Apple has agreed to make substantial changes to its App Tracking Transparency feature in Germany, concluding a three-year antitrust investigation by the country’s Federal Cartel Office (Bundeskartellamt). The settlement, announced Monday, requires Apple to remove “possibly discouraging symbols and wording” from consent prompts and align the design of requests for Apple’s own services much more closely with those shown to users for third-party apps.
The core complaint centered on a double standard that since iOS 14.5 launched in April 2021, Apple has required third-party apps to ask permission before tracking users across other apps and websites for personalized advertising. Apple’s own services, however, have not been subject to the same restrictions, allowing the company to access user data for its own ad targeting while making it “far more difficult” for developers to do the same. In February 2025, German regulators issued a preliminary finding that Apple abused its market power through this differential treatment.
Under the binding commitments, Apple must implement several specific changes. The consent prompts for both Apple’s offerings and third-party apps will be “neutral in terms of content, wording and layout.” Apps will also receive “more scope to explain to users what significance personalized advertising has for their offering and their business model,” and developers will have “freedom to combine the consent request required by Apple with the consent requests required under data protection law.” Apple has four months from formal notice to implement the changes, and the terms will remain binding for seven years.
A Settlement That Falls Short for the Advertising Industry
Despite the regulatory victory, the advertising industry has rejected the settlement as insufficient. Bernd Nauen, chief executive of the German Advertising Federation, said in a joint letter that the “proposed commitments would not change the negative effects of the App Tracking Transparency Framework.” Publishers and media groups had pushed hard for full data parity with Apple’s own services, arguing that even neutral prompts still disadvantage third-party developers.
Apple framed the agreement differently, the company stated: “At Apple, we believe privacy is a fundamental human right, and we introduced App Tracking Transparency to give users a simple way to control whether apps have permission to track their activity across other companies’ apps and websites. While we believe the current ATT prompt provides a clear, easy-to-understand and effective way to keep users in control of their data, we have agreed to make changes to the text and formatting of the prompt at the FCO’s request.” Andreas Mundt, head of the Bundeskartellamt, emphasized that Apple had agreed to introduce neutral consent prompts for both its own services and third-party apps.
Germany Sets a European Precedent as Fines Mount
The German settlement signals an inflection point in Apple’s broader battle over App Tracking Transparency across Europe. France’s Competition Authority has already fined Apple €150 million ($162 million) over the implementation of ATT, while Italy’s Competition Authority imposed a €98.6 million ($116 million) fine. This German resolution may establish a template for how other EU regulators approach the same issue.
Earlier this year, Apple suggested it might withdraw ATT from the EU entirely rather than face continued pressure. The company stated that “intense lobbying efforts in Germany, Italy and other countries in Europe may force us to withdraw this feature to the detriment of European consumers.” That threat did not materialize. Instead, Apple has accepted a four-month implementation window and seven-year compliance period, effectively resolving the investigation without dismantling the feature itself.
The answer will likely emerge over the next few months as Apple tests its revised prompts with developers and prepares for deployment across Germany and potentially the wider EU.
