in the EU today.
*05:16:21-05:16:26*

I think that's an extremely important point to take away from this.
*05:16:26-05:16:30*

I think, Natasha, you had a question about data.
*05:16:30-05:16:34*

I think there's-- I'm not sure you would get anything from looking at the placement on the screen because the screens are fully randomized, which means that you and I will have seen different choices, not just based on the fact that, notionally at least, I'm based in Ireland and you're based here.
*05:16:34-05:16:51*

In Brussels, it is changing depending-- and I think that's something we've been true with in the commission.
*05:16:51-05:16:58*

So one assumes it is extremely random and no pattern would emerge from that.
*05:16:58-05:17:05*

I think one other point I want to make sure I address as I reflected upon it, there was a question about why we don't do this on a global basis.
*05:17:05-05:17:13*

And I think we've always approached the DMA as to the European law that relates to Europe.
*05:17:13-05:17:18*

And we are not going to export European law to the United States, and we're not going to export European law to other jurisdictions.
*05:17:18-05:17:25*

Each jurisdiction should have the freedom in decision making to make its own decisions.
*05:17:25-05:17:31*

And so we're going to abide by that.
*05:17:31-05:17:34*

Sorry, just one other final point, and this isn't a-- back and forth.
*05:17:34-05:17:39*

Aurelien from DuckDuckGo, who makes very constructive comments, I will say, and ones which we're always very conscious of in terms of how we engage with them.
*05:17:39-05:17:51*

You had a question, I think it was you, about the ability to link the user if they changed their choice, or maybe it was OWA, to re-prompt them on the default.
*05:17:51-05:18:01*

So there is a deep link that will drop the user right into settings for defaults.
*05:18:01-05:18:09*

So you saw me show a screen there which showed the defaults, so the new defaults menu.
*05:18:09-05:18:15*

And so the user can be deep linked into that default setting, and in there, then, can go and change it.
*05:18:15-05:18:20*

Now, this is obviously subsequent to the user having already made a very explicit choice on the choice screen.
*05:18:20-05:18:27*

So there is an ability to come in there.
*05:18:27-05:18:28*

I'm actually thinking it wasn't you now, Aurelien.
*05:18:28-05:18:30*

Yeah, yeah, yeah, that's correct, confirming it.
*05:18:30-05:18:32*

But there is that ability to do it, and that's possibly the ease of doing that, is perhaps why some of these other companies are persisting in re-prompting users.
*05:18:32-05:18:44*

Thank you.
*05:18:44-05:18:44*

We'll take two questions from the Slido, then we continue in the room.
*05:18:44-05:18:49*

And to the extent there is no six free questions, which will be taken by priority, it's OK to ask questions which are other questions related to browsers.
*05:18:49-05:18:58*

So I think that's totally OK, given the name of the session.
*05:18:58-05:19:01*

But I hand over to Kasia for the two questions from Slido first.
*05:19:01-05:19:07*

Eric Lizola from Aalto University asks, if Apple ended its search deal with Google, would Apple still set Google as default on Safari, Siri, and Spotlight?
*05:19:07-05:19:17*

Does Apple prioritize market share, like Google, or privacy-focused alternatives, like DuckDuckGo, when choosing defaults?
*05:19:17-05:19:26*

And the second question, from Benjamin Earhart, the Guardian Project.
*05:19:26-05:19:30*

It's an NGO.
*05:19:30-05:19:32*

When does Apple plan to fix the security issues that are not affected by itself, but affect other browser vendors?
*05:19:32-05:19:39*

For example, inability to tune out, hence protect users' privacy, or AV traffic, stop leaking IP addresses through share sheets, or WebRTC.
*05:19:39-05:19:51*

Thanks.
*05:19:51-05:19:54*

I think I'll need-- I'm going to need that question again, the second one.
*05:19:54-05:19:57*

Is it leaking, stopping other people from leaking?
*05:19:57-05:20:02*

It's inability to tune out.
*05:20:02-05:20:05*

And yeah, I think it's Apple leaking IP addresses.
*05:20:05-05:20:09*

It's the question that we received.
*05:20:09-05:20:13*

Try your best, Gary.
*05:20:13-05:20:15*

It's expected.
*05:20:15-05:20:20*

So I think it's a matter of public record.
*05:20:20-05:20:23*

Apple selected Google Search over 15 years ago as the default on our Safari browser.
*05:20:23-05:20:30*

We did that after an exhaustive examination of the market, which concluded they were the best search engine in the market.
*05:20:30-05:20:37*

We've revisited that multiple times as it's become a matter of public record in the trial in the United States.
*05:20:37-05:20:43*

And so we'll continue to pick the best search engine that we believe serves our users.
*05:20:43-05:20:50*

Now, at the same time that we've done that, we've also enabled it and made it very simple for users to switch to other alternatives, including search engines that market themselves as more privacy-focused.
*05:20:50-05:21:05*

And so we've made it incredibly easy for users to switch that default. And we'll continue to do so.
*05:21:05-05:21:11*

So our focus has always been on what have our users want?
*05:21:11-05:21:15*

What do our users expect?
*05:21:15-05:21:17*

And for better or for worse, the vast overwhelming majority of users want to use Google.
*05:21:17-05:21:23*

Hence, they're the default.
*05:21:23-05:21:28*

So on the second question, which I'm going to interpret to be a question about how Safari works, I'm going to answer it as best I can.
*05:21:28-05:21:36*

And then maybe they can take a follow-up question.
*05:21:36-05:21:38*

It might be a way to go.
*05:21:38-05:21:41*

So the great news when you use Safari is that Apple does not collect any of your personal information.
*05:21:41-05:21:47*

You can also, as you're using Safari, enable by default is intelligent tracking prevention, which actually prevents the-- let's use the word leakage, as was used there, assuming it's about that.
*05:21:47-05:22:01*

So that is actually blocked by default, including tracking cookies.
*05:22:01-05:22:06*

And if you search within Safari, Safari search, or maybe we're calling it Spotlight now, the name changes, Apple does not collect the full octet of the IP address.
*05:22:06-05:22:21*

We drop it.
*05:22:21-05:22:22*

And in addition, it's associated with a 15-minute rotating identifier, such that we cannot link the search, which is a feature identity, which you might have expected to be my answer in any case, based on some of my earlier outline of our privacy positions.
*05:22:22-05:22:38*

But I'm happy to take the requester's question, if they wish to clarify it.
*05:22:38-05:22:43*

It's just that I don't know the specifics of it, unfortunately.
*05:22:43-05:22:46*

I would like to take 15 minutes to answer it, actually, because I feel we have such a fantastic privacy story here, but I need to know the specifics.
*05:22:46-05:22:54*

Thank you, Gary.
*05:22:54-05:22:54*

Back to the room.
*05:22:54-05:22:55*

So by parity, questions on choice, Architecture 6.3.
*05:22:55-05:22:59*

Please, go.
*05:22:59-05:23:03*

Hey, Frederick Riedel from Riedel.wtf again, with the OneSec app.
*05:23:03-05:23:08*

Besides blocking apps, we also do help people spend less time on websites.
*05:23:08-05:23:14*

So it's very exciting that people now have more choices, and we have more options to help people spend less time on these websites.
*05:23:14-05:23:23*

But I'm a bit concerned, or I would love to learn how Apple will make sure that existing APIs that are currently available in WebKit will be available when people decide to use custom browser engines as well.
*05:23:23-05:23:37*

As an example, we used a screen time API, more specifically the managed settings part of it, that really specifically allows us to block certain websites.
*05:23:37-05:23:47*

Users can, for example, also decide to block porn sites.
*05:23:47-05:23:51*

That's also a parental control setting, but also users decide to put it on their own phones.
*05:23:51-05:23:56*

And yeah, I would love to know if and how Apple will allow developers like me to apply such restrictions in third party browser engines as well.
*05:23:56-05:24:08*

I actually wanted to follow up on Benjamin Earhart's question.
*05:24:08-05:24:19*

So the privacy proxy thing in Safari is great, but the problem is that third party browsers do not get the same kind of protections because private information is leaked by the operating system in third party browsers.
*05:24:19-05:24:33*

So when third party browsers want to tunnel, like what is done with Safari, some key private information is leaked.
*05:24:33-05:24:41*

So this has been an issue that we've been working with for years.
*05:24:41-05:24:44*

So I work a little bit with Benjamin Earhart, and Apple has acknowledged and not fixed.
*05:24:44-05:24:51*

So we're wondering when they will be fixed.
*05:24:51-05:24:53*

OK, thank you.
*05:24:53-05:24:53*

So I think this is the clarification of the preceding question.
*05:24:53-05:24:56*

John?
*05:24:56-05:24:58*

Hi.
*05:24:58-05:24:58*

Thanks for having us.
*05:24:58-05:24:59*

So since you guys mentioned that this was about choice screen, I just want to give a quick note to say, if you look at the agenda sessions on browsers, it's about Apple's first year of compliance, not exclusively on choice screens.
*05:24:59-05:25:12*

But since we said choice screens, let's talk about something that we discovered thanks to the choice screens.
*05:25:12-05:25:18*

And that's everyone's favorite topic, adult content.
*05:25:18-05:25:21*

So on iOS, there are two mechanisms to control what type of content that can be accessed.
*05:25:21-05:25:27*

So one is the Web Content Restriction setting, which blocks adult sites and any other site that a parent chooses to block from being accessed in the web browsing.
*05:25:27-05:25:37*

Two is the Age Restriction settings, built into both iOS and App Store to stop users from downloading apps that aren't considered appropriate for their age group.
*05:25:37-05:25:46*

And just to reiterate, content is separate from the age settings.
*05:25:46-05:25:50*

These are two separate settings in iOS.
*05:25:50-05:25:53*

Now, here's where it gets problematic.
*05:25:53-05:25:55*

Apple has given all web browsers on iOS a 17-plus age rating, despite the fact that the websites they can load are not controlled using the Age Restriction setting, but using the Web Content Restriction setting.
*05:25:55-05:26:07*

I don't know if you're following content and age are different.
*05:26:07-05:26:10*

So how can it be that the browser's user interface itself is considered inappropriate for children, not the Web Content Day display?
*05:26:10-05:26:18*

We believe that Apple isn't acting in good faith here, because Apple's own browser, Safari, also has a 17-plus rating.
*05:26:18-05:26:24*

Yet it can be used even with age restrictions enabled.
*05:26:24-05:26:28*

So what now?
*05:26:28-05:26:29*

It's OK to use Safari for porn, but not other browsers.
*05:26:29-05:26:34*

Given that all browsers on iOS, including Safari, use the exact same Web Content Restriction setting, what is it about other browsers that means that they're not allowed to be installed or used when Safari is?
*05:26:34-05:26:46*

