Summary

• The CMA proposes requiring Apple to support both secure element and host-based card emulation technologies for third-party NFC applications.
• Its proposed access principles are intended to produce substantially lower charges while allowing Apple fair compensation, rather than imposing a fixed price.
• The consultation follows Apple's strategic market status designation and closes on 17 November 2026, before any final conduct requirement is decided.

The Competition and Markets Authority has proposed changes to the way Apple provides access to contactless technology on iPhones, seeking to reduce the fees and technical restrictions that UK financial technology businesses say hinder their ability to compete.

The consultation, published on 20 October, would require Apple to support both major international near field communication standards and make access available on fair, reasonable, transparent and non-discriminatory terms.

Known as NFC, the technology enables communication between devices at short distances. It supports contactless payments as well as digital travel passes, identity credentials, loyalty services and electronic keys used to enter buildings or vehicles.

The CMA believes Apple’s existing arrangements may make it commercially difficult for independent developers to provide some of these services in the UK. The regulator is seeking responses by 17 November before deciding whether to impose a conduct requirement under the Digital Markets, Competition and Consumers Act 2024.

Developers would gain a choice of NFC technology

The proposed requirement addresses two technical approaches: secure element technology and host-based card emulation.

A secure element stores sensitive credentials in a protected component of the device. Host-based card emulation provides an alternative method that can support contactless interactions with relevant information managed outside that component.

Both technologies are used internationally, but Apple’s current UK arrangements provide access through the secure element approach. The CMA wants developers to have access to both standards, allowing them to select the architecture that meets their service requirements.

That choice could be particularly relevant to businesses already providing contactless payment services in other markets. Maintaining different technical versions for the UK and European Union can increase software development costs, testing requirements and the complexity of supporting customers across jurisdictions.

The CMA says the evidence it has examined does not identify inherent security concerns that would justify excluding either standard. That assessment concerns the technologies themselves; individual applications would still need appropriate controls for authentication, credential management and the protection of customer information.

For developers, technical access also involves reliable documentation, application interfaces and approval processes. A platform may support an industry standard while imposing conditions that make it difficult to use in a commercially viable service.

The consultation therefore looks beyond whether an iPhone is technically capable of exchanging contactless information. It examines the rules governing who may use that capability and under what circumstances.

Commercial terms could determine market entry

The CMA has received complaints that Apple’s charges and associated contractual conditions create barriers for UK businesses developing contactless products.

For a payment provider, access charges can become significant when applied across large numbers of transactions or users. A business with relatively narrow margins may find that an additional fee prevents it from offering a competitive service even where the technology operates correctly.

Developers of travel, identity and access applications can face similar considerations, particularly when the service must work with established infrastructure and customers expect convenient access through their phones.

The regulator is not proposing to set a fixed access price. Instead, it wants principles governing how fees and other terms are determined, with the expectation that charges will be substantially lower than those currently imposed by Apple.

Its approach would also allow Apple to receive fair compensation for making the functionality available. The proposed terms would need to permit effective competition without requiring Apple to provide access without charge.

Pricing transparency will be relevant to that assessment. Developers need enough information to evaluate likely costs, establish business models and compare alternatives before committing engineering resources to a service.

Non-discriminatory terms are also important where a platform operator supplies its own products alongside competing applications. Businesses need confidence that access conditions will not unnecessarily favour services controlled by the platform owner.

Implementing the principles could require decisions about the basis on which fees are calculated, how changes are communicated and how disputes concerning access are resolved.

European wallet launches provide a comparison

The CMA points to developments in the European Union, where changes to Apple’s NFC access arrangements have enabled alternative payment applications to reach the market.

According to the regulator, Vipps launched a competing payment service six months after Apple agreed to provide access in the EU. Other companies entering the market include PayPal, Klarna, Curve and BBVA.

The regulator contrasts that activity with the UK, where it says no wallet-type product competing with Apple’s own offering has launched under the existing arrangements.

The comparison does not establish that identical businesses or services would emerge immediately following changes to UK access rules. Payment arrangements, customer demand and commercial strategies differ between markets, while prospective entrants would still need to develop and support their products.

Nevertheless, the EU experience gives the CMA an example of how changes to access conditions can create opportunities for competing developers using established technology.

UK fintech businesses may be particularly interested in account-to-account payments. These services allow users to transfer funds directly between bank accounts, potentially supporting alternatives to some conventional card-based payment arrangements.

David Geale, the Financial Conduct Authority’s executive director for consumers, payments and competition, welcomed the CMA’s proposals and connected improved NFC access with the development of open banking payments.

Other potential applications extend beyond payments. Developers could use contactless technology to support digital credentials, age verification, workplace entry and transport services, depending on the technical and commercial arrangements established.

Competition intervention follows platform designation

The proposals follow the CMA’s designation of Apple’s mobile platform as having strategic market status under the UK’s digital markets regime.

That designation allows the regulator to consider targeted conduct requirements addressing identified competition problems. It does not itself require Apple to implement every change proposed during subsequent consultations.

The latest process follows an earlier call for evidence on NFC access launched in June. Businesses and other interested parties now have an opportunity to comment on the proposed measures and the practical conditions needed for effective implementation.

The CMA has confirmed that confidentiality arrangements with Apple should not prevent businesses from making submissions to the consultation.

The regulator estimates that the UK fintech sector generates approximately £214 billion in turnover and supports more than 360,000 jobs. It also cites figures showing that contactless transactions accounted for 39% of all UK payments in 2025, compared with 3% a decade earlier.

Those payment figures include physical cards as well as mobile devices, so they describe the wider contactless market rather than the proportion of transactions conducted using iPhones.

Research cited by the CMA also indicates that 62% of UK adults use a digital wallet, demonstrating the commercial importance of interfaces through which consumers access payment and credential services.

The consultation closes on 17 November. The CMA will then assess submissions before determining whether to impose a conduct requirement and what its final terms should contain.

The practical consequences will depend on the standards Apple is required to support, the costs and approval procedures faced by developers, and the services that businesses subsequently bring to the UK market.