In late 2025, the UK Competition and Markets Authority (CMA) used its new powers under the Digital Markets, Competition and Consumers Act 2024 (DMCC) to designate both Apple and Google as holding Strategic Market Status (SMS) in mobile ecosystems. The decision — the first SMS designations of their kind in Britain — opens the door to bespoke conduct requirements covering app store commissions, sideloading restrictions, browser engine rules, and the terms on which third-party developers reach UK consumers.
The designations are not, in themselves, findings of wrongdoing. They are a regulatory gating mechanism: only firms with substantial and entrenched market power and a position of strategic significance in a given digital activity can be made subject to the CMA's new conduct requirements and pro-competition interventions. Mobile operating systems, native app distribution, and mobile browsers are the three activities on which the CMA has now established jurisdiction over both companies.
How the UK Got Here
The DMCC Act, which received Royal Assent in May 2024 and whose digital markets regime came into force in January 2025, was the culmination of nearly five years of policy work that began with the Furman Review in 2019 and the creation of the CMA's Digital Markets Unit in shadow form in 2021. The CMA had already conducted a deep mobile ecosystems market study in 2021–22, concluding that Apple and Google operated an effective duopoly across operating systems, app stores, and browser engines.
That earlier work meant the SMS investigations launched in January 2025 had a head start. The CMA opened parallel probes into both companies on the same day and ran them in lockstep. Their conclusion — that both firms hold entrenched power over mobile ecosystems in the UK — surprised no one, though the precise conduct requirements that follow will matter far more than the labels.
The Pro-Innovation Reading
From a pro-innovation perspective, the UK regime has three features worth defending — and a few worth watching.
First, the SMS framework is participative. Unlike the EU's Digital Markets Act, which imposes a rigid list of dos and don'ts on designated gatekeepers, the DMCC requires the CMA to consult on tailored conduct requirements activity by activity. That should, in principle, produce rules that match the actual competition problem rather than a one-size-fits-all template. The Act also includes a countervailing benefits exemption allowing firms to argue that a contested practice produces benefits — for users, for security, for innovation — that outweigh the competition harm.
Second, the regime is iterative. SMS designations last five years and conduct requirements can be revisited. That matters in a sector where the underlying technology, business models, and threat landscape change every couple of years. Static, treaty-like rules age badly; a rolling supervisory regime, properly resourced, has a better chance of staying useful.
Third, the CMA must consider investment incentives, innovation, and consumer welfare — not just market share — when setting requirements. This is a meaningful improvement over earlier drafts of the Bill and reflects sustained pressure from industry, academics, and free-market commentators during pre-legislative scrutiny.
Where Proportionality Will Be Tested
The hardest calls are still ahead. Three areas in particular deserve careful regulatory humility:
- Sideloading and alternative app stores. Forcing Apple to permit installation of apps outside the App Store unlocks competition — but the European experience under the DMA shows that it also creates new vectors for malware, scam apps, and pirated content. The CMA's conduct requirements should preserve meaningful security review, even if the reviewer is no longer Apple.
- Browser engines. Apple's WebKit-only rule on iOS has plausibly held back web app innovation in the UK for a decade. Allowing Chromium and Gecko on iOS is the correct call. But the transition should be designed so that users retain a clear default and can understand which engine is rendering their pages.
- App store commissions. A blunt cap on the 15–30% commission risks undercutting the cross-subsidy that funds developer tools, payment infrastructure, and fraud prevention. A better path is to require steering — letting developers point users to alternative payment or subscription pages — and to let competition do the price discovery.
The Global Context
Britain now becomes the third major jurisdiction, after the European Union and Japan, to impose bespoke rules on mobile gatekeepers. South Korea and India are watching closely; the United States, post-Epic v. Google, is moving through the courts rather than through legislation. The risk of fragmentation is real, and UK firms — particularly smaller publishers and fintechs — will benefit if the CMA aligns its requirements with the EU's DMA wherever it sensibly can. Where it diverges, it should explain why.
Our Take
Designating Apple and Google as having Strategic Market Status is, by itself, an unremarkable step — the evidence has been on the table since the 2022 market study. The harder, more consequential work is now beginning: drafting conduct requirements that genuinely open mobile ecosystems to competition without dismantling the security, privacy, and developer experience that made smartphones successful in the first place. If the CMA pulls that off, the UK will have built a regime worth exporting. If it does not, it will have added one more layer to an already-fragmented global rulebook for the same handful of products.