Apple's ATT Consent Prompts Get a Competition-Law Makeover in Germany

Germany's Federal Cartel Office (Bundeskartellamt) has closed its abuse-of-dominance proceeding against Apple over the App Tracking Transparency Framework (ATTF) by declaring Apple's proposed commitments legally binding. The regulator's core complaint: Apple's own consent prompts for personalised advertising were designed to encourage consent, while the prompts it forced on third-party apps were structured to discourage it. That asymmetry, the authority argued, breached Germany's special abuse control rules for large digital companies (Section 19a GWB) and Article 102 TFEU.

Apple maintains the ATTF is a privacy-protection measure and competition-law compliant, but it has agreed to significant changes. Under the binding commitments, Apple will align its consent prompts for its own offerings and third-party apps much more closely. Specifically, it will remove potentially discouraging symbols and wording from the predefined prompts for third-party providers, making the design neutral in content, wording, and layout. App publishers and content providers—like media publishers—will also get more room to explain to users why personalised advertising matters for their business model.

The commitments also tackle the complexity of the current consent architecture. Third-party apps often had to request consent multiple times even after users had already given data-protection-law-compliant consent. Apple will now give app publishers more freedom to combine its required consent request with the requests mandated under data protection law, or connect them in a way that is clear to users. Advertisers and technical service providers to the advertising industry are expected to benefit from the improved conditions as well.

The proceeding, initiated in June 2022, reflects a broader European push. The French and Italian competition authorities have already fined Apple a combined €248.6 million over the ATTF. The Bundeskartellamt's solution, reached after a market test in December 2025, is intended to shape the future design of the ATTF across the EU. Apple has four months to implement the changes, which will apply for seven years and be monitored by an independent trustee.

Notably, the Bundeskartellamt stressed it is not aiming to maximise consent rates. As President Andreas Mundt put it, the goal is to ensure users can make a free and informed decision—whether they choose to allow or deny personalised advertising.