So thanks to this dark pattern, we discovered that most users under the age of 18, an estimated up to 15% of all European users, cannot use any browser other than Safari, undermining their meaningful browser choice.
*05:26:46-05:27:02*

So these users will grow up having only ever used Safari on iOS, and perhaps not even knowing about the existence of other browsers.
*05:27:02-05:27:10*

So to further demonstrate the absurdity of the situation, if a parent were to set an age restriction but not a Web Content Restriction, children would be able to access adult content not just in Safari, but also in any other app that implements an in-app browser.
*05:27:10-05:27:23*

And my favorite notable ones are social media apps and messaging apps, like Instagram, TikTok, Snapchat, WhatsApp.
*05:27:23-05:27:29*

These all have 12-plus age ratings.
*05:27:29-05:27:32*

But you can adult open links in messages, posts, and profiles on all these social media apps.
*05:27:32-05:27:38*

So if your friend sends you a porn link on Instagram, you can open it.
*05:27:38-05:27:40*

There's no problem with that somehow.
*05:27:40-05:27:42*

And if a parent who has done this might believe that they've blocked adult content, when in reality, all they have done is block competitors to Safari, that's not a great situation.
*05:27:42-05:27:51*

So given that under the Article 13.4 of DMA, Apple must not use interface design or behavioral techniques to undermine its compliance, what specific steps will Apple take to ensure that third-party browsers and social media apps are treated equally in age-restricted environments?
*05:27:51-05:28:05*

Thank you.
*05:28:05-05:28:07*

Thank you.
*05:28:07-05:28:10*

In the back, a lady.
*05:28:10-05:28:11*

Yes.
*05:28:11-05:28:14*

Good afternoon.
*05:28:14-05:28:14*

Agata Nowacka from Cessna.
*05:28:14-05:28:15*

I'm both a browser and a search engine based in Czech Republic.
*05:28:15-05:28:21*

Just to echo what the commission says, rather common than the question, Apple mentioned that actually users generally do not switch browsers.
*05:28:21-05:28:29*

As a Czech browser, we think and we see the trend that it's completely different.
*05:28:29-05:28:35*

And probably this is due to the measurement tool.
*05:28:35-05:28:40*

In Czech Republic, stat counts is not actually applicable.
*05:28:40-05:28:45*

The audience measurement tool that is counting actually the users is Gemius.
*05:28:45-05:28:50*

Therefore, our numbers are completely different.
*05:28:50-05:28:52*

So is Apple open to take those into account to shape the future switching?
*05:28:52-05:29:00*

Thank you.
*05:29:00-05:29:03*

One more.
*05:29:03-05:29:03*

So I'd like to return to browser engines for a second.
*05:29:09-05:29:13*

If it's OK, I'd like to quickly clear up my kind of connections to this.
*05:29:13-05:29:17*

Because I think, Carol, you were suggesting that I'm a friend for Spotify and the OWOs.
*05:29:17-05:29:22*

That's what I heard.
*05:29:22-05:29:23*

I'm just a student.
*05:29:23-05:29:24*

I volunteer because I truly believe in the open web.
*05:29:24-05:29:28*

I don't get paid.
*05:29:28-05:29:29*

I don't receive any compensation.
*05:29:29-05:29:30*

I paid for myself to be here because I want to be.
*05:29:30-05:29:33*

And the organization does not receive any money either.
*05:29:33-05:29:36*

It's just donations.
*05:29:36-05:29:37*

So if that's OK and all clear, I'd like to carry on to the question.
*05:29:37-05:29:42*

When Apple does eventually, hopefully, allow other browser engines on iOS, we'll be seeing a new phase of competition.
*05:29:42-05:29:50*

These engines will be unique on iOS, acting as an intermediary platform between the iOS and the web.
*05:29:50-05:29:55*

But having been blocked from iOS for over 15 years, when they arrive, they will inevitably experience unique bugs, which need to be identified and resolved.
*05:29:55-05:30:03*

And I think, if I remember correctly, I said earlier that the new EU iOS will experience, I quote, "vulnerabilities and problems that will be unique here." However, these restrictions, which are unique to Apple, creates a new problem.
*05:30:03-05:30:20*

Most web developers, like us, but not like us, are all around the world-- in the US, where you're from, in Asia, and Africa, and the rest of the Americas, all over.
*05:30:20-05:30:31*

And they still serve EU users.
*05:30:31-05:30:34*

But they're going to be unable to install or test these new browsers with their third-party engines on their devices.
*05:30:34-05:30:40*

This means that these developers will be able to test Safari, but not Firefox's Gecko or Chromium, putting these competing browsers, web developers, businesses, and users at a significant disadvantage.
*05:30:40-05:30:54*

Apple faced the same issue with native app developers earlier, and ultimately resolved it by allowing testing versions of EU-only apps to be downloaded outside of the EU for developmental purposes.
*05:30:54-05:31:04*

The same principle should apply here.
*05:31:04-05:31:06*

Web developers globally must be able to test their sites in the new competing browsers on iOS, regardless of where they're located.
*05:31:06-05:31:13*

We understand that Apple may not wish to allow these browsers to ship to consumers.
*05:31:13-05:31:17*

That's their choice, I suppose.
*05:31:17-05:31:19*

But that is a completely separate issue to allowing developers to test it.
*05:31:19-05:31:23*

So my question is, what solution does Apple propose to ensure that web developers outside of the EU can install and test these browsers and maintain compatibility and interoperability for users in the EU?
*05:31:23-05:31:39*

Thank you.
*05:31:39-05:31:39*

Over to Kyle and Gary.
*05:31:39-05:31:43*

I should start saying Gary and then Kyle.
*05:31:43-05:31:46*

You would like that.
*05:31:46-05:31:47*

I would love it.
*05:31:47-05:31:48*

It's my whole goal.
*05:31:48-05:31:51*

So Gary will go into some of the details here.
*05:31:51-05:31:53*

But I would simply say again, we're in a period of transition where we built an operating system, a set of operating systems, that was designed to be the most secure in the world.
*05:31:53-05:32:04*

And that is what we have built. A critical aspect of that was our integration of WebKit into our operating systems.
*05:32:04-05:32:11*

And we've continued to maintain that as the most secure way to ensure that we have the very best operating system possible.
*05:32:11-05:32:19*

We've also introduced flexibility and APIs for third-party browser engines to take advantage of these new opportunities under the DMA.
*05:32:19-05:32:27*

We're also engaged in ongoing conversations with Mozilla and with the other company in terms of bringing them to iOS.
*05:32:27-05:32:35*

In terms of earlier, I don't think I referenced that you were getting funding from Spotify.
*05:32:35-05:32:39*

I don't know where you're getting funding from.
*05:32:39-05:32:41*

My reference is more to the code representative who does get a lot of funding from Google and Meta and Qualcomm and Spotify and others, but not yourself.
*05:32:41-05:32:49*

I understand that.
*05:32:49-05:32:49*

And I actually really-- Hold on.
*05:32:49-05:32:56*

So just so we're clear, I really respect the way that your team has approached this.
*05:32:56-05:33:02*

I don't question your motives.
*05:33:02-05:33:04*

I don't question your funding.
*05:33:04-05:33:05*

We disagree.
*05:33:05-05:33:07*

I think that's clear.
*05:33:07-05:33:08*

In forums like that, this are places to disagree.
*05:33:08-05:33:12*

We think we have developed a compliant solution.
*05:33:12-05:33:15*

I appreciate hearing your feedback and your feedback and your colleagues' feedback.
*05:33:15-05:33:18*

We'll take that into account.
*05:33:18-05:33:20*

We've read your papers.
*05:33:20-05:33:21*

We've read your advocacy.
*05:33:21-05:33:23*

There are points that we disagree.
*05:33:23-05:33:25*

And we'll probably continue to disagree going forward.
*05:33:25-05:33:28*

But I am not in any way disparaging where you're coming from.
*05:33:28-05:33:31*

I understand you're a well-meaning person who believes that he understands how to best design our operating system.
*05:33:31-05:33:36*

I get that.
*05:33:36-05:33:39*

In terms of some of the other points, I think probably, Gary, you're probably well-placed to address some of those.
*05:33:39-05:33:46*

Well, I'll address as many as I can.
*05:33:46-05:33:48*

There were wide ranging, I think.
*05:33:48-05:33:51*

James, maybe I'll just take yours first in terms of what we'd call the test and entitlement.
*05:33:51-05:33:55*

I think as we've been going along, we have learned a lot as to how to facilitate that kind of testing outside of the EU, even in relation to browser engines.
*05:33:55-05:34:09*

I think that's a subject of active discussion.
*05:34:09-05:34:11*

I think we've been discussing it with Mozilla and Google also and the commission.
*05:34:11-05:34:16*

I would expect to see some updates there.
*05:34:16-05:34:17*

So you can just generally see we are trying to be more conscious of that.
*05:34:17-05:34:22*

I think there was a general point about how each restrictions are applied on the platform.
*05:34:22-05:34:27*

And you will know that this issue is a major focus for Apple currently.
*05:34:27-05:34:33*

We made some announcements at WWDC in terms of an age attribution API.
*05:34:33-05:34:41*

We're doing a lot of focused work there.
*05:34:41-05:34:44*

And that is an area that we will be looking at and are looking at, I'm happy to say on that.
*05:34:44-05:34:50*

So that will be a large focus for us.
*05:34:50-05:34:55*

I think I also heard a clarification in relation to the question, which I hadn't understood.
*05:34:55-05:35:02*

And obviously, APIs are available to WebKit or available to WebKit.
*05:35:02-05:35:07*

I don't think I would describe it as a-- I think you said a fix.
*05:35:07-05:35:11*

I think it might be trying to make them available to others on the platform.
*05:35:11-05:35:15*

And obviously, as we go forward-- and this is in the 6.7 session-- as browser engines become available, which are alternative browser engines, which I presume they will in a timeline to come, there will be 6.7 issues there as well in terms of what iOS features are available to Apple services.
*05:35:15-05:35:35*

And so that's something we will have a look at in that context as they come in.
*05:35:35-05:35:39*

And certainly, those are the kinds of conversations we're having.
*05:35:39-05:35:42*

Even I think the question we had from Rital, that has been a topic.
*05:35:42-05:35:47*

So you asked about the screen time APIs and how we look at those.
*05:35:47-05:35:51*

They're all actively under discussion, some of those things we've received interoperability requests for.
*05:35:51-05:35:56*

And I think that is a good process in which to understand what it is that developers need and respond to them in a timely manner.
*05:35:56-05:36:05*

And I think we have been doing that.
*05:36:05-05:36:06*

And we are very anxious for child protection and age assurance reasons to make sure that that is working in a good manner on the platform.
*05:36:06-05:36:16*

It wasn't my intention to elide any other point anybody made.
*05:36:16-05:36:20*

