What Apple's UK SMS Designation Means for Browsers and Web Apps

TL;DR: The UK’s Competition and Markets Authority (CMA) has officially designated Apple as having Strategic Market Status (SMS). After four years investigating Apple’s restrictions on browser engines and web apps, the CMA now has statutory authority to enforce remedies proposed in its Market Investigation Reference completed this year.

The most important outcomes being:

• Apple can be compelled to allow third-party browsers on iOS to use their own engines.

• Apple can be compelled to provide equivalent access to functionality for browsers using their own browser engines.

• Apple can be compelled to let third-party browsers install and manage web apps using their own engines.

• Apple can be compelled to remove barriers to web app adoption, such as implementing a web app equivalent to smart banners or install prompts in iOS Safari.

# What does being designated Strategic Market Status mean?

On the 25th of April 2024, the UK government passed the Digital Markets, Competition and Consumers Bill (DMCC) bill which aimed to “boost competition in digital markets”.

This bill gave the UK Regulator the Competition and Markets Authority (CMA) the ability to designate a firm as having Strategic Market Status (SMS) in a digital activity linked to the UK. Once a firm has been designated the CMA is able to create a bespoke code of conduct for that company, or apply pro-competition interventions to fix particular issues related to the digital activity.

Importantly, and the CMA stress this in their report, a designation of having Strategic Market Status is not in itself an indication of wrongdoing. It simply means that the company has substantial and entrenched market power and a position of strategic significance.

Only the largest companies can be designated: those with turnover greater than £1 billion in the UK or £25 billion globally, thresholds introduced ‘to make clear that smaller firms will not be in scope’.

On the 23rd January 2025 the CMA started an investigation to decide if either Apple or Google had Strategic Market Status. You can read our response to Apple’s SMS investigation here and our response to the proposed decision here.

Last week, on the 22nd of October 2025, the CMA formally designated both Apple and Google as having Strategic Market Status.

The DMCC is quite different from the EU’s Digital Markets Act (DMA), in that the bill itself does not specifically spell out the obligations, unlike the DMA whose articles explain the obligations in significant detail. This means the CMA has more flexibility in what obligations it can impose and how they will work.

That is, the CMA now has the power to impose separate, tailor-made codes of conduct on each of Apple and Google in order to boost competition in digital markets.

# What obligations might the CMA impose on Apple?

During the SMS investigation, the CMA discussed a number of potential obligations it may impose on Apple and Google in relation to browsers, browser engines and web apps.

They were:

• “A requirement for Apple to provide equivalent access to functionality for browsers using alternative browser engines.”

• “A requirement mandating Apple to provide equivalent WebKit access for all WebKit-based browsers on iOS.”

• “A requirement for Apple in respect of in-app browsing to provide interoperability with bundled engines for in-app browsing and allow sufficient cross-app functionality to enable third-party browsers to provide in-app browsing in native apps.”

• “A requirement for Apple not to enter into agreements with Google where it receives search advertising revenues connected to the use of Chrome on iOS.”

• “A requirement for Apple and Google to make changes to choice architecture for browsers.”

• “A requirement that prevents Google from making payments to OEMs and its licensing of its first-party apps and proprietary APIs conditional upon the prominent display and specific default-settings for Google Chrome on Android devices.”

• “A number of the above requirements would need to be complemented by ensuring Apple: (i) permits browser apps to use alternative browser engines; and (ii) enables browser vendors using alternative browser engines to install and manage progressive web apps.”

According to the CMA these interventions could lead to greater browser and web app competition:

These types of potential interventions could lead to greater competition for developing browser features related to performance, privacy and/or security which support user needs. They could also encourage greater use of web apps as an alternative to native apps accessed through a mobile app store, which could lead to lower development costs and lower barriers to entry and expansion for app developers and greater accessibility of apps by users. CMA - SMS Investigation Request for Comment
(emphasis added)

In their current roadmap, the CMA will begin consulting on the following interventions at these times:

Late 2025

• Requiring Apple to fairly and objectively consider requests from third parties for interoperable access to functionality in its operating systems.

