As part of recent key developments in the Epic v. Apple Case we would like to bring to your attention an important update that may impact how you manage in-app purchases, allowing flexibility in guiding users to external payment methods within iOS apps.
A SHORT RECAP [SEPTEMBER 2021]
The legal dispute between Epic Games and Apple began when Epic added a direct payment option within Fortnite, circumventing Apple’s in-app purchase system and avoiding the 30% commission typically charged. In response, Apple removed Fortnite from the App Store. Epic subsequently filed suit, alleging that Apple’s conduct was anticompetitive and monopolistic.
In a nuanced ruling, U.S. District Judge Yvonne Gonzalez Rogers found that:
- Apple is not a “monopoly” under federal or state antitrust law. While Apple holds significant market share in mobile gaming, it does not exert monopolistic control over the broader digital or smartphone markets.
- Apple’s anti-steering provisions—which prevented developers from directing users to external payment methods—violated California’s Unfair Competition Law.
As a result, the court issued a nationwide permanent injunction, requiring Apple to:
- Allow developers to include links, buttons, or other calls to action within their apps that lead users to alternative payment mechanisms.
- Permit developers to communicate freely with users about non-App Store payment options.
Both parties appealed parts of the ruling.
RECENT DEVELOPMENT [APRIL 30, 2025]
On April 30, 2025, Judge Gonzalez Rogers ruled that Apple was in willful violation of the 2021 injunction. Specifically, Apple had:
- Imposed a 27% commission on external purchases;
- Restricted how developers could communicate alternative payment options; and
- Created conditions that continued to impede fair competition.
The court rejected Apple’s post-ruling policy changes as noncompliant and stated that the company had manufactured “post hoc justifications” to sustain an anticompetitive revenue stream. Judge Gonzalez Rogers warned: “This Court will not play ‘whack-a-mole,’ nor will it tolerate further delay.”
As art of the permanent injunction expansion, the court restricts Apple from:
- Imposing any commission or any fee on purchases that consumers makes through external means, and as a consequence thereof, no reason exists to audit, monitor, track or require developers to report purchases or any other activity that consumers make externally;
- Restricting or conditioning developers’ style, language, formatting, quantity, flow or placement of links for purchases outside an app;
- Prohibiting or limiting the use of buttons or other calls to action, or otherwise conditioning the content, style, language, formatting, flow or placement of these devices for purchases within an app;
- Excluding certain categories of apps and developers from obtaining link access;
- Interfering with consumers’ choice to proceed in or out of an app by using anything other than a neutral message apprising users that they are going to a third-party site;
APPLE DEVELOPER GUIDELINES UPDATE
To comply with the court order, Apple updated its Developer Program Guidelines as follows:
- 3.1.1(a) Link to Other Purchase Methods: Developers may apply for entitlements to provide a link in their app to a website the developer owns or maintains responsibility for in order to purchase digital content or services. These entitlements are not required for developers to include buttons, external links, or other calls to action in their United States storefront apps. Please see additional details below.
- 3.1.3 Other Purchase Methods: The following apps may use purchase methods other than in-app purchase. Apps in this section cannot, within the app, encourage users to use a purchasing method other than in-app purchase, except for apps on the United States storefront and as set forth in 3.1.1(a) and 3.1.3(a). Developers can send communications outside of the app to their user base about purchasing methods other than in-app purchase.
The revised guidelines permit app developers to direct users from the app to external sources to conduct in app purchases.
WHAT THIS MEANS FOR YOU
As of April 30, 2025, developers targeting U.S. users may:
- Direct users to conduct purchases via the web, outside Apple’s payment system.
- Do so using buttons, hyperlinks, or any calls to action—without paying Apple’s 30% commission.
- Freely choose the language, design, and placement of these external payment links in their apps.
This marks a significant shift in App Store policy and opens the door for greater flexibility and reduced fees for developers operating in the U.S.