If I've missed something, please let me know.
*05:36:20-05:36:22*

So we still have 10 minutes in this session.
*05:36:22-05:36:29*

So, Kush?
*05:36:29-05:36:32*

Yeah, just to your last point, Gary, my first question about user testing would be great to get a response to that.
*05:36:32-05:36:38*

And then just to Kyle's point about two separate binaries and security being the reason for the browser engine kit restrictions, we'd love to understand how you see those things connected and why security is the reason for that restriction.
*05:36:38-05:36:51*

John?
*05:36:51-05:36:57*

John from Open Web Advocacy.
*05:36:57-05:36:58*

So last year, after we made a lot of noise to get Apple to reinstate home screen web apps in the EU, Apple announced that home screen web apps continue to be built directly on WebKit and its security architecture.
*05:36:58-05:37:10*

However, under Article 5.7 of the DMA, Apple is not allowed to impose a browser engine on either users or third party browsers.
*05:37:10-05:37:17*

Can Apple update us on the progress made for allowing third party browser engines to install and manage home screen web apps on iOS once third party browser engines arrive on iOS?
*05:37:17-05:37:27*

Thank you.
*05:37:27-05:37:28*

Thank you.
*05:37:28-05:37:29*

Please.
*05:37:29-05:37:30*

Hi, I'm Kay Gibele, Chamber of Progress.
*05:37:30-05:37:35*

We are a tech industry association.
*05:37:35-05:37:39*

We have some over 35 leading tech companies supporting us, including Apple.
*05:37:39-05:37:46*

I was wondering, in respect to some of the user choice changes that you've made, but also generally, because you've talked about the extraterritorial effect of the DMA and implementation in other jurisdictions as well, not wanting to export law, but a lot of other jurisdictions are passing similar rules or considering it in your engagements with authorities.
*05:37:46-05:38:10*

Has the commission been the most advanced in terms of designing these interventions?
*05:38:10-05:38:19*

How is it looking elsewhere?
*05:38:19-05:38:21*

One more?
*05:38:21-05:38:24*

You, please.
*05:38:24-05:38:28*

Did you want to ask a question?
*05:38:28-05:38:34*

I can.
*05:38:34-05:38:34*

Generally, my voice is loud enough.
*05:38:34-05:38:40*

I don't need a microphone.
*05:38:40-05:38:43*

So I'm always told I'm too loud.
*05:38:43-05:38:45*

This is about UK, because obviously we don't have our legislation yet.
*05:38:45-05:38:51*

Has the UK government engaged fully and clearly with Apple on this issue, on digital services?
*05:38:51-05:38:58*

And what do you think their view is on how this is going to go forward?
*05:38:58-05:39:02*

Oh, please, you cannot-- that was quick.
*05:39:02-05:39:06*

[AUDIO OUT]
*05:39:06-05:39:09*

Thank you.
*05:39:09-05:39:13*

Mike Sachs, the App Association.
*05:39:13-05:39:15*

We are a trade association.
*05:39:15-05:39:17*

Apple is one of our sponsors.
*05:39:17-05:39:18*

And we are here representing member companies that are all SMEs.
*05:39:18-05:39:24*

Native apps are important, but browser apps are important as well.
*05:39:24-05:39:28*

And a lot of us have both.
*05:39:28-05:39:31*

I'm wondering if there are any plans, even though the DMA might not require it, to make native apps more prominent and to give them essentially equal footing in the user's view.
*05:39:31-05:39:46*

We already have the ability to install them on their home screen to receive push notifications.
*05:39:46-05:39:52*

And I think then the point that somebody made about developers worldwide being able to test web apps that are using browser engines is an important one.
*05:39:52-05:40:07*

And so will developers have the ability to install those apps that are available only in the EU just for development purposes?
*05:40:07-05:40:18*

Thank you.
*05:40:18-05:40:19*

Gary and Kyle.
*05:40:19-05:40:20*

And now he gave him the opportunity, and he passed.
*05:40:20-05:40:26*

So I think on home screen web apps, obviously these are available today here and around the world.
*05:40:26-05:40:35*

We have nothing to announce in terms of what we will do, if and when a third-party browser engine comes to iOS.
*05:40:35-05:40:44*

Certainly I can say from a high-level perspective, our focus will continue to be, as I've said several times, on ensuring that anything that's operating on our platform is as secure and as private as possible, and it does not damage the operating system.
*05:40:44-05:40:58*

Browsers and home screen web apps are different than other things.
*05:40:58-05:41:03*

They have other access to the operating system that we will have to manage and control.
*05:41:03-05:41:07*

And so we have not settled out on any of those issues.
*05:41:07-05:41:11*

As I've said again, we've engaged with Mozilla.
*05:41:11-05:41:13*

We've engaged with Google.
*05:41:13-05:41:15*

We're figuring out the solution that works best for all parties.
*05:41:15-05:41:21*

I think in terms of other jurisdictions, listeners, I'm not going to get into a long discussion around what does the law look like here and other places.
*05:41:21-05:41:30*

There are obviously differences.
*05:41:30-05:41:31*

And I think those differences will become more and more pronounced in the coming years.
*05:41:31-05:41:36*

Obviously, the current US administration has a view about some of those jurisdictions, including Europe.
*05:41:36-05:41:43*

I don't know what the coming months and years what will happen.
*05:41:43-05:41:47*

What I can say is Apple's focused on ensuring that it complies with the law in each jurisdiction.
*05:41:47-05:41:52*

What we will not do is take the law in one jurisdiction and export it to another.
*05:41:52-05:41:57*

That is simply not something we're going to do.
*05:41:57-05:41:59*

But we are going to focus on what are our legal obligations in a given market that we're operating in, engage with the local regulator, make sure that we're fully in compliance.
*05:41:59-05:42:08*

And also, when we have concerns, like we've outlined here today, we're going to make them very clear.
*05:42:08-05:42:14*

And I will say, in other jurisdictions, they've been far more receptive to understanding and accommodating those concerns than what we've seen so far in Europe.
*05:42:14-05:42:23*

I want to make sure we get the Mozilla question answered, because he's asked it twice.
*05:42:23-05:42:31*

Yeah.
*05:42:31-05:42:32*

So in terms of the testing, as you know, Kush, we have a very extensive program for employee carry.
*05:42:32-05:42:42*

Then we have our developer seats, our public seats.
*05:42:42-05:42:45*

We've got over a million participants in it.
*05:42:45-05:42:48*

We receive feedback on those.
*05:42:48-05:42:50*

We have extensive feedback from users in relation to how those screens are working in practice, which I think that was your question, actually.
*05:42:50-05:42:59*

I think it's before implementation.
*05:42:59-05:43:01*

No, I understand.
*05:43:01-05:43:02*

But the seed is gone.
*05:43:02-05:43:03*

I'm going to say a seed is well before implementation.
*05:43:03-05:43:06*

I think we're different from other people in that respect, in terms of the scale that we have.
*05:43:06-05:43:12*

I think you raised an issue in relation to security.
*05:43:12-05:43:15*

The reality is-- and everybody knows this, and this is why it's taken a while to work through the issues-- that browser engines are a security vector.
*05:43:15-05:43:21*

I know, not agreed by everybody, that they have a similar security profile.
*05:43:21-05:43:27*

But they do.
*05:43:27-05:43:28*

I could sit here now and read a list of, I don't know, 100 actual vulnerabilities associated with browser engines.
*05:43:28-05:43:37*

There are known vulnerability.
*05:43:37-05:43:39*

So therefore, we want to move forward in a way that takes account of those vulnerabilities and does not put our users at risk on the platform.
*05:43:39-05:43:48*

And I think that is something which everybody should want as an outcome here.
*05:43:48-05:43:52*

OK, so the last one.
*05:43:57-05:43:58*

OK?
*05:43:58-05:43:58*

[INTERPOSING VOICES]
*05:43:58-05:44:01*

But John travels from far.
*05:44:01-05:44:05*

Thank you so much.
*05:44:05-05:44:06*

So OK, I'm going to bundle two questions into one, because I think they go along really well together.
*05:44:06-05:44:11*

This has to do with web apps and their installation methods.
*05:44:11-05:44:14*

Apple has previously told the Australian and the UK regulators that web apps are a viable competitor to native apps, and their own App Store developer guidelines say that if a developer does not want to use the App Store, there's always the open internet.
*05:44:14-05:44:26*

As such, we believe that web apps should get equal treatment to native apps when it comes to installation.
*05:44:26-05:44:31*

Users can install native apps with one click via the App Store, which a website can link to or even open without user interaction.
*05:44:31-05:44:38*

Users can also directly install native apps with one click within browsers using smart install banners on the top.
*05:44:38-05:44:45*

Web apps inside of Safari and even third party browsers are unable to do either of these at the moment.
*05:44:45-05:44:51*

So to install a web app on iOS, user must go through a four step process, navigating the Safari menu, finding the Share icon, which I don't know why it's labeled Share, scrolling down and clicking to the confusingly named at the home screen button instead of install.
*05:44:51-05:45:07*

On other operating systems, most browsers clearly place this button labeled install app in the first page of the menu or in the address bar and crucially allow websites to prompt users to install web apps just like native apps.
*05:45:07-05:45:20*

So our question is, what will Apple do to ensure quality and installability between native apps and web apps?
*05:45:20-05:45:26*

And related to this question, it has to do with iOS 26.
*05:45:26-05:45:31*

With the new redesign-- but we'll get to that-- last year in a better release, right before DMA deadline, Apple quietly tried to kill web apps on iOS until we, Open Web Advocacy, led an open letter with over 5,000 signatures from organizations, companies, individuals, including European MEPs to ring the alarm bells and try to stop Apple.
*05:45:31-05:45:52*

So this year, right before this DMA workshop, with the iOS 26 beta, Apple has made it even more difficult to install web apps and added them to add them to home screen and hidden the functionality two more button presses and menus deep compared to the previous version.
*05:45:52-05:46:09*

So why is Apple trying to make it even harder than it already is to install web apps and trying to add them to the home screen?
*05:46:09-05:46:14*

Thank you.
*05:46:14-05:46:15*

Thank you.
*05:46:15-05:46:16*

Gary or Kyle or-- It's got to be Gary.
*05:46:16-05:46:19*

Yeah.
*05:46:19-05:46:20*

And then it will be coffee.
*05:46:20-05:46:21*

Oh, fantastic.
*05:46:21-05:46:24*

So I think we'll have to get back to the iOS 26 issue.
*05:46:24-05:46:28*

That's not something I'm aware of.
*05:46:28-05:46:31*

And I think on the first issue, I do think there is a fundamental difference in terms of installability and what a user should know between an app that has gone through the thorough app review process, which has checked it across all the App Store guidelines, run the code, examined how it worked, and then see what the experience is, check what privileges it wants to access, examined how it's going to access them.
*05:46:31-05:47:02*