First half of 2026

• Requiring Apple to allow third-party browsers and app developers to use alternative browser engines on iOS and iPadOS.
• Requiring that Apple’s choice architecture in relation to digital wallets and browsers supports active user choice and does not give Apple’s own products and services an advantage over those of third parties.
• The CMA will further work to explore the potential for Progressive Web Apps.

Later

• Requiring Apple to provide third-party browsers using WebKit with access to equivalent functionality as that used by Safari.

Under Consideration

• Action to address the impact on competition arising from the revenue share agreement between Apple and Google.

# The WebKit Restriction

For the last 16 years, Apple has banned browser vendors from porting their own browser engines to iOS. They have done this via App Store Rule 2.5.6:

2.5.6 Apps that browse the web must use the appropriate WebKit framework and WebKit JavaScript.

This is directly referenced in the final decision:

On Apple Mobile Devices, all mobile browsers are required to use Apple’s WebKit browser engine, as specified in Apple’s App Store Review guidelines. Apple therefore does not face competition from rival mobile browser engines within its Mobile Ecosystem. This position will not change unless Apple lifts its prohibition on the use of alternative browser engines within its Mobile Ecosystem. CMA - SMS Investigation into Apple’s Mobile Platform - Final Decision
(emphasis added)

WebKit is the engine that powers Safari and several smaller browsers on Linux and macOS.

In practice, 2.5.6 is a requirement that on iOS, browsers from Google, Microsoft, Mozilla, Samsung, Vivaldi, Brave, Opera and others cannot use their own engines the way they do everywhere else. These engines take hundreds of thousands of engineer hours to develop, and are excluded from Apple’s most successful consumer operating system. Competing browser vendors are only allowed to produce shells around a very specific, unaltered version of Safari’s WebView; a component whose features Apple dictates.

Apple has a browser monopoly on iOS, which is something Microsoft was never able to achieve with IE Scott Gilbertson - The Register
(emphasis added)

All of this is compounded by yet another Apple policy: no third-party browser engines. You can install apps like Chrome, Firefox, Brave, DuckDuckGo, and others on the iPhone — but fundamentally they’re all just skins on top of Apple’s WebKit engine. That means that Apple’s decisions on what web features to support on Safari are final. If Apple were to find a way to be comfortable letting competing web browsers run their own browser engines, a lot of this tension would dissipate. Dieter Bohn and Tom Warren - The Verge
(emphasis added)

So it’s not just one browser that falls behind. It’s all browsers on iOS. The whole web on iOS falls behind. And iOS has become so important that the entire web platform is being held back as a result. Niels Leenheer - HTML5test
(emphasis added)

…because WebKit has literally zero competition on iOS, because Apple doesn’t allow competition, the incentive to make Safari better is much lighter than it could (should) be. Chris Coyier - CSS Tricks
(emphasis added)

What Gruber conveniently failed to mention is that Apple’s banning of third-party browser engines on iOS is repressing innovation in web apps. Richard MacManus - NewsStack
(emphasis added)

No other major operating system imposes such a ban. Microsoft Windows, Android, Linux, and Apple’s own macOS all enable browser vendors to choose and modify their own engines. All rival iOS browsers are essentially Safari under the hood. This browser ban is unique to Apple’s iOS.

Even in the EU, where Apple has been legally obligated to allow browser vendors to use their own engines for over 19 months, no browser vendor has successfully ported a competing engine to iOS because the financial, technical, and contractual barriers Apple has put in place remain insurmountable.

The CMA’s Final Decision finds that Apple’s ban of third party browser engines harms both browser and web app competition on iOS:

# Web Apps can not Effectively Compete on iOS

Somewhat surprisingly, Apple submitted evidence arguing that web apps were an effective competitor to native apps on their app store, despite the significant barriers that Apple has placed in their way, and the fact they attempted to remove the functionality altogether in the EU rather than share it with third-party browsers using their own engines.

