EU DMA Guide: Alternative iOS App Distribution
The Digital Markets Act changed everything for iOS in Europe. For the first time, you can distribute iOS apps outside the App Store. But should you? Here's everything you need to know.
🇪🇺 EU-Only Regulation
Alternative app distribution is only available in the European Union. Users must have an Apple ID registered to an EU country and be physically located in the EU. This guide covers iOS 17.4+ and iPadOS 18+ requirements as of 2026.
What is the Digital Markets Act?
The Digital Markets Act (DMA) is EU legislation that designates Apple as a "gatekeeper" and requires them to open iOS to competition. Starting March 2024, Apple was required to allow:
Alternative Marketplaces
Third-party app stores can distribute iOS apps in the EU
Web Distribution
Developers can distribute apps directly from their websites
Alternative Payments
Apps can use third-party payment processors and link to external purchases
⚠️ This Isn't Free Distribution
Alternative distribution doesn't mean "no rules." All iOS apps distributed in the EU—including through alternative marketplaces—must still be notarized by Apple for security. Apple also charges a Core Technology Fee for high-volume apps, regardless of distribution method.
Your Distribution Options in the EU
As a developer, you now have multiple ways to distribute your iOS app to EU users:
Option 1: App Store (Traditional)
Recommended for MostContinue using the App Store as you always have. No changes required.
Pros:
- • Existing infrastructure
- • Built-in discovery
- • User trust
- • No Core Technology Fee for <1M installs
Cons:
- • 15-30% commission
- • App Review required
- • Apple's guidelines
Option 2: Alternative Marketplace
For Specific Use CasesDistribute through third-party app stores like Epic Games Store, AltStore, etc.
Pros:
- • Potentially lower commission
- • More flexible guidelines
- • Alternative payment options
Cons:
- • €0.50 Core Technology Fee per install (1M+)
- • Limited user reach
- • User friction to install marketplace
Option 3: Web Distribution
For Large DevelopersDistribute your app directly from your website to EU users.
Pros:
- • Complete control over distribution
- • No marketplace commission
- • Direct relationship with users
Cons:
- • Requires 1M+ EU annual installs to qualify
- • €0.50 Core Technology Fee applies
- • Must handle all user support
Alternative Marketplace Requirements
If you want to distribute through an alternative marketplace, or operate one yourself, here are the requirements:
For Apps Distributed via Alternative Marketplace
-
Notarization Required
All apps must be notarized by Apple for security scanning (not full App Review)
-
Apple Developer Program Membership
Standard €99/year membership required
-
Alternative Terms Addendum
Must agree to Apple's alternative terms for EU distribution
-
Core Technology Fee May Apply
€0.50 per first annual install above 1 million threshold
For Operating an Alternative Marketplace
-
€1M
€1,000,000 Letter of Credit
Must provide standby letter of credit from A-rated financial institution, OR have 2+ years good standing with 1M+ EU installs
-
EU
EU Legal Entity Required
Must be incorporated, domiciled, or registered in the EU with a subsidiary legal entity
-
Content Moderation Obligations
Ongoing monitoring for fraudulent/malicious apps, IP dispute handling, takedown processes
-
Full Responsibility for Payments
Handle all payment processing, refunds, disputes, and tax collection yourself
Notarization vs App Review
Even with alternative distribution, Apple still "notarizes" every iOS app. But notarization is very different from App Review:
| Aspect | App Review (App Store) | Notarization (Alternative) |
|---|---|---|
| Purpose | Content guidelines + Security | Security only |
| What's Checked | Full guidelines compliance, UI/UX, content quality | Malware, platform integrity, basic security |
| Typical Time | 24-48 hours (sometimes longer) | Usually faster (automated scanning) |
| Can Reject For | Any guideline violation | Only malware/security issues, EU platform rules |
| Human Review | Yes, manual review | Primarily automated |
✅ What Notarization Won't Block
- • Apps that compete with Apple services
- • Apps with alternative payment processing
- • Apps that Apple's App Review might consider "minimum functionality"
