On 22 October 2025, the Competition and Markets Authority issued two landmark decisions that will reshape the UK’s mobile ecosystem for years to come. Following the CMA’s first designation decision on 10 October 2025 designating Google Search with Strategic Market Status (read about it in our blog here), the CMA designated both Apple and Google as having Strategic Market Status in the provision of their respective Mobile Platforms under the Digital Markets, Competition and Consumers Act 2024. These parallel designations represent the first comprehensive application of the UK’s DMCCA regime to mobile platforms, following extensive nine-month investigations that gathered evidence from both companies, over 100 market participants, and received 41 consultation responses combined (23 for Apple, 18 for Google). Read our blog on the consultation responses here.
by Anush Ganesh
Scope of the Designations
The CMA took distinct approaches to defining each platform’s digital activities, reflecting distinct differences in their business models. For Apple, the Mobile Platform encompasses iOS, iPadOS, the App Store, and Safari with WebKit on Mobile Devices (Apple para 1.13). These components form an integrated package of complementary services facilitating interactions between users and content providers (Apple para 1.15). The definition excludes the devices themselves and content accessed via the platform, though the CMA recognizes their close connection within Apple’s broader Mobile Ecosystem (Apple para 1.16).
Google’s Mobile Platform comprises Android, Google Play Store, and Chrome and Blink (Google para 1.14). Android is licensed to manufacturers under various agreements, with Google controlling both the open-source Android Open-Source Project (AOSP) and proprietary Google Mobile Services (GMS) providing access to essential apps and Application Programming Interface (API) (Google paras 4.20-4.22). Chrome is pre-installed on most Android devices as the default browser, and Blink is embedded in numerous apps through WebView, giving Google pervasive influence over web content access (Google para 4.85).
Both designations reflect a critical innovation in the CMA’s approach. Rather than treating operating systems, app stores, and browsers as separate markets, the CMA grouped these components together because they are closely related, carried out in conjunction, and subject to common competitive dynamics (Apple para 1.15; Google paras 1.16-1.18). This grouping reflects commercial reality as users, manufacturers, and app developers interact with these components as an integrated ecosystem rather than discrete services.
Platform Power
While both companies achieved SMS designation, their investigations revealed different approaches to platform control that achieve similar competitive outcomes. Apple operates through integration across the entire ecosystem, controlling hardware design, operating systems, app distribution, browser functionality, and payment processing (Apple paras 1.19-1.20). The company generates revenue primarily from device sales rather than advertising, commanding 50-60% of UK mobile devices through substantial and entrenched market power stable over at least eight years (Apple paras 6.19-6.24). The CMA found evidence of ecosystem lock-in, with brand loyalty driving users to own multiple Apple devices and using integrated services, substantially increasing switching costs (Apple paras 6.71-6.85).
Google maintains platform power through apparently open architecture with strategic control points. Android’s open-source foundation enables device customization and alternative app distribution (Google para 1.20), yet Google maintains control through Play Services, search defaults, and advertising integration (Google paras 2.43-2.44), commanding 40-50% of UK mobile devices within a stable duopoly (Google para 1.4). Despite the technical openness, the CMA found Google faces no effective competition in licensing its Mobile Platform to OEMs due to their dependence on GMS licensing (Google paras 1.24-1.26 and 4.20).
Market Dominance
The CMA conducted comprehensive assessments revealing limited effective competition. Apple supplies around 50-60% of UK end-users and Google supplies around 40-50%, with both platforms serving distinct customer groups (Google para 6.94). In tablets, Apple’s iPad has an even stronger position (Apple paras 6.33-6.36), with Apple particularly dominant at the premium smartphone end (Apple paras 6.37-6.45).
Market segmentation reduces direct competitive pressure. Google dominates smartphones under £300 with 100% share, while Apple commands 82% over £600 (Google para 6.24; Apple para 6.21). Among Android users, 76% did not consider switching primarily due to cost, with 51% citing iPhones as too expensive (Apple para 6.38). Among iOS users, 85% did not consider switching, suggesting different retention mechanisms across platforms (Google para 6.47).
Google pays Apple to be the default search engine in Safari worth £1-3 billion annually in the UK which fundamentally alters competitive incentives (Apple paras 6.126-6.127). The CMA concluded this dampens competition between the two ecosystems, as both companies share an interest in maintaining the status quo, reducing competition intensity (Apple para 6.128; Google para 6.143).
Through evidence shown by the CMA, it was learnt that users rarely consider switching between ecosystems due to high switching costs, both technical such as data transfer difficulties and psychological such as familiarity and ecosystem lock-in (Apple paras 6.46-6.67). Apple challenged these findings, citing evidence that 65% of users who switched encountered no barriers (Apple Response to Consultation, page 28). However, the CMA maintained that costs and friction remain significant deterrents (Apple para 6.66).
App developers must access both platforms’ user bases to reach their full potential customer base. Developers engage in multi-homing, developing apps for both iOS and Android, but this demonstrates both platforms are essential rather than indicating substitutability (Apple paras 6.89-6.93; Google paras 6.134-6.136). For Google specifically, while multi-homing is prevalent, it does not provide effective competitive constraint. The necessity of maintaining an Android presence means app developers lack credible exit options (Google para 6.152).
Strategic Significance and Economic Impact – SEMP and POSS
Both investigations identified substantial barriers operating at multiple levels preventing meaningful competition. The CMA identified powerful indirect network effects creating self-reinforcing barriers: more users attract more app developers, which attracts more users, creating a “chicken and egg” problem for new entrants struggling to achieve critical mass on both sides simultaneously (Google paras 6.151).
The CMA found Apple has been highly profitable globally for at least ten years, with high margins and high return on capital. Services revenue, including App Store and Safari-related revenue, has grown to 25% (and almost 40% of gross profits) in 2024 (Apple paras 8.10). This sustained high profitability supports the finding of substantial market power (Apple para 8.45).
Similarly, the CMA found that Google generated a revenues in the range of £10-20 billion in the UK in 2024 (Google para 8.20). Browsers require major engineering resources to maintain modern browser engines meeting evolving web standards (Google paras 6.170-6.171). The CMA concluded that no new mobile ecosystem has successfully entered the market at scale in over a decade and that the market for smartphones and tablets has been dominated by Google and Apple (Google para 8.61).
Beyond substantial and entrenched market power (SEMP), both firms have positions of strategic significance (POSS) meeting multiple statutory criteria (Apple para 1.26; Google para 1.27). Large numbers of UK businesses depend on the platforms to reach customers, satisfying the criterion that a significant number of other firms use the digital activity in carrying on their business (Google para 8.88; Apple para 8.95).
Almost all adults in the UK have access to a mobile device, and almost all use a platform provided by Apple or Google. The UK has a vibrant app developer community, representing Europe’s largest app economy by revenue and app developer count. In total, the UK app economy generates an estimated 1.5% of UK GDP while supporting approximately 400,000 jobs across direct, indirect and supporting functions (Apple para 1.5).
The FinTech sector contributes over 76,000 jobs, over half of all UK unicorn companies, and more than £18 billion of inward investment over the past three years (Google para 1.7). The UK video games sector contributes £6 billion of Gross Value Added annually and supports 73,000 jobs, with mobile gaming the fastest growing segment (Apple para 1.6; Google para 1.7). Given the important role these platforms play as essential gateways for UK mobile users accessing digital content and for UK businesses distributing such content, it is imperative these groups are treated fairly and have trust and confidence in their ability to use these platforms (Apple para 1.8; Google para 1.9).