Germany: Federal Cartel Office conducts market test of commitments proposed by Apple concerning its App Tracking Transparency Framework investigation

On 2 December 2025, Germany's Federal Cartel Office (FCO) announced a market test of commitments proposed by Apple concerning its App Tracking Transparency Framework (ATTF). The proposals address competition concerns raised in the FCO's preliminary assessment of February 2025. That assessment found that the ATTF imposes stricter data-access rules on third-party apps, while Apple's own apps operate under different consent prompts. These differences, in wording, design, choice architecture, and required steps, were found to encourage consent for Apple's services, potentially advantaging its advertising activities. Apple now commits to revising both prompts to ensure neutral design, aligned content and visuals, a simplified choice architecture for third-party apps, and clearer explanations of subsequent data use. The market test will involve industry stakeholders and data protection authorities to examine if these changes resolve the concerns, including Apple's practice of attribution without explicit consent. The investigation is being conducted under Section 19a of the German Competition Act (GWB) and Article 102 of the Treaty on the Functioning of the European Union (TFEU), in coordination with the European Commission and the European Competition Network.