- • Content that violates Apple's content guidelines (but not EU law)
Core Technology Fee Explained
The Core Technology Fee (CTF) is Apple's most controversial DMA response. Here's exactly how it works:
€0.50
per first annual install
1M
free installs threshold
How It's Calculated
- • Counts first annual installs in the EU (not total downloads)
- • "First annual" = first time a user installs in a 12-month period
- • Reinstalls by the same user in same year don't count again
- • Updates don't count as new installs
- • First 1,000,000 installs per year are free
- • After 1M: €0.50 × (installs - 1,000,000)
Example: 5M EU Installs
5,000,000 - 1,000,000 = 4,000,000
4,000,000 × €0.50 = €2,000,000/year
Example: 500K EU Installs
500,000 < 1,000,000 threshold
€0 Core Technology Fee
⚠️ CTF Applies to ALL Distribution Methods
If you agree to Apple's alternative terms for the EU, the Core Technology Fee applies whether you distribute via the App Store, alternative marketplace, OR web distribution. The only way to avoid it is to stay on the original App Store terms (no alternative distribution).
Who's Exempt from CTF?
- • Nonprofits - Must be registered nonprofit organization
- • Educational institutions - Accredited schools and universities
- • Government entities - EU-based government organizations
- • Developers under 1M installs - Below threshold, no fee
Note: Fee-waiver developers can only distribute apps from other fee-waiver developers.
Should You Use Alternative Distribution?
For most developers, the answer is no. Here's a framework to help you decide:
Stay on App Store If:
- ✓ You have fewer than 1 million EU users per year
- ✓ Your app already passes App Review without issues
- ✓ You benefit from App Store discovery and trust
- ✓ You don't want to handle payment processing yourself
- ✓ You're a Small Business Program member (15% commission)
Consider Alternative Distribution If:
- → Your app has been rejected by App Review for content/guideline reasons
- → You're a large company (1M+ installs) with high revenue per user to offset CTF
- → You want to offer alternative payment options that save more than 30% commission
- → You're building a game with your own launcher/store (like Epic)
- → Your app serves a niche that benefits from marketplace curation (e.g., retro games)
🚨 The Math Often Doesn't Work
Let's say you have 2 million EU installs and earn €2 per user in revenue:
- • App Store: €4M revenue × 30% = €1.2M to Apple, you keep €2.8M
- • Alternative: €4M revenue + (1M × €0.50 CTF) = €0.5M to Apple, you keep €3.5M
In this case, alternative saves €700K. But if revenue per user is lower, the CTF can cost MORE than the 30% commission. Do the math for your specific case.
Frequently Asked Questions
Can I distribute the same app on App Store AND alternative marketplaces?
Yes, but once you agree to the alternative terms, the Core Technology Fee applies to ALL your EU installs across all distribution methods. You can't cherry-pick App Store for some users and alternative for others without the CTF applying to both.
What happens if a user travels from EU to another country?
Apps installed via alternative distribution continue to work. However, users can only install NEW apps from alternative marketplaces while physically in the EU with an EU Apple ID. Existing apps remain functional globally.
Is the €1M letter of credit really required?
Only if you want to OPERATE an alternative marketplace. If you just want to distribute your apps through someone else's marketplace (like Epic Games Store), you don't need the letter of credit—only standard developer program membership and notarization.
Does Japan have similar alternative distribution?
Yes, Japan is implementing similar requirements following their competition laws. As of late 2025, Apple has added Japan-specific terms. The implementation is similar to EU but with Japan-specific legal requirements. Check Apple's Japan developer portal for current details.
Can I avoid App Review entirely with alternative distribution?
You avoid Apple's content-based App Review, but you still need notarization (security scanning) and must comply with EU platform integrity rules. You'll also need to comply with the marketplace's own rules if distributing through a third-party store.
Related Guides
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