To me, those things are different.
*05:47:02-05:47:04*

And I think they're different from a threat vector for users.
*05:47:04-05:47:08*

And so I do think they're going to have to operate slightly differently to make sure that users are not unintentionally installing something from the web that they simply don't understand.
*05:47:08-05:47:19*

Thank you very much.
*05:47:19-05:47:21*

And with this, thank you to everyone for this penultimate session.
*05:47:21-05:47:25*

So we now have-- and I can actually leave you a 20-minute break, as is in the original planning.
*05:47:25-05:47:34*

And then for the most resilient ones and very curious about how to do session on data portability API, we will welcome you here in 20 minutes, which is at 40 past 3.
*05:47:34-05:47:49*

Thank you.
*05:47:49-05:47:51*

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*05:47:51-05:47:54*

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Can we please take the seats so that we start the last session more or less on time?
*06:05:16-06:05:22*

Earlier you come back, earlier you will get out of this by now 30 degrees room.
*06:05:22-06:05:31*

And I should say that everyone who stays until the end will get a medal at the end.
*06:05:34-06:05:42*

Excellent.
*06:05:55-06:05:56*

And welcome back.
*06:05:56-06:05:57*

So we are here for our last session.
*06:05:57-06:06:00*

Before we start the data portability session, I would like to still give floor to Clement from Bits and Coffee Consult.
*06:06:00-06:06:09*

I would like to give impression that not everyone got to ask the question as they wanted and that there was-- it's just maybe John is so loud on my right hand side, so he was more visible.
*06:06:09-06:06:24*

And I got a floor several times.
*06:06:24-06:06:26*

So Clement, the floor is yours.
*06:06:26-06:06:28*

So we are still discussing the browsers.
*06:06:28-06:06:33*

Thank you so much.
*06:06:33-06:06:34*

And just as an opening remark, I was lucky enough to be at the Apple Park earlier this month for the Worldwide Developer Conference three weeks ago.
*06:06:34-06:06:42*

And just I wanted also to say thank you for organizing when you unveiled iOS 26.
*06:06:42-06:06:46*

And I wanted to thank you for providing all these tools to developers.
*06:06:46-06:06:51*

Now, regarding browsers, I just wanted to highlight that in this room and in the commission, we are all tech savvy.
*06:06:51-06:06:58*

And we know what is spam, what is scam, what is all these pishing remarks-- pishing attempts, sorry.
*06:06:58-06:07:05*

So in a world where spam, scams, and even state finance hacker groups, sorry, and where malicious contents are increasingly prevalent, also where browsers in giant are front-end defense, how will you ensure that Safari with its energy efficiency system, system level integration, and strong privacy defaults remain clearly positioned as the safest and most reliable option for users, especially on iOS?
*06:07:05-06:07:32*

In a regulatory context like the DMA, which somewhat rightfully demand choices, and also, as your own slide showed, promotes other gatekeepers, how do you preserve differentiation, not through privilege, but through transparency so that user can make informed decision based on security and not just branding?
*06:07:32-06:07:53*

To build on that, is there maybe a plan to extend protections like iCloud Private Relay, which works remarkably well and more broadly across the system or across browsers to reinforce user safety regardless of the regulatory constraints?
*06:07:53-06:08:08*

Thank you.
*06:08:08-06:08:10*

Gary, can you please take this one?
*06:08:10-06:08:13*

Well, OK.
*06:08:13-06:08:16*

I will.
*06:08:16-06:08:17*

I think the question boils down to would we make iCloud Private Relay available to third-party apps?
*06:08:17-06:08:25*

The good news there is that any third-party app on iOS or iPadOS or macOS, as far as you can consider, it does not have to be an app, that is sending unencrypted traffic, that traffic is automatically encrypted by the use of Private Relay on the device.
*06:08:25-06:08:41*

Beyond that, I would need to know more, Clement, about your specific issue, but that is the package that is offered by Private Relay today.
*06:08:41-06:08:48*

It actually encrypts unencrypted traffic.
*06:08:48-06:08:53*

Thank you, Gary.
*06:08:53-06:08:54*

Any other unanswered questions from the browser session?
*06:08:54-06:08:58*

Does anyone feel that they didn't have sufficient opportunity to ask the question during the browser session because of John being loud and long?
*06:08:58-06:09:06*

No.
*06:09:06-06:09:10*

So with that, I consider that we can open the how-to-do session on data portability and I will hand over to my colleague Andrea Gadotti who will present the dialogue we had on 69610.
*06:09:10-06:09:24*

Can we have the slides?
*06:09:24-06:09:25*

Thank you.
*06:09:25-06:09:26*

>> Cool.
*06:09:27-06:09:28*

Thanks, Lucia.
*06:09:28-06:09:29*

So, well, first of all, I mean, to say a couple of words, I think it's important to say that we are a company that is very committed to the data protection of our data.
*06:09:29-06:09:38*

We are committed to the data protection of our data.
*06:09:38-06:09:41*

We are committed to the data protection of our data.
*06:09:41-06:09:44*

We are committed to the data protection of our data.
*06:09:44-06:09:47*

We are committed to the data protection of our data.
*06:09:47-06:09:50*

We are committed to the data protection of our data.
*06:09:50-06:09:53*

So, well, first of all, I mean, to say a couple of words on 69610 as obligations.
*06:09:53-06:10:00*

So these are some of the core provisions of the DMA that aim to foster contestability and fairness in digital markets.
*06:10:00-06:10:09*

And in a nutshell, these articles enable end users and business users free of charge to benefit from effective, high-quality, continuous and real-time data portability.
*06:10:09-06:10:21*

On 69610 more specifically, this is critical.
*06:10:21-06:10:24*

It's a critical obligation to overcome data lock-in for end users and business users and really simplifies switching and multi-homing.
*06:10:24-06:10:33*

And in simpler words, this means that when users are free to move their data to other services, then they are also more likely to try these services and maybe also to switch to them in the long run.
*06:10:33-06:10:48*

For 61610, this allows business users to obtain anonymous data about their own end users, but it also allows them to obtain personal data of the end users if the end user gives consent.
*06:10:48-06:11:03*

So both obligations also go farther than allowing end users and business users themselves to obtain the data.
*06:11:03-06:11:11*

And this is because they also enable end users to authorise third parties to receive this data.
*06:11:11-06:11:18*

And this is a much easier process for end users.
*06:11:18-06:11:22*

I mean, it's much easier to opt in into something like this.
*06:11:22-06:11:26*

And also for business users, it favours the development of innovative use cases relying on the portability of end user and business user data.
*06:11:26-06:11:37*

Now, in terms of regulatory dialogue, so first of all, since Apple's designation as a gatekeeper in September 2023, we have engaged continuously and I would say constructively with Apple to ensure that compliance with 69610 is effective.
*06:11:37-06:11:56*

Of course, at the same time, we have also been in contact with many third parties to understand the requirements.
*06:11:56-06:12:01*

And clearly, this is an area where we think feedback is very valuable and we encourage any interested party to contribute to the Q&A later today and also, of course, to reach to us in the future.
*06:12:01-06:12:15*

Importantly, regulatory dialogue as a process is iterative and open-ended.
*06:12:15-06:12:23*

And we believe that working collaboratively with gatekeepers and interested third parties is key for the effective implementation of the DMA data portability obligations as well as the other obligations.
*06:12:23-06:12:35*

We already welcome Apple's previous and ongoing efforts to implement data portability solutions.
*06:12:35-06:12:42*

Of course, the dialogue is very much ongoing and we expect further improvements as well as the rollout of an important solution for device switching that I will be talking about in a second.
*06:12:42-06:12:55*

So, I will quickly focus on 6.9.
*06:12:55-06:13:00*

So, these are a couple of areas of focus that we had with Apple.
*06:13:00-06:13:06*

This is, of course, not exhaustive.
*06:13:06-06:13:08*

So, in terms of App Store data, we had many discussions on the user flow to authorise third parties to obtain App Store data.
*06:13:08-06:13:16*

And an example is the number and frequency of reminders that the user gets when they set up a periodic export of their data to a third party.
*06:13:16-06:13:27*

And these types of details, I mean, we know that they are very important for the user experience and also, in turn, for the third party's incentives to invest in using DMA solutions.
*06:13:27-06:13:38*

And also, for App Store data still, we have worked on the type of security controls that Apple may put in place.
*06:13:38-06:13:46*

And, in short, while Apple can ask a few questions to ensure that the receiving party is legitimate, it may not impose restrictions on how the ported data is used.
*06:13:46-06:14:01*

Then, there is device switching, which is also known as OS Move.
*06:14:01-06:14:05*

And this is really, I think, one of the most important contexts for data portability.
*06:14:05-06:14:13*

And this is because, I mean, we are all smartphone users, and I'm sure that for most of us, the idea of switching to a smartphone with a different operating system looks quite daunting.
*06:14:13-06:14:26*

And, of course, I mean, we are kind of afraid that it will take us days, maybe, to get all my apps up and running, and also that I might lose my data in the process.
*06:14:26-06:14:37*

And instead, so what I do is to, when I buy a new smartphone, I will just buy a smartphone with the same operating system.
*06:14:37-06:14:45*

And one of the reasons is precisely that it's easy to port all the data from the old device to the new one.
*06:14:45-06:14:52*

Now, Apple has been working on a very exciting solution to port iPhone data to another operating system.
*06:14:52-06:15:00*

The objective is that moving from an iPhone to an on-Apple smartphone should be as easy as moving from an iPhone to another iPhone.
*06:15:00-06:15:09*

So that's such as contacts and message history.
*06:15:09-06:15:12*

But we also expect that it will cover two types of data that are a lot more complex.
*06:15:12-06:15:18*

And these are eSIM data and third-party app data.
*06:15:18-06:15:23*

And I'm sure Apple will tell you more about this.
*06:15:23-06:15:25*

And I mean, Apple, as mentioned in their compliance report, the target is for a rollout to end users by the end of this year.
*06:15:25-06:15:34*

Also, Apple has implemented a similar solution to move Safari data.
*06:15:34-06:15:41*

So with this, basically, users can use the solution to move their Safari data to other web browsers on iOS.
*06:15:41-06:15:49*

And, for example, this includes bookmarks, credit card data, and other data categories.
*06:15:49-06:15:55*

And, of course, we're engaging with Apple to make sure that this solution is easy to use for users.
*06:15:55-06:16:02*

Then quickly on 6.10, we have focused on -- I mean, this is, again, not exhaustive, but one of the areas of focus was equal conditions.
*06:16:02-06:16:13*

So we had several discussions with Apple to ensure that third parties and Apple have access to data for their own services under equal conditions.
*06:16:13-06:16:22*

