On 20 October 2026 the Competition and Markets Authority published a consultation on a proposed conduct requirement that would make Apple give third-party developers access to the iPhone's NFC chip "on fair, reasonable, transparent and non-discriminatory terms". The consultation closes at 11:59pm on 17 November 2026. It is the first concrete test of whether the UK's digital markets regime can reduce a platform's control over a specific function without hurting the product around it.
The case for intervening
The regulator's case deserves a fair statement. Apple has strategic market status in mobile platforms. The CMA confirmed this on 22 October 2025, finding that UK users tend to stay on either Apple or Android and that businesses must serve both to reach customers. Apple controls the NFC chip on its own devices. A bank or fintech that wants to offer tap-to-pay inside its own app cannot do so without first agreeing terms with the company whose wallet it competes against.
The CMA's June 2026 release said businesses had raised concerns that "Apple's high fees and strict terms" were preventing access to NFC functionality. A LexisNexis summary of the October consultation says the CMA considers that Apple's current fees and access conditions create barriers to entry and expansion. If that is right, the harm is not abstract. A gatekeeper is deciding who may compete in contactless payments, and it sets the price of that competition.
The Paypers, citing the Financial Times, reports that Apple opened an NFC system in 2024 in several countries, including the UK. Companies using it must sign commercial agreements, comply with Apple's security and privacy rules, and pay "associated fees". The same report mentions a 0.15% fee that Apple takes on Apple Pay card transactions, which banks and fintechs have objected to. That figure is a secondhand press report, not a CMA finding, and the consultation's own fee analysis should be read before anyone relies on it.
Why the design matters more than the principle
The proposal is better than the blunt interventions we have criticised elsewhere, for three reasons.
- It targets one function. The requirement concerns NFC access, not Apple's whole business model. That fits the regime's stated purpose of "proportionate, targeted interventions". The designation itself is, in the CMA's words, "not a finding of wrongdoing".
- It is built on evidence the CMA has already gathered. On 30 June 2026 the CMA asked developers about two design questions: the technical method by which NFC access should be provided, and the price charged for it. The October proposal follows that call for evidence, which closed on 21 July 2026.
- It does not demand free access. The CMA says it aims to promote competition "while protecting Apple's incentives to invest". It also expects access fees to be "substantially lower than Apple's current charges", not zero. That is the right distinction. Apple built the secure hardware and the ecosystem, and a cost-reflective charge is defensible. A charge that functions as a toll on rivals is not.
The security objection is serious but not decisive
Apple's strongest argument is security. According to The Paypers, Apple has argued that restricting NFC access to its own wallet protects user security and helps combat fraud. Payments are a high-value target, and a badly designed access regime could expose users to malicious apps. A regulator that waves this away would deserve criticism.
But the objection supports a requirement with well-specified safeguards. It does not support a ban. The strongest version of the conduct requirement would let Apple impose objective, published security standards applied equally to its own wallet and to rivals, with a clear process for approving developers. "Non-discriminatory" is the operative word. If Apple's own wallet is held to the same rules as everyone else's, the security argument loses its force as a reason for exclusion. If it is not, the argument looks like a competitive defence dressed as a safety one.
The cost of getting this wrong runs both ways. If the standards are too lax, fraud losses fall on consumers. If they are too strict or too vague, Apple retains a discretionary veto and the requirement achieves little.
What the consultation should settle
The consultation document runs to 147 pages, and we have not been able to review its full text. The questions that matter most are these.
- How fees are benchmarked. "Substantially lower" needs an anchor, such as a published cost-based methodology that Apple and developers can both test. Without one, the same dispute reappears at the compliance stage.
- How security is verified. Standards should be objective, public and applied to Apple's own services. Any exception for Apple's wallet should need justification.
- How the review works. The regime should measure outcomes after implementation: wallet entrants, fraud rates and consumer uptake. If the evidence shows no benefit, the rule should be revised.
Apple is reportedly likely to challenge the outcome in court, according to the Paypers' sources. That is its right, and a well-evidenced decision will survive it. A poorly reasoned one will not, which is a good reason for the CMA to publish its working.
A pro-innovation reading
The app economy supports, in the CMA's figures, around 400,000 UK jobs and 1.5% of GDP. Contactless payments, digital identity and digital car keys all depend on a chip that one company controls. Opening that chip on cost-based, security-neutral terms would let fintechs compete on product, which is what an innovation policy should do. Regulation that stays this narrow, is tied to a defined harm and commits to measuring results is the kind that markets can live with.
The risk is drift. If the final requirement becomes a vehicle for price-setting beyond what the evidence supports, or if security terms are left vague, it will deliver neither competition nor safety. Respondents have until 17 November to press for specifics, and they should.