While this is an argument that Apple has made repeatedly around the globe, we had believed that given the mounting regulatory push to enable both browsers and web apps to compete fairly on iOS, and the distinct possibility that web apps could actually become a powerful competitor to their app store, that Apple might retreat from this line of argument.

In particular, were browser vendors allowed to use their own engines, allowed to install and manage web apps using those engines and were Apple to implement an equivalent installation mechanism to that they provide to their native apps via Safari (i.e. smart banners or an equivalent to install prompts), the impact on web apps’ viability would be profound.

However the CMA found that web apps are not currently a viable competitor to Apple’s App Store:

This is unsurprising given the extensive issues with developing web apps in iOS Safari, Apple’s ban on third-party browser engines and the lack of equivalent discoverability for web apps in Safari as Apple provides its own app store’s apps.

Worse, these problems on iOS dampen web app viability across the entire mobile ecosystem:

Several content providers further submitted that functionality issues with web apps are due to restrictions that Apple has imposed on web browsers within its Mobile Ecosystem, which carry over to Google’s Mobile Ecosystem due to the platform-agnostic nature of web apps (ie because web developers build their web apps using functionalities available across all major browsers). CMA - SMS Investigation into Google’s Mobile Platform - Final Decision
(emphasis added)

# Barriers to Rival Browsers on iOS

The final decision lays out substantial barriers to third-party browsers competing fairly on iOS.

First, the WebKit restriction that prevents browsers from using their own engine:

We find that the WebKit restriction restricts the ability of rival mobile browsers to innovate and develop features, and increases their costs. It therefore creates a barrier to entry and expansion for rival mobile browsers on Apple’s Mobile Ecosystem and limits the competitive constraint on Safari. CMA - SMS Investigation into Apple’s Mobile Platform - Final Decision
(emphasis added)

Apple has also been found to withhold or delay providing functionalities to rival browsers:

We find that greater and/or more immediate access to certain functionalities on Apple’s Mobile Ecosystem has provided Safari with a competitive advantage relative to third-party mobile browsers, by allowing Safari to implement features that are not available to rival mobile browsers, and therefore limiting the competitive constraint on Safari. CMA - SMS Investigation into Apple’s Mobile Platform - Final Decision
(emphasis added)

The CMA also have found that Apple’s pre-installation and choice architecture dampens third-party browsers’ ability to compete:

…although it is possible for users to switch to an alternative mobile browser to Safari, there are barriers to doing so, given Safari’s position as the pre-installed and default mobile browser on many new Mobile Devices. We find that this, combined with behavioural biases, and general low user awareness and engagement with mobile browsers (see above), provides Safari with a competitive advantage and therefore limits the competitive constraints on it within Apple’s Mobile Ecosystem. CMA - SMS Investigation into Apple’s Mobile Platform - Final Decision
(emphasis added)

Next, the CMA directly criticises the Apple-Google Search Deal (officially called ISA). In particular, a clause where Google also pays Apple a share of revenue for Chrome’s traffic on iOS.

We find that the ISA materially limits Apple’s and Google’s incentives to compete, and this dampens the extent of competition between Apple’s Mobile Ecosystem and Google’s Mobile Ecosystem. CMA - SMS Investigation into Apple’s Mobile Platform - Final Decision
(emphasis added)

Finally, all of these issues combined lead the CMA to conclude that the competitive constraint applied to Safari by third-party browsers on iOS is limited.

Importantly these are all issues that the CMA can directly address in their code of conduct for Apple.

# Apple Claims it has multiple Safaris (Again)

In September 2023, Apple attempted to claim to the EU that it offers not one, but three distinct web browsers all coincidentally named Safari.