And this means, for example, that when it comes to data from the App Store, the data that Spotify can obtain should be no less than what Apple obtains in relation to Apple Music.
*06:16:22-06:16:33*

And the same principle applies, for example, between Safari and Firefox in relation to iOS analytics data.
*06:16:33-06:16:42*

Then, of course, on the data that is actually made available by Apple in their compliance solution, this is an area where we welcome feedback.
*06:16:42-06:16:50*

And, of course, the premise of this is that the data should be in scope of Article 6.10 to begin with.
*06:16:50-06:16:57*

Then, again, also here we have worked with Apple on the user flow, particularly on how end users can provide consent to share personal data with a business user.
*06:16:57-06:17:09*

So the dialogue with Apple is still ongoing, as I said.
*06:17:09-06:17:13*

And we therefore encourage third parties to reach out first to Apple.
*06:17:13-06:17:19*

And if the concern is not resolved, we are willing to step in to make sure that the data portability obligations create real opportunities.
*06:17:19-06:17:27*

So it's really important to us to receive feedback based on concrete uses of the solution.
*06:17:27-06:17:33*

Now, with that, thanks for your attention.
*06:17:33-06:17:36*

And I will leave the floor to Apple so that they can tell us the amazing solutions that they have implemented in the past year.
*06:17:36-06:17:44*

>> Great.
*06:17:44-06:17:45*

Thank you very much, Andrea.
*06:17:45-06:17:47*

And I do like to keep you happy, actually.
*06:17:47-06:17:49*

So you had a number of areas for me to try and focus on today.
*06:17:49-06:17:55*

So I'm hopefully going to cover all of those.
*06:17:55-06:17:58*

And I do commend everybody that has made it true to this last session.
*06:17:58-06:18:02*

Actually, there's a few more people here than I was anticipating.
*06:18:02-06:18:07*

I was wondering about should I place a little wager on the numbers.
*06:18:07-06:18:11*

And I think we've lost, actually.
*06:18:11-06:18:12*

So thank you very much for bearing with us through the extreme heat in the room.
*06:18:12-06:18:17*

And as Andrea said, in our final session today, we're going to discuss Apple's latest work to comply with the data-related provisions of the DMA and walk through in particular our data portability APIs.
*06:18:17-06:18:30*

And we'll focus mostly on Article 6.9.
*06:18:30-06:18:33*

One of the APIs is, in fact, Article 6.10, probably true 6.9.
*06:18:33-06:18:37*

We've kind of melded them together there.
*06:18:37-06:18:39*

And 6.9 is the provision that sets out requirements for users or approved third parties to be able to download a user's covered data for use elsewhere.
*06:18:39-06:18:49*

So in what you saw on Andrea's slides there was the App Store data in the main we would be talking about there.
*06:18:49-06:18:57*

We will also discuss our collaboration with Google to make it more seamless for users to switch from iOS, iPadOS to Android, and obviously crucially from Android to iOS, iPadOS.
*06:18:57-06:19:09*

So working both ways.
*06:19:09-06:19:12*

And we've worked incredibly hard in bringing this to users since we were here last year.
*06:19:12-06:19:17*

And I am also excited to be able to talk to you about the work around it.
*06:19:17-06:19:21*

I know Andrea was very excited about it.
*06:19:21-06:19:25*

And we'll also discuss the work we've done to provide developers and business users with even more helpful data analytics, including third-party access to, as I said, the App Data Transfer API, which is probably more 6.10 related, but more than happy to talk about it and make sure everybody is aware of it.
*06:19:25-06:19:46*

As an initial matter, and I guess if you haven't been here already today, I'll say it again.
*06:19:46-06:19:53*

Apple endeavors to comply with the DMA, as you know, in a way that reduces the risks for user security and privacy as much as possible.
*06:19:53-06:20:01*

Protecting user privacy and security are the core Apple values.
*06:20:01-06:20:05*

They are rooted in the DMA itself.
*06:20:05-06:20:09*

And it aligns with the data protection goals of other European regulations, such as the GDPR, which is, of course, itself embedded in the DMA through the text of Recital 12.
*06:20:09-06:20:22*

Central to a discussion about data portability in Apple's case is understanding what user data Apple actually stores in the first place.
*06:20:22-06:20:31*

Apple, as I believe you will all know, practices data minimization.
*06:20:31-06:20:35*

That means we collect only the minimum amount of data required to deliver a given service.
*06:20:35-06:20:42*

We imply on-device intelligence and other features to minimize the data that we collect in our apps, browsers, and on online services.
*06:20:42-06:20:52*

These privacy values are built into everything we make.
*06:20:52-06:20:56*

Just to give one example, Apple Pay uses a device-specific number and unique transaction code, so your card number is never stored on your device or on Apple servers.
*06:20:56-06:21:09*

Moreover, Apple does not collect data on iOS, iPadOS, or Safari in a way that identifies individual users.
*06:21:09-06:21:19*

The only Apple core platform service that collects data on a user-by-user basis is the App Store.
*06:21:19-06:21:25*

And even then, Apple only collects user information that is necessary for the App Store to function as intended.
*06:21:25-06:21:33*

That means Apple does not, and in fact cannot, facilitate end-user access to individualized Safari or iOS data on our servers.
*06:21:33-06:21:43*

Instead, this data, in an identifiable form, is stored on-device and is only shared across your devices using end-to-end encryption.
*06:21:43-06:21:53*

This data is neither controlled nor accessible by Apple, nor is it accessible to any third party, unless the user explicitly chooses to transfer it to them, in a process I'll talk about in a little bit.
*06:21:53-06:22:07*

Some of your feedback to Andrea, which was encouraging, is "Why am I having Safari data, or iOS data, or iPadOS data?" Well, the reason is we don't have access to it ourselves.
*06:22:07-06:22:18*

As a brief note, before we go further, I want to mention something that Andrea mentioned there in passing, that since last year, we have developed our browser switching solution for exporting relevant browser data from Safari into another browser on the same device.
*06:22:18-06:22:33*

We introduced that with iOS 18.2 also.
*06:22:33-06:22:38*

And this allows the user to move bookmarks, browsing history, saved passwords, usernames, installed extensions, and credit card data.
*06:22:38-06:22:51*

The selected categories of data can be imported or exported across browsers on a user's iPhone or iPad.
*06:22:51-06:22:58*

We do warn users that their exported data is not encrypted, and we recommend to all users that after they import their data into another browser, that they should delete the export file.
*06:22:58-06:23:08*

Now, let's talk in more detail about our approach to portability of the server-side data that we do have.
*06:23:08-06:23:16*

We come to this conversation with significant experience leading and influencing industry work on portability.
*06:23:16-06:23:24*

We've been consistent in our commitment to portability for decades, contributing to external initiatives such as the Data Transfer Project, now called Data Transfer Initiative, which shares our goal to empower users to transfer their data from one service to another.
*06:23:24-06:23:41*

At the core of our data portability design is the idea that users should be in control of their own data.
*06:23:41-06:23:48*

We make it easy for users to download key data or transfer to third parties if they so choose.
*06:23:48-06:23:57*

Through Apple's data and privacy page, a user can download a copy of different categories of their own data, or can even choose to delete their Apple account and associate the data entirely.
*06:23:57-06:24:08*

We did much of this work even before the DMA.
*06:24:08-06:24:11*

For example, we implemented a means for users to export a copy of their photos from iCloud to Google Photos four years ago, three years before Google was in a position to reciprocate.
*06:24:11-06:24:22*

So let's talk briefly about the features that are specific to users only, and then get into detail about our APIs that facilitate effective portability for third-party developers.
*06:24:22-06:24:35*

On the user side, we built off of our pre-existing data and privacy page, which gave users control over relevant App Store data again before the DMA, and created certain features to make the process abundantly clear.
*06:24:35-06:24:50*

This includes the ability for users to download data at recurring intervals, clearly see exactly what data is available to request, provide data on a real-time or ongoing basis as desired by the user, and cancel imminent or scheduled data requests.
*06:24:50-06:25:08*

The first link on this slide will take users to an Access Request menu, where they can choose to download their data from multiple applications.
*06:25:08-06:25:17*

This includes options for downloading data on services that are not identified as core platform services under the DMA.
*06:25:17-06:25:25*

As for the DMA solutions, users can also select a one-time or recurring download of their data.
*06:25:25-06:25:32*

Once a user submits their request, they can monitor its status on the data and privacy page.
*06:25:32-06:25:40*

I think maybe our slides went off a little bit there.
*06:25:40-06:25:44*

You should be picturing great things happening, a blue box on the side, various things look something like that.
*06:25:44-06:25:53*

So now let's turn to our APIs that enable data portability for third-party developers.
*06:25:53-06:25:58*

I'm going to go over two separate but related APIs today.
*06:25:58-06:26:02*

The first is called Account Data Transfer API, which allows users to authorize a third-party to pull data on their behalf.
*06:26:02-06:26:10*

If a user wants someone to be able to pull all of their App Store history, Account Data Transfer API can securely facilitate that data transfer.
*06:26:10-06:26:19*

The second is called App Data Transfer API.
*06:26:19-06:26:23*

This API can be used by developers to request and download user-specific information for their own app specifically.
*06:26:23-06:26:32*

First is the Account Data Transfer API.
*06:26:32-06:26:35*

This allows users to authorize a third-party to pull data on their behalf.
*06:26:35-06:26:39*

This means users can sign into their third-party accounts and approve the transfer of App Store data that falls within the scope of the DMA.
*06:26:39-06:26:47*

So when a user downloads a third-party service or platform, with this option enabled, a user can then choose to link their new app or web account with their Apple account so that the third-party can pull in the available user data.
*06:26:47-06:27:02*

We've implemented the Open Industry API, the OAuth handshake, to facilitate this.
*06:27:02-06:27:08*

This allows Apple to authenticate the user within the context of the third-party service or platform and subsequently to place requests to obtain DMA-covered data about the user from Apple.
*06:27:08-06:27:22*

That describes the interface and integrations we built to enable the third-party to request data.
*06:27:22-06:27:27*

We also had to build a means to manage continuous, ongoing data transfers.
*06:27:27-06:27:32*

As Article 6.9 requires continuous real-time access to data, we built the Account Data Transfer API to enable users to authorize a third-party to pull data on their behalf on an ongoing basis without having to submit multiple requests.
*06:27:32-06:27:49*

End users can now initiate the transfer of their data themselves, either through Apple's data and privacy page, or authorized third-parties can use the API to integrate directly with us.
*06:27:49-06:28:01*

We have gone ahead and allowed for quick and recurring downloads and transfers should users opt into these features.
*06:28:01-06:28:08*

The user also decides how long they want their data to be ported over.
*06:28:08-06:28:13*

