Sarah Cardell, CEO of the Competition and Markets Authority

A porter taps in to a pharmacy store room. An outpatient pays for a hospital car park with a phone held against a reader. A locum shows a digital pass at a ward entrance. Each of these actions could run through the device in the pocket. On the iPhone, the tap itself has been governed by a single company, on terms that some British developers say make building anything worthwhile commercially unworkable.

The Competition and Markets Authority has moved to change that. Its proposals, open for consultation until 17 November, would cut access fees, remove technical barriers and give developers additional technical routes into Apple's contactless technology. The regulator said UK businesses had told it the existing arrangements could be unviable, with fees and contractual terms making it hard for rivals to build and scale services. Chief executive Sarah Cardell has said the changes would address the barriers holding competitors back. It is a measured, evidence-led intervention, and a welcome one.

The scale of the dependency explains the urgency. Contactless now accounts for 39 per cent of UK payments, against 3 per cent a decade ago. It also carries transport journeys, building access and stored digital credentials. Technology that plays such a central role in daily life has become essential infrastructure, and infrastructure works best when access is open and affordable.

The relevance to health is indirect, and it deserves to be stated plainly. Nothing in the proposals concerns clinical care. The link lies in the direction of NHS digital policy. The NHS App has become the main route for repeat prescriptions, appointment management and record access, and ministers want it to carry far more of the relationship between patient and service. The government has also pursued phone-based digital identity. Both ambitions rest on the assumption that the smartphone wallet is where trusted credentials will live. On the iPhone, who is allowed to build for that wallet, and at what price, shapes what the NHS can deploy.

The practical effect falls on suppliers. Small health-tech firms building staff identity, patient check-in or secure access products for trusts operate on tight margins and fixed-price framework contracts. A fee structure that suits a high-volume retail payment can sink a product sold to a hospital trust. Lower fees and more technical routes change that arithmetic, and may widen the field of British companies able to bid. That matters to an NHS that wants a more competitive supplier market and has little appetite for dependence on a handful of large vendors.

NHS digital leaders and integrated care boards have a role here. The consultation exists to gather evidence, and public sector use cases are exactly the kind that regulators rarely see in volume. Trusts that have tried and abandoned wallet-based projects because of access costs hold information the CMA would find useful. Silence from the health sector would leave the debate to banks and retailers.

There are caveats that a serious reading must carry. Apple has defended tight control of its hardware on security grounds, and healthcare raises the stakes on privacy and data protection. Opening access must come with standards that satisfy NHS information governance, and the consultation is the right place to test them. Digital exclusion also remains real. Millions of patients and staff do not use a smartphone, or do not use an iPhone, so no wallet credential can replace its physical equivalent for years.

For policymakers the episode carries a wider lesson about state capacity. A regulator that identifies a specific bottleneck in a digital market, consults openly and proposes proportionate remedies is doing what the government says it wants from public bodies: acting quickly, with evidence, in service of growth. That credibility is an asset when the same government asks the public to trust digital services with their health records and identities.

The proposals open one lock on one phone, and the NHS will not feel the effect next quarter. They do establish that access to the hardware citizens carry should be available on terms a small British developer can afford. Health is among the sectors with most to gain if that principle holds.

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