The UK's Competition and Markets Authority (CMA) has opted for a regulatory strategy distinct from the EU's prescriptive Digital Markets Act (DMA), choosing not to impose stringent, "ex ante" rules on tech giants Apple and Google. Instead, the CMA has accepted legally binding, voluntary commitments from both companies. This approach prioritises negotiated undertakings over legislative mandates to ensure fair treatment for app developers and consumers, marking a unique path for UK digital regulation.

Commitments Over Mandates

The decision, announced in early 2026, stems from a desire to secure tangible benefits more swiftly and with fewer unintended consequences than a full DMA-style regime. The CMA has secured specific, enforceable undertakings focused on increasing transparency and fairness, including clarifying app store fees, improving dispute-resolution mechanisms, and ensuring equitable access to software tools and APIs. a spokesperson for the CMA stated that this "commitments approach" is designed to balance protecting competition with enabling thriving digital ecosystems. The regulator will monitor compliance closely and retains the power to impose further remedies, including fines, if the undertakings are breached.

A Contrast with the EU's DMA

This principles-based, flexible approach contrasts sharply with the EU's DMA, which mandates detailed obligations for "gatekeepers," such as forcing the allowance of third-party app stores and sideloading. The CMA's strategy aligns with the UK government's Innovation Strategy, advocating for proportional and adaptive regulation, particularly relevant to dynamic sectors like health and medical technology. However, some experts caution that this lighter touch may not fully address the fundamental structural issues of platform dominance, risking a lag behind the EU's globally benchmarked regulation.

Mixed Industry Reactions

Industry reactions have been mixed. While smaller app developers appreciate the push for more transparent processes and clearer fee structures, critics argue that the lack of strong regulatory teeth, such as forced sideloading, means the commitments may only lead to cosmetic changes. App developer groups warn that voluntary commitments might be insufficient to address deep-rooted imbalances in the mobile ecosystem and have pledged to closely monitor the CMA's enforcement efforts.

Implications for UK Health Technology

The CMA's decision has significant implications for the UK's burgeoning health technology sector, where digital health tools and telehealth platforms rely heavily on mobile app stores for distribution. While the new undertakings aim to improve transparency around fees and policies, core issues like the dominance of native app distribution channels and platform billing requirements remain. Furthermore, the CMA's approach does not directly address critical issues of interoperability and data access, which are crucial for healthcare technology.

Ultimately, the CMA's commitments-first model provides an alternative to the more interventionist measures seen in the EU and the United States. The central question remains whether this collaborative and agile framework can deliver meaningful change. For digital health innovators, policymakers, and patients, the success of the CMA's approach will determine whether mobile platforms support or constrain the next generation of UK health technology services.

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