This can be a one-off pull, a daily pull for 30 days, or a weekly pull for 180 days.
*06:28:13-06:28:20*

These time limits ensure that this personal data is not continuously transferred to the third-party for an unlimited time period.
*06:28:20-06:28:27*

We want to make sure users don't forget they're allowing others to access their data.
*06:28:27-06:28:33*

Apple also understands that there are inherent risks associated with any form of data portability, especially when it involves granting access to third-parties to all of a user's in-scope set of App Store data, which includes every review a user has written and every app a user has ever downloaded.
*06:28:33-06:28:50*

This data can be very personal, like which dating or health apps you've downloaded and when.
*06:28:50-06:28:56*

That's why we have now implemented robust wraparound protections for the API to guard user privacy.
*06:28:56-06:29:03*

I do want to note three things on this point.
*06:29:03-06:29:07*

First, Apple wishes to take steps to minimize the possibility of third-parties using or obtaining data in a way that will cause unacceptable risk.
*06:29:07-06:29:15*

So we undertake a process where third-party services or platforms undergo additional review and are potentially denied, when there is a high risk that a third-party service or platform will use a user's data to their detriment, like to sell or license the third data to third-parties unknown to the user.
*06:29:15-06:29:35*

Second, and this is key, Apple requires third-parties to enroll and go through a round of due diligence before qualifying for access to the Account Data Transfer API.
*06:29:35-06:29:46*

Third-parties request access to this API by submitting a short, as I heard Andrea describe it, questionnaire to Apple.
*06:29:46-06:29:54*

Among other things, this form asks whether they plan to sell or license user data to third-parties that the user has no relationship with, and if so, asks for additional information.
*06:29:54-06:30:05*

If their response indicates a higher level of risk to personal data, the third-party undergoes additional review and potentially can be denied.
*06:30:05-06:30:14*

If a third-party's request is rejected, they will be told why and informed about how they can get in touch if they disagree with our decision.
*06:30:14-06:30:23*

These kinds of checks are performed by Apple's industry-leading and highly trusted data protection team.
*06:30:23-06:30:29*

These checks are necessary to ensure that this provision of the DMA does not double as an easy way for third-parties to misuse user's data.
*06:30:29-06:30:36*

And I do commend the Commission from an early stage agreeing that it was important the DMA not become synonymous with abuse of data in this space.
*06:30:36-06:30:45*

A third note here, of course, Apple requires authorization from the user before an approved third-party developer can use the API for their data, which means we've implemented user authentication and authorization, including the integration of two-factor authentication.
*06:30:45-06:31:04*

Understanding the inherent risks to data portability I mentioned before, and the potential sensitivity of sharing every app purchase or download, we also want to make sure a user does not authorize continuous data transfers and then forget they did so.
*06:31:04-06:31:18*

To that end, after a user has authorized an approved third-party developer to use the API for their data, the user will see who they are sharing the data with on their sign-in page and their data and privacy page.
*06:31:18-06:31:31*

Apple provides users with confirmation when they link to a third-party account, when a transfer request is placed, and when a request is completed, and for recurring requests when the transfers are scheduled to end.
*06:31:31-06:31:46*

Importantly, a user can cancel sending their data to a third-party at any time via Apple's data and privacy page.
*06:31:46-06:31:53*

Apple's portability mechanism aims to ensure that throughout the entire process, the user remains in control of their data transfers.
*06:31:53-06:32:02*

Now let's look at how this works in practice by walking through the user flow for the Article 6.9 portability solution we've created.
*06:32:02-06:32:10*

A user will be brought to a page where they can initiate a data transfer request.
*06:32:10-06:32:15*

They sign in to their user account.
*06:32:15-06:32:18*

Then they can see what information is sought by the third party, for example, their personal information or their app install information.
*06:32:18-06:32:28*

The user can drill down and see more detailed information about what the third party's website or app to initiate the request.
*06:32:28-06:32:36*

Once the user confirms, they will receive an email summarizing the data they have approved for developer access.
*06:32:36-06:32:44*

And when the request is in progress, users can also see ongoing data requests on the data and privacy page.
*06:32:44-06:32:53*

Users will receive an email confirmation with a portability.
*06:32:53-06:32:58*

The account data transfer API, which we've just been discussing, has a sibling named the App Data Transfer API.
*06:32:58-06:33:06*

It is available to all developers in the EU and allows them to request and download user-specific app store information and app install activity data for their specific app on an individualized basis.
*06:33:06-06:33:19*

To implement it, the developer needs to enable the relevant entitlement on developer.apple.com for the specific app, as we just saw for account data transfer.
*06:33:19-06:33:30*

The difference is that developers can only ask for and receive personal data for their own app.
*06:33:30-06:33:37*

So, where for the account data transfer API, the user authorizes the third party to access all in-scope app store data, for the App Data Transfer API, the user only authorizes the developer to access data related to their app.
*06:33:37-06:33:53*

So, those are the APIs.
*06:33:53-06:33:55*

Now, let's talk about the uptake of these features.
*06:33:55-06:33:59*

I'll start with user self-service requests for their own data via the data and privacy page.
*06:33:59-06:34:05*

We receive about 650 requests a week from users via the data and privacy page.
*06:34:05-06:34:12*

The most popular request type has been the one-time request for lifetime data.
*06:34:12-06:34:17*

We get about 575 requests for that option each week.
*06:34:17-06:34:22*

The recurring requests have been less popular.
*06:34:22-06:34:25*

Every week, we receive about 30 requests for recurring daily downloads and about 20 requests for recurring weekly downloads.
*06:34:25-06:34:34*

Apple listens carefully to feedback from users as we design capabilities.
*06:34:34-06:34:39*

And when users have good points to make, believe me, we hear about it.
*06:34:39-06:34:43*

To date, with data download and transfer, we have not heard any concerns from users, whether about the availability, design, or anything else.
*06:34:43-06:34:54*

As for the APIs we created for the DMA, those numbers are smaller.
*06:34:54-06:35:00*

We've had a grand total of seven third parties apply to use the Account Data Transfer API.
*06:35:00-06:35:07*

Of those seven, five were flagged as ineligible, either because they were intended for non-commercial research or because the applications were fake.
*06:35:07-06:35:16*

We now have two approved third parties, but neither of them have made a request via the API so far.
*06:35:16-06:35:23*

As for the App Data Transfer API, about 300 developers have enabled it, but none of them have ever used it.
*06:35:23-06:35:31*

We've also received zero technical support queries about these portability solutions and only three non-technical queries over the past 17 months.
*06:35:31-06:35:41*

Now there is a good chance that developers simply don't know about these options, and we hope this presentation and other information on our website helps spread the word.
*06:35:41-06:35:52*

On a different note, we know developers do use and benefit from app analytics reports.
*06:35:52-06:35:58*

And Apple has been strengthening its information with developers for years.
*06:35:58-06:36:02*

Our approach gives developers and Apple more of an equal opportunity than ever to access data analytics.
*06:36:02-06:36:09*

In the EU, users can elect to not share their data at all or to share their data analytics with Apple and developers.
*06:36:09-06:36:19*

Developers have access to dashboards and reports to measure performance through app analytics, sales and trends, and payments and financial reports, and reporting through APIs.
*06:36:19-06:36:30*

Since I spoke here at last year's DMA workshop, Apple has worked to further the means available for developers to engage with the analytics we make available.
*06:36:30-06:36:38*

As we announced earlier this month at WWDC, app analytics is providing powerful new data visualizations and automated reports to help developers measure the performance of their apps.
*06:36:38-06:36:51*

Metrics are also organized by customer lifecycle stages, so it's easier to find the metrics developers care about most.
*06:36:51-06:36:59*

What's more, new subscription reports will include app download source data, so developers can better understand where people found their app.
*06:36:59-06:37:11*

With that said, let me make one more note here on our values.
*06:37:11-06:37:14*

Apple will always be cognizant of the balance between ensuring developers have the information they need to grow their apps and the core tenet of gathering only data that is necessary to collect and ensuring that data remains protected.
*06:37:14-06:37:27*

In sharing these analytics, we will continue to provide data as appropriate aggregates, blend unique user data, and add noise to data to mask personal information where warranted.
*06:37:27-06:37:39*

But of course, Apple's relationship with developers is not a one-way street, and we welcome their feedback.
*06:37:39-06:37:45*

They can easily submit it via Feedback Assistant.
*06:37:45-06:37:49*

And finally, and as promised at the start, I wanted to talk about the work we've done over this past year with Google to make it even more seamless for users to switch from their iOS/iPadOS devices to Android, and as I said, crucially, vice versa.
*06:37:49-06:38:04*

This is a huge undertaking on both sides, so let me be clear about how Apple is approaching this.
*06:38:04-06:38:12*

We are treating this as a top priority, tracking progress closely, and are working hard to ensure delivery on time.
*06:38:12-06:38:20*

We have devoted thousands of engineering hours to build a process that feels very simple to users.
*06:38:20-06:38:26*

That your experience changing from Android to iOS, iPadOS, and vice versa is as seamless as possible for the user.
*06:38:26-06:38:34*

But while this may be simple for users, it is not at all simple for Apple.
*06:38:34-06:38:38*

This is a big project.
*06:38:38-06:38:42*

Aligning on data classes, shipping schedules, etc. is complex enough when it is just Apple.
*06:38:42-06:38:48*

When you add a completely different partner to the mix, that obviously adds more complexity, even with positive intent on both sides.
*06:38:48-06:38:57*

Google claims that it is in fact even more complicated than that, as Android is obviously available on a number of other device manufacturers' devices.
*06:38:57-06:39:07*

We have also needed to engage with a large number of carriers to ensure that the solution to seamlessly port your eSIM across devices will work as intended.
*06:39:07-06:39:16*

This requires a large amount of testing and development work.
*06:39:16-06:39:20*

But we are making progress, and we expect to have the solution available to ship by the end of the year.
*06:39:20-06:39:27*

Users then will have the possibility of seamlessly porting all the data on their devices, including third-party app data, messages data, contacts, browser data, passwords, photos, videos, and so on, over to their device of choice.
*06:39:27-06:39:45*

With that, we would like to thank the European Commission for hosting this session today.
*06:39:45-06:39:50*

I will say I am very, very happy to take your final round of questions on the data portability discussed.
*06:39:50-06:39:58*

Excellent.
*06:39:58-06:39:59*

Thank you very much, Gary.
*06:39:59-06:40:01*

So, indeed, I will open the floor for the questions.
*06:40:01-06:40:05*

Then -- no, not you.
*06:40:05-06:40:08*

[ Laughter ]
*06:40:08-06:40:10*

And then we'll also follow the slide door.
*06:40:10-06:40:12*

And then just to announce that we will have Rita having closing remarks.
*06:40:12-06:40:18*

