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Bundeskartellamt Evaluates Apple's App Tracking Transparency Framework Proposals

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Photo: Photo by Yue Iris on Unsplash

The German competition authority, Bundeskartellamt, is testing Apple's proposed changes to its App Tracking Transparency Framework in response to competitive concerns raised in February 2025.

02.12.2025 | German competition authority


The Bundeskartellamt has initiated a market test for the solutions proposed by Apple regarding its App Tracking Transparency Framework (ATTF). This action follows significant competitive concerns expressed in February 2025 about the current design of the system.

Andreas Mundt, President of the Bundeskartellamt, emphasized the importance of transparency and fairness in how apps access user data. He noted that Apple's ATTF establishes critical rules that impact competition across the ecosystem, and there is a fundamental need for changes to ensure that these rules are equitable for all parties involved.

Apps, both from Apple and third-party developers, require user consent to access valuable data for advertising purposes. The ATTF dictates how this consent is obtained on devices like the iPhone. However, Apple has been criticized for providing different consent prompts for its own apps compared to third-party apps, which may lead to biased user consent outcomes.

The Bundeskartellamt's preliminary assessment indicated that Apple's current design of consent windows favors its own services, potentially disadvantaging third-party developers who rely on data-driven advertising to sustain their business models.

Apple's recent proposals aim to address these competitive issues and will be evaluated through a market test involving app developers, media and advertising associations, and data protection authorities. The results will inform the Bundeskartellamt's further legal assessment of the situation.

Key changes proposed by Apple include neutralizing the design of consent prompts and simplifying the consent architecture for third-party apps. However, Apple has not proposed changes regarding the measurement of advertising success, which the Bundeskartellamt will also scrutinize during the market test.

The proceedings are being conducted under both national and European law, with close coordination with other national competition authorities and the European Commission throughout the process.

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