Apple made this attempt despite the Digital Markets Act containing specific clauses to address this exact behavior:

Article 13(1): An undertaking providing core platform services shall not segment, divide, subdivide, fragment or split those services through contractual, commercial, technical or any other means in order to circumvent the quantitative thresholds laid down in Article 3(2). No such practice of an undertaking shall prevent the Commission from designating it as a gatekeeper pursuant to Article 3(4). Digital Markets Act

Fortunately, the team at the EC saw through this argument and carefully dismantled Apple’s position.

The EU Commission rejected Apple’s argument noting:

In this UK’s 2025 SMS investigation, Apple once again attempted to claim that Safari on iOS and Safari on iPadOS were distinct separate digital activities.

Both OWA and Mozilla supported the CMA in considering it a single digital activity.

Open Web Advocacy supported the CMA’s proposed reasons for considering Safari to be a single browser, adding that Apple’s own marketing presents Safari in this way. Mozilla, similarly, agreed with the CMA’s proposed position, further noting that the underlying code of browsers across both iOS and iPad OS tends to be almost identical, and that, until recently, Apple had a single submission process across both platforms. CMA - SMS Investigation into Apple’s Mobile Platform - Final Decision
(emphasis added)

The CMA rejected Apple’s arguments and has found that

# Combined Digital Activity: Apple’s Mobile Platform

The DMCC allows the CMA to group digital activities together where they share a common purpose. The CMA has chosen to combine iOS, iPadOS, Apple’s App Store, Safari and WebKit as a single digital activity called “Apple’s Mobile Platform”.

This is important as it allows the CMA to create remedies that cross these overlapping activities and to avoid circumvention. It also allows the CMA to consider whether interlinkages between these may contribute to market power which is relevant to if Apple gets designated with respect to each of these digital activities.

...whether and how any interlinkages between these may contribute to market power across the digital activity; for example, whether the firm’s position in one activity in the group reinforces its position in another.
CMA - SMS Investigation into Apple’s Mobile Platform - Final Decision
(emphasis added)

Apple unsurprisingly disagreed:

The CMA helpfully provided Apple with many of their past statements where they claim the opposite:

The CMA goes on to explain the many ways that Apple devices and services are bound together:

Other responders, including OWA, were broadly supportive of grouping these activities into a single Mobile Platform activity.

# Apple’s Service Revenue Breakdown

The CMA’s report also digs into Apple’s revenue and notes that increasing service revenue and service gross profit is growing in importance. Service revenue was a surprising 40% of gross profit in 2024.

While the majority of Apple’s revenue has historically come from device sales, the contribution and importance of Apple’s services business, which includes App Store and Safari, has been increasing steadily in recent years. Services accounted for almost 25% of revenue in 2024, and almost 40% of gross profits. Apple’s services revenues include the fees earned by Apple from what Apple refers to as Third Party Licensing Arrangements, which is predominantly made up of its share of revenue from Google under the ISA as considered in Chapter 6; and the App Store, which is monetised through commission fees and advertising revenues. CMA - SMS Investigation into Apple’s Mobile Platform - Final Decision
(emphasis added)

This is important as the CMA’s mobile ecosystem market study identified competition in browsers reducing Apple’s Google ad revenue and competition from web apps reducing Apple’s app store revenue as powerful incentives for Apple’s restrictions on third-party browsers and web apps.

Apple receives significant revenue from Google by setting Google Search as the default search engine on Safari, and therefore benefits financially from high usage of Safari. [...] The WebKit restriction may help to entrench this position by limiting the scope for other browsers on iOS to differentiate themselves from Safari [...] As a result, it is less likely that users will choose other browsers over Safari, which in turn secures Apple’s revenues from Google. [...] Apple generates revenue through its App Store, both by charging developers for access to the App Store and by taking a commission for payments made via Apple IAP. Apple therefore benefits from higher usage of native apps on iOS. By requiring all browsers on iOS to use the WebKit browser engine, Apple is able to exert control over the maximum functionality of all browsers on iOS and, as a consequence, hold up the development and use of web apps. This limits the competitive constraint that web apps pose on native apps, which in turn protects and benefits Apple’s App Store revenues. UK CMA - Interim Report into Mobile Ecosystems
(emphasis added)

The CMA in their latest report note that innovations have been held back due to a lack of competition, directly citing Apple’s WebKit Restriction:

This matters as competition is the primary driver of growth and innovation. Companies that, due to anti-competitive behaviour or some structural reason, do not face sufficient competition, are likely to raise prices and minimize expenditure beyond what is necessary to retain existing customers.