And then you will all be released from this room.
*06:40:18-06:40:22*

So, hands up, please.
*06:40:22-06:40:24*

Please.
*06:40:24-06:40:26*

You may have already answered my question.
*06:40:26-06:40:28*

Again, Natasha Gerlach with CIPL, but from the heat, I'm not sure.
*06:40:28-06:40:32*

Maybe I misheard you.
*06:40:32-06:40:34*

So, we looked at data portability in light of the GDPR quite detailed and reissued a report on that.
*06:40:34-06:40:43*

And we'll do some more research.
*06:40:43-06:40:46*

But what struck us is that under the GDPR, you know, you also have data portability provisions, of course.
*06:40:46-06:40:52*

And there you would assume that data is ported from one controller to the other.
*06:40:52-06:40:59*

And so the GDPR compliance moves along with the data.
*06:40:59-06:41:03*

But the DMA is not focused on personal data alone, as Gary outlined quite detailed just now.
*06:41:03-06:41:13*

So there's non-personal data that's included in this.
*06:41:13-06:41:16*

And we don't actually necessarily know who the third party is that requests the data in the end, so they may or may not be subject to the GDPR, or they may be in a jurisdiction where this would be very difficult to enforce, which, by the way, leads to interesting questions on data transfers as well.
*06:41:16-06:41:34*

And, you know, we looked at, you know, how do we know how this third party, the developer, obtained the authorization from the end user, for instance, to ask whether data were coercive measures used.
*06:41:34-06:41:48*

Did the end user understand what they were authorizing in the end?
*06:41:48-06:41:51*

The Data Act has provisions on all of that, but the DMA doesn't.
*06:41:51-06:41:57*

And so you mentioned, you know, also that there are data transfer frameworks, like we have in open banking as well.
*06:41:57-06:42:06*

You mentioned the data transfer initiative, which Cibil also supports to ensure that, again, we don't know who the third party is necessarily.
*06:42:06-06:42:14*

It could be two men in a van, and we don't know what their security measures are.
*06:42:14-06:42:17*

And so there should be some minimum security standards.
*06:42:17-06:42:21*

But what my question actually was, and maybe you answered this, was because, of course, you have very little influence on that.
*06:42:21-06:42:28*

You have to port this data out on what the GDPR compliance of those who import the data may or may not be.
*06:42:28-06:42:36*

But do you have any indicators of who these third parties are?
*06:42:36-06:42:40*

And this is where I'm not sure I heard you right, but I think you mentioned some numbers that were quite low in terms of who asked for this data.
*06:42:40-06:42:49*

Thank you.
*06:42:49-06:42:55*

Hi, Kay Gibelli, Chamber of Progress.
*06:42:55-06:43:00*

You've mentioned quite a vast amount of changes that you're making, including ones that you will be making.
*06:43:00-06:43:07*

I'm very eager to see the data as it comes in, but the data that you did show on usage is also interesting.
*06:43:07-06:43:14*

How does the ratio of the investment that you guys have made in terms of engineering to prepare these solutions to the number of actual uptake and usage of these solutions compare to other things that you create for your users?
*06:43:14-06:43:28*

Thank you.
*06:43:28-06:43:32*

So Geoffrey from Kuit App Maker.
*06:43:32-06:43:35*

And so with the app data transfer, will you be able to transfer data from one app to the same competitor's app?
*06:43:35-06:43:43*

Let's say I have a competitor doing the same thing that I do.
*06:43:43-06:43:46*

Will I be able to implement something to get data from the app to import it in mine?
*06:43:46-06:43:52*

And second one is concerning the Android to Apple transfer.
*06:43:52-06:43:56*

Will this work also with all Samsung overlay and all the overlay that you see on Google?
*06:43:56-06:44:02*

Thank you.
*06:44:02-06:44:09*

It was very similar.
*06:44:09-06:44:11*

Sorry, Mike Sachs App Association.
*06:44:11-06:44:13*

We are a trade association.
*06:44:13-06:44:14*

Apple is a sponsor.
*06:44:14-06:44:16*

Our members are SMEs.
*06:44:16-06:44:18*

The data device portability is very interesting to us.
*06:44:18-06:44:23*

My first question was very similar to the one that was previously asked, but related to that, a lot of us have -- many of us have apps that are only available on one platform, but we have partner other independent companies that offer similar solutions on the other platforms, and we would like to make sure that it remains in the independent family.
*06:44:23-06:44:50*

So in addition to the scenario where a user is porting data from one platform to another within the same app, is there -- have you thought about the idea of basically two independent app makers that are active on a specific platform working together and facilitating the data transfer so that they can continue to use an independent app?
*06:44:50-06:45:21*

John?
*06:45:21-06:45:23*

Thank you so much for giving me the mic.
*06:45:23-06:45:24*

I know I talk a lot.
*06:45:24-06:45:26*

In the previous section, I criticized Apple a bit, so instead in this section, I want to start by genuinely thanking you guys.
*06:45:26-06:45:32*

I just want you to know it's a heartfelt thank you.
*06:45:32-06:45:35*

In February, the U.K. ordered Apple to break iCloud's end-to-end encryption, and Apple challenged the U.K.'s incredibly privacy-invasive order.
*06:45:35-06:45:43*

So I would like to thank Apple for challenging the U.K.'s order and upholding their security and privacy promises in the U.K. to the extent that the law allows them, and fighting for the privacy and security of journalists, activists, minorities who deeply need advanced data protection, especially nowadays.
*06:45:43-06:45:59*

So thank you for doing that.
*06:45:59-06:46:00*

I think iCloud is an incredible cloud platform that is an integral part of iOS, iPadOS, macOS, and Apple is absolutely leading the way in this particular area.
*06:46:00-06:46:10*

And as a reminder, in contrast, just a few days ago, to comply with a U.S. executive order, Microsoft helped suspend the email account of an international criminal court prosecutor in the Netherlands.
*06:46:10-06:46:20*

So due to stories and events like these, and changes in global politics, Europeans are increasingly more concerned and looking for European cloud solutions, and many European small companies are reporting 100% to 200% monthly increase in new users.
*06:46:20-06:46:35*

I also think that it would be exemplary of Apple to offer data migration options to allow Europeans to keep their data here in Europe, using other encrypted European services, so that users can freely choose to store their data, like photos, with other companies in legal jurisdictions they prefer.
*06:46:35-06:46:52*

So my question is, will Apple make it easier for Europeans to move their data from iCloud photos to other heavily encrypted security and privacy-focused European photo storage services like Crypty?
*06:46:52-06:47:03*

Perhaps similar to the way Apple offers direct data migrations to Google Photos, which sadly is neither end-to-end encrypted, nor does it have a focus on privacy.
*06:47:03-06:47:13*

So if Apple has security or privacy concerns about improved data portability, can they explain why these same concerns don't apply to Google Photos, a service that is not encrypted, and what specific security measures prevent Apple from extending their existing migration options to other legitimate services providers in Europe like Crypty?
*06:47:13-06:47:31*

Thank you.
*06:47:31-06:47:32*

Quite some material, Gary.
*06:47:32-06:47:36*

You don't have your friend here, so you will have to handle it by yourself.
*06:47:36-06:47:41*

No, that's fine.
*06:47:41-06:47:44*

I think I'll take John's first, because it's just in my mind.
*06:47:44-06:47:48*

And also, I knew there was going to be a sting in the tail.
*06:47:48-06:47:52*

You know, it was coming, you know, it seemed all great, and then it was coming at the end.
*06:47:52-06:47:56*

But I think it's all fine.
*06:47:56-06:47:58*

Thank you very much for the positivity on the work we've done in analytics.
*06:47:58-06:48:03*

Thank you for the words in relation to advanced data protection.
*06:48:03-06:48:07*

I obviously cannot say anything specific about the status of that or whether it in fact even was about advanced data protection, to be clear.
*06:48:07-06:48:16*

I don't know much about the individual situations that you mentioned in relation to some other companies.
*06:48:16-06:48:22*

And I think the – let's take the iCloud photo transfer issue.
*06:48:22-06:48:27*

So one of the areas that I'm very anxious to see is more industry members joining initiatives, such as the data transfer initiative.
*06:48:27-06:48:40*

That, to my mind, will then encourage portability of data on an increased scale.
*06:48:40-06:48:46*

So I think, as I mentioned in my presentation, we actually put in place transfer from iCloud photos to Google photos a number of years before we were in a position to finalize it with Google.
*06:48:46-06:48:58*

We did that because we felt it was the right thing to do.
*06:48:58-06:49:02*

And the user has to very much explicitly consent to doing that.
*06:49:02-06:49:07*

And if there's a company such as Crypti or any other company, we are here, available.
*06:49:07-06:49:12*

We want to make that work.
*06:49:12-06:49:14*

The framework for making it work as efficiently as possible would be through the data transfer initiative.
*06:49:14-06:49:20*

And I think it would really benefit from having some other voices in there.
*06:49:20-06:49:25*

So I can even give you some details of people who would be more than happy to talk about that, John.
*06:49:25-06:49:30*

I think next year I'll move to just beyond Helsinki, in fact, and then maybe I'll get to ask more questions from the floor.
*06:49:30-06:49:37*

I think then I'll go back to where Natasha was.
*06:49:37-06:49:40*

I think we said we had seven requests, Natasha.
*06:49:40-06:49:44*

Two of them were, I think, they just – I think they hit by accident, actually, is my view.
*06:49:44-06:49:51*

Two of them – there was really only one that was, to my mind, a use case that would have caused a huge risk to data.
*06:49:51-06:50:00*

And again, through my work with my colleagues as I look down here, through Andrea, Dennis and Antoine, we have worked through a process of trying to make sure we're striking the right balance.
*06:50:00-06:50:11*

Obviously, we care deeply about privacy and security.
*06:50:11-06:50:13*

That is not to try and stop legitimate requests being fielded.
*06:50:13-06:50:18*

And where we receive a legitimate request, those requests are being granted.
*06:50:18-06:50:23*

It's just for whatever reason, the two that we have granted them to, and it's probably only over the last three to four months that they've gone through.
*06:50:23-06:50:30*

Maybe they just haven't been able to do the work necessary on their side to engage their users.
*06:50:30-06:50:34*

It could be any reason.
*06:50:34-06:50:35*

But to pick up Kay's point, we've done an incredible amount of work on this.
*06:50:35-06:50:41*

I actually asked somebody to take a look at it last week, and I think we've had 300 engineers working on it across the various different teams.
*06:50:41-06:50:52*

And so therefore, we want it to be used.
*06:50:52-06:50:55*

We want people to use this functionality to get the benefit of what we've put in place.
*06:50:55-06:51:00*

This is something we've always been focused on ensuring.
*06:51:00-06:51:02*

We were certainly one of the leaders in terms of providing data in a common industry format such as XML with a view to GDPR.
*06:51:02-06:51:10*

