€500 Million, April 2025

The Infringement Finding

The Commission's decision targeted Apple's compliance with Article 5(4) of the Digital Markets Act, the provision that prohibits gatekeepers from restricting developers' ability to communicate freely with their own users — directing them to deals, subscriptions or downloads available elsewhere on the web. Apple had been formally designated a gatekeeper in respect of the App Store in September 2023. From 7 March 2024, when the DMA's obligations became enforceable, the Commission expected Apple's anti-steering rules to have changed materially. They had not changed enough.

Investigators found that Apple's updated link-out entitlement — the mechanism it offered developers who wished to point users to external purchase options — remained subject to conditions that the Commission determined were not compliant. Apple required developers to apply separately for the entitlement, imposed restrictions on the wording and placement of outbound links, and retained the ability to review and reject the format of communications to users. The Commission concluded that these conditions, taken together, preserved the economic effect of the old anti-steering prohibition and denied developers the genuine freedom the regulation requires.

The decision also noted Apple's Core Technology Fee as part of the broader commercial context, though the €500 million fine was levied solely on the steering infringement, not on the fee itself.

The Basis for the Number

Under the DMA, the Commission may impose fines of up to 10 percent of a company's total worldwide annual turnover for a first violation. Apple's annual revenue reported for fiscal year 2024 was approximately $391 billion; the €500 million penalty therefore represents roughly 1 percent of that ceiling (and about 0.13 percent of Apple's turnover).

The Commission's published non-compliance decision ↗ cited the duration of the infringement — running from the March 2024 enforcement date through the point of decision — alongside the gravity of the conduct and the need for deterrence as the factors shaping the quantum. It also noted that Apple had not taken adequate steps to remedy the breach after the Commission's preliminary findings were communicated, a circumstance that weighed against any reduction. Margrethe Vestager, who had driven the original DMA negotiations as Executive Vice President for A Europe Fit for the Digital Age, had departed the Commission by the time the decision landed; the penalty was issued under the competition portfolio.

Apple was given a deadline of 60 days from the decision date to bring its steering practices into full compliance or face additional periodic penalty payments.

Apple's Response

Apple stated publicly that it disagreed with the Commission's findings and intended to appeal. The company maintained that its link-out entitlement did allow developers to communicate with users about external offers, and that the restrictions it retained were justified by user safety and the integrity of the App Store experience. Apple did not dispute the factual timeline but characterised the Commission's interpretation of Article 5(4) as exceeding what the regulation requires.

An appeal to the General Court of the European Union in Luxembourg would not automatically suspend the fine, though Apple could seek interim relief separately. Given the typical pace of EU court proceedings, a final appellate ruling would not be expected for several years.

What It Signals

The size of the penalty is notable less for what it costs Apple — a company holding hundreds of billions in cash and short-term investments — than for what it establishes procedurally. This is the first time the Commission has moved from designation through investigation to a quantified DMA penalty, completing the enforcement arc the regulation set out to create. Other parallel investigations into Apple's DMA compliance remained open at the time of the decision, as did proceedings concerning Apple's interoperability obligations under Article 6.

For developers, the practical question is whether Apple's next revision to its link-out rules will satisfy the Commission before a second penalty cycle begins. For other designated gatekeepers watching from Mountain View, Menlo Park and Seattle, the April decision answers one question that had remained open since the DMA took effect: yes, the Commission will fine.