The CMA highlight that Apple can and does profitably forego innovation without fear of losing customers to competitors with this quote:

Apple’s vice president of iPhone marketing who explained in February 2020:‘In looking at it with hindsight, I think going forward we need to set a stake in the ground for what features we think are ‘good enough’ for the consumer. I would argue were [sic] already doing *more* than what would have been good enough.’ After identifying old features that ‘would have been good enough today if we hadn’t introduced [updated features] already’, she explained, ‘anything new and especially expensive needs to be rigorously challenged before it’s allowed into the consumer phone.’ CMA - SMS Investigation into Apple’s Mobile Platform - Final Decision
(emphasis added)

# Barriers to Switching

The CMA has found that there are substantial barriers to users switching phone brands.

This is important, and lines up with a common argument about browser engines, which is “switch to Android if you wish to use other browser engines”. This of course misses the point in three important ways:

• Consumers, in general, have low awareness of browsers, browser engines and web functionality, and are unaware how anti-competitive constraints on them are making the apps they use more expensive, of lower quality and of lower security. Even consumers who are acutely aware of Apple’s browser engine ban, face substantial and significant barriers to switching.

• Businesses cannot choose where their customers are, and must support iOS, regardless of any lack of web functionality or browser competition.

• Businesses who may wish to use web apps as a powerful and interoperable means of delivering apps to their customers are constrained from doing so due to a lack of critical features and significant bugs in iOS Safari. iOS Safari faces no effective competition. This constraint can even extend to Android, due to the loss of an effective cross platform interoperable web solution that also works on iOS.

Apple, while not denying the switching costs, argued that this does not imply weak competitive constraint on Apple’s Mobile Platform via alternatives:

Apple submitted that switching costs do not imply weak competitive constraints. The presence of switching costs may in some circumstances benefit customers by intensifying competition for new customers. However, this is much less likely to be the case in mature markets with large established players. In the case of mobile platforms, as already highlighted above, the vast majority of users are buying a replacement device and hence the pool of ‘new’ customers is relatively small compared to the pool of existing customers. Both Apple’s and Google’s strategies will therefore be largely driven by what is profitable in relation to the customers who are already within their mobile ecosystems. [...] CMA - SMS Investigation into Apple’s Mobile Platform - Final Decision
(emphasis added)

Ultimately, and correctly in our opinion, the CMA concludes that: “Apple’s Mobile Platform faces only a limited constraint from other mobile platforms when competing for mobile end-users as a whole.”.

# Other Competition Authorities

The CMA’s decision also notes a number of other competition authorities are looking into Apple’s mobile platform:

The CMA is far from the only authority considering these issues. Several competition authorities globally have taken action in relation to Apple’s Mobile Platform in recent years (including the US Department of Justice (DoJ), European Commission, Japan Fair Trade Commission (JFTC) and Australian Competition and Consumer Commission (ACCC)). Although our SMS investigation is focused on Apple’s activities in the UK, Apple’s Mobile Platform operates globally, and we have sought to learn from international findings in conducting our own investigation. CMA - SMS Investigation into Apple’s Mobile Platform - Final Decision
(emphasis added)

Multiple regulators and government organizations have recommended ending Apple's ban on third-party browsers. This includes the UK, EU, Japan, USA and Australia. Further, multiple new laws have already been passed, including the Digital Markets Act (DMA), and Japan's Smartphone Act which directly prohibits it. Australia and the United States are also considering similar legislation. Finally the U.S. Department of Justice is pursuing an antitrust case against Apple and their complaint directly cites the issue.