We follow that now under DMA.
*06:51:10-06:51:12*

We want this thing to work.
*06:51:12-06:51:13*

This has not been one of the areas where we've had extensive regulatory dialogue with the Commission.
*06:51:13-06:51:19*

We might have some difference of opinion here as to what the law actually requires, but in fact, that hasn't stopped us trying to arrive at workable solutions that benefit the end user.
*06:51:19-06:51:30*

Then I think, Jeffrey, you had a question about app-to-app transfer.
*06:51:30-06:51:34*

So what you do get is that anybody who wants to ask for all of your App Store data, if you sign up and get the account data transfer API, you can have all of that.
*06:51:34-06:51:43*

You can also have your own app data with a personal identifier associated with it.
*06:51:43-06:51:49*

That was something we were told developers wanted pre-DMA.
*06:51:49-06:51:52*

We haven't seen it come true since, but it is there.
*06:51:52-06:51:56*

I think, again, for that app-to-app transfer, I think initiatives such as the data transfer initiative are going to be a good way to drive that forward.
*06:51:56-06:52:06*

I think it is at least arguable that that requirement already exists in Article 20 of the GDPR for those developers that are established here in the EU, so that could be a space to explore in relation to it.
*06:52:06-06:52:22*

I think maybe Mike – oh, you also raised the point about device portability.
*06:52:22-06:52:27*

So, yes, Samsung is not a designated gatekeeper, so Samsung is not required to participate in the device portability initiative.
*06:52:27-06:52:38*

I do know that Google – and you'll have a chance to ask them questions, I think they're tomorrow, right?
*06:52:38-06:52:43*

They are engaging, as I understand it, with Samsung.
*06:52:43-06:52:47*

We believe it to be crucial that users have the ability to make a choice to port to and from Samsung and other major device manufacturers as well, and not just Pixels, and I know that is something that Google is also focused on as part of the conversations we're having, and I think that would be a kind of fair outcome for everybody involved.
*06:52:47-06:53:10*

I think maybe there was a point from Mike in relation to apps available on only one platform, and is the data moving across?
*06:53:10-06:53:19*

Yes.
*06:53:19-06:53:20*

If we have friendly relationships with another independent app developer, for example, who has an Android app, and the user wants to switch between our two apps, is there a scenario, maybe not in the first version by the end of this year, where you can envision basically users porting their data from one platform to another, but then to an app that provides similar functionality?
*06:53:20-06:53:47*

Yes.
*06:53:47-06:53:48*

I think your best bet is going to be Article 20 of the GDPR, unless the Commission has grand plans to designate many, many, many more gatekeepers, which I don't think they're going to reveal that today, so I think that's probably the best basis to look at that, and again, as I was saying in response to the question to Jeffrey, probably, to my mind, that's a GDPR issue, perhaps more so than a DMA one.
*06:53:48-06:54:11*

That's not to in any way try to impede.
*06:54:11-06:54:13*

And just to be clear, I didn't mean to obligate people into doing that.
*06:54:13-06:54:18*

It would be an entirely voluntary collaboration.
*06:54:18-06:54:21*

Yes, yes.
*06:54:21-06:54:22*

I think you would be very anxious not to do that.
*06:54:22-06:54:25*

But in terms of -- so I would suggest that the data transfer initiative -- and I'm not here, I'm not on a commission for getting new members for it, but I do think it is worthy work and one that benefits us all to have standards developed that we can all work against in this space.
*06:54:25-06:54:41*

Very good.
*06:54:41-06:54:46*

I have a couple of questions from Slido.
*06:54:46-06:54:50*

Andrea?
*06:54:50-06:54:52*

Yes, so there are a few questions by Jacob Endler from Datapods, who for context is one of the two admitted parties to the API, and they do have valid access tokens for the request, and this will become clear in a second.
*06:54:52-06:55:12*

So one question says that the documentation instructs that one can request data via a post request to the URL, you know, accountdatatransfer.apple.com.
*06:55:12-06:55:23*

This endpoint has not been reachable for months.
*06:55:23-06:55:26*

We have raised this issue in a support ticket in April without answers so far.
*06:55:26-06:55:31*

Then there is another question that, you know, maybe is a bit too technical for this forum, but I mean, basically one question is from the same person.
*06:55:31-06:55:42*

As issues with the implementation are becoming apparent, is there a technical contact we can reach out to to make Apple's DP API a working product?
*06:55:42-06:55:53*

The documentation is not clear on contact details.
*06:55:53-06:55:56*

The generic support is unresponsive.
*06:55:56-06:56:01*

And then I'm going to another question by Ian Brown.
*06:56:01-06:56:07*

Apple's OS transfer process works really nicely between two iOS devices.
*06:56:07-06:56:13*

The set of apps which reliably break for me in that process are high security ones, such as Signal and banking apps.
*06:56:13-06:56:20*

Will Apple develop the process farther in the future?
*06:56:20-06:56:27*

I hope that's the Ian Brown, actually, noted privacy and security researcher.
*06:56:27-06:56:33*

I heard a question from him earlier as well.
*06:56:33-06:56:37*

Well, it is intended that third party data will transfer as part of the device switching solution that we're working on.
*06:56:37-06:56:47*

I think that provides a good basis for that kind of thing to happen.
*06:56:47-06:56:50*

And so certainly Signal will be able to opt in if they're able against their security model to have the data transfer.
*06:56:50-06:56:58*

And I know that was when you were particularly focused on yourself, Andrea, as we had those conversations.
*06:56:58-06:57:03*

So I'm hoping it will be facilitated for.
*06:57:03-06:57:05*

In relation to Jacob, I'd like to hear about that.
*06:57:05-06:57:09*

I'm not aware of that.
*06:57:09-06:57:10*

I hope the support ticket's gone to the right place.
*06:57:10-06:57:12*

So I'd like to take that away.
*06:57:12-06:57:14*

So if you can pass my details, which you have, Andrea, to Jacob, I'll personally take that one up.
*06:57:14-06:57:21*

Very good.
*06:57:21-06:57:24*

Any more burning questions in the room?
*06:57:24-06:57:27*

Please.
*06:57:27-06:57:29*

Again, I don't really need the microphone.
*06:57:29-06:57:33*

At what point do you think Apple might die of death by API?
*06:57:33-06:57:39*

Okay.
*06:57:39-06:57:40*

It has the benefit of being short.
*06:57:40-06:57:45*

John, can you match that?
*06:57:45-06:57:48*

Okay, try.
*06:57:48-06:57:51*

Thank you.
*06:57:51-06:57:52*

So Apple has a pretty cool data portability section on their data and privacy page where users can request exports of their data.
*06:57:52-06:57:59*

However, the process is a bit cumbersome and incomplete, and I want to give a little bit of a background as to how I think it can be better and ask a question related to data exports in general.
*06:57:59-06:58:08*

Today, if an iOS user wishes to export their data from iCloud, Apple offers users three options.
*06:58:08-06:58:14*

One, download your photos individually, maximum 1,000 photos at a time through iCloud.com in the browser, which is incredibly impractical for large photo libraries that consist of hundreds of gigabytes of photos.
*06:58:14-06:58:27*

Option two, request a full account export that takes days to process and arrives as a massive zip file.
*06:58:27-06:58:33*

So if the user has a terabyte of photos, this requires the user to have yet another free terabyte on their drive due to needing to unzip the exported photos.
*06:58:33-06:58:41*

Option three, and this is my personal favorite, users can use Apple's own photos app on iOS by tapping share, which incredibly crashes if you select more than 3,000 to 4,000 photos and tap share.
*06:58:41-06:58:53*

So you can't realistically use it either.
*06:58:53-06:58:56*

And you're welcome to try this out today for fun if you would like to try to crash it.
*06:58:56-06:59:00*

Even if you export photos in smaller batches, the photos app strips some metadata, and this approach doesn't preserve the user's albums or organizational preferences.
*06:59:00-06:59:09*

Now, under the DMA, Apple is required to provide effective portability of data, and even though I acknowledge the difficulty of dealing with gigabytes of data, I would respectfully argue that the current iCloud photos export process clearly falls short if not fails in this area when the photos app crashes.
*06:59:09-06:59:26*

So it's either ineffective or fails to preserve some metadata.
*06:59:26-06:59:30*

So my question is this.
*06:59:30-06:59:32*

When will Apple provide reliable migration options for iCloud photos that allows users to migrate their photos with full metadata and albums intact to their own hard drives?
*06:59:32-06:59:41*

And just to be clear, I'm not even talking about migrating to a competing service.
*06:59:41-06:59:44*

I'm simply talking about letting users back up their data to their own hard drives.
*06:59:44-06:59:48*

So it's not even an issue of security or privacy or competing services.
*06:59:48-06:59:52*

It's just letting them back up their data easily.
*06:59:52-06:59:54*

Thank you.
*06:59:54-06:59:55*

Interesting question, but you failed miserably.
*06:59:55-06:59:58*

Anyone else in the room would like to ask questions on 69610 data portability and the new Brave world?
*06:59:58-07:00:08*

No.
*07:00:08-07:00:09*

Well, so that means, Gary, you have your last couple of minutes, and then the floor will be Rita's for closing remarks.
*07:00:09-07:00:21*

Right.
*07:00:21-07:00:22*

Okay.
*07:00:22-07:00:23*

Let's take those two things and turn -- John, it was going so well earlier.
*07:00:23-07:00:29*

So I'm obviously not going to accept that iCloud data is in scope of the DMA.
*07:00:29-07:00:35*

I hope you'll forgive me if I'm going to draw that line in relation to it.
*07:00:35-07:00:40*

That is not covered.
*07:00:40-07:00:42*

I'm more than happy to take your feedback in relation to iCloud.
*07:00:42-07:00:45*

I will say we have a fantastic system that we've built to allow you to port it directly to another controller, and as we said earlier, I would love more controllers to be part of that.
*07:00:45-07:00:57*

The browser-based solution that has existed for many years because, as I mentioned earlier, we have been focused on interoperability for years in advance of the DMA, and the Photos App solution was also developed independently of that, and if there's issues around numbers and how to do it, that is reflective of scaling issues, and I'm sure we'd be happy to take additional feedback on that one.
*07:00:57-07:01:21*

And then Mike's point, I don't think we're quite at it yet, Mike, in terms of API, but of course it may come along, it may come along eventually, but as of now, we are dutifully engaging as well as we can, and especially in this space, as I mentioned earlier, this is a space we want to get right, and this is a space we think users benefit from, and so the investment that we're putting into it right now, it might be outweighed by the actual return we're seeing, but it is one that we are committed to continuing to engage on because we think it is important for users.
*07:01:21-07:01:51*

And I think that's a very important point
*07:01:51-07:11:27*