Apple becomes a debt collector with its new developer agreement

In a significant update to its developer license agreement, Apple has announced that it will now have the authority to recover unpaid amounts, such as commissions and fees, by directly deducting them from in-app purchases processed on behalf of developers. This change is poised to impact developers operating in jurisdictions where local laws permit linking to external payment systems. Developers in these regions will be required to report any external payments back to Apple to ensure compliance with the commission structure. The adjustment appears to provide Apple with a mechanism to collect fees it deems owed if a developer reports lower earnings than expected. This complex policy shift could have ramifications for developers across the EU, US, and Japan, especially as the legal landscape surrounding these commissions continues to evolve. Recently, a federal appeals court in the US indicated that Apple could be allowed to collect certain commissions, although not the full 27% it previously enforced. According to the revised agreement, Apple reserves the right to "offset or recoup" what it considers due, including any amounts it collects on behalf of developers from end-users. This essentially means that funds from in-app purchases related to digital goods, services, or subscriptions could be subject to unexpected deductions based on Apple's assessment of owed amounts. The agreement does not clarify how Apple will determine if it is entitled to these funds, but it does outline that developer payments can include various commissions, fees, and taxes. Notably, the Core Technology Fee (CTF) currently imposes a charge of €0.50 for each annual install exceeding one million over the past year in the EU. In January 2026, this fee will transition to a new model, the Core Technology Commission (CTC), which will introduce a more intricate percentage-based fee structure applicable to apps utilizing external payment methods. Additionally, the updated terms empower Apple to collect unpaid dues from any associated entities, such as affiliates or parent companies, which means it could pursue collections from a developer's other applications or those from their parent organization. This agreement also includes new stipulations regarding age assurance technology, particular provisions for iOS apps in Japan, and other requirements. A noteworthy addition is the definition of protocols for voice-activated assistants, particularly concerning the prohibition of recordings made without user consent. While Apple is not outright banning these recordings, it has emphasized that applications should not facilitate such actions without user awareness. As these changes take effect, developers will need to navigate Apple's evolving guidelines, leading to questions about how strictly these rules will be enforced. Apple has yet to provide commentary on these developments.