We highlighted this in our response to the proposed decision:

# Mobile Ecosystems Study and Market Investigation Reference

The CMA has been investigating Apple’s restrictions on browsers and web apps for 4 years. This started on the 15th June 2021, when the UK’s Competition and Markets Authority (CMA) launched a market study into mobile ecosystems. This study correctly identified that Apple was undermining browser and web app competition via its ban on third-party browser engines.

On the 22nd of November 2022, the CMA announced it had decided to launch a Market Investigation Reference into Mobile Browsers and Cloud Gaming.

Market Investigation References (MIRs) are only started when the CMA has “reasonable grounds for suspecting that a feature or combination of features of a market or markets in the UK prevents, restricts, or distorts competition”. They are a significant and expensive undertaking:

Full market investigation references tend to be used only in cases where competition problems are considered to be particularly significant and/or warrant further detailed investigation, and where the stronger and more wide ranging powers available to the CMA are considered to be more appropriate. Ashurst - Guide to the use of market studies in UK competition law
(emphasis added)

Upon having confirmed the adverse impact on competition, MIRs are intended to fix the issue:

Following a market investigation, the CMA can take remedial action itself through exercising its order - making powers or by accepting undertakings from relevant parties. Alternatively, it can recommend (but not require) that remedial action should be taken by others such as government, regulators and public authorities. Section 134(6) of the EA02 requires the CC [Competition Commission] to take into account the following in considering potential remedial action: "the need to achieve as comprehensive a solution as is reasonable and practicable to the adverse effect on competition and any detrimental effects on customers so far as resulting from the adverse effect on competition". Ashurst - Guide to the use of market studies in UK competition law
(emphasis added)

Their final decision included the following remedies:

The MIR team also explained in extensive detail that they decided that deferring these remedies to be implemented under the DMCC was the fastest and legally safest path forward.

This matters, as it means that the SMS investigation is not happening in a vacuum. The UK government has spent considerable effort investigating Apple on this topic over the past four years. These investigations have consistently identified anti-competitive behaviour by Apple that is suppressing both browser and web app competition on iOS, and now the CMA has the power under this designation to fix the wrongs that both the mobile ecosystem investigation and the mobile browsers and cloud gaming market investigation reference identified.

Fortunately, the SMS investigation team appears to be moving decisively in that direction. They directly included a number of these already identified remedies in their SMS investigation. However, as a competition regulator, the CMA must follow a formal process of consultation before enforcing such remedies. According to the CMA’s roadmap, the consultation covering browsers, browser engines and web apps is expected to begin in the first half of 2026.

# Why the Web should be Allowed to Compete Fairly

Allowing browsers and web apps to compete fairly on all operating systems will bring some significant advantages to consumers and businesses:

• The web could offer a true alternative to today’s mobile app stores as it has on desktop for the last two decades. It is open, interoperable, and free from proprietary fees or a 30% cut for the operating system. This interoperability lowers costs for developers, raises quality, reduces barriers to entry for smaller teams and fuels greater innovation across the industry.

• When developers have real alternatives, app stores must work harder to retain their users and developers. This could lead to lower fees, faster reviews, fairer terms and better overall service for both developers and consumers.

• Competition would push Safari to improve its stability, compatibility, and features. With multiple browsers able to compete freely with their own engines, users benefit from faster innovation, higher quality, better security and higher stability. Currently Safari faces no effective competition on iOS.

• Lowering the barriers to web-based apps could finally make it viable for a third mobile operating system to emerge, breaking the current duopoly.

When the web thrives, everyone benefits. Regulators have the power to make this a reality, but they need strong evidence and support from developers and companies that depend on the web.

Stay tuned for updates on the CMA’s upcoming investigation into browsers and web apps, starting in the first half of next year. We’ll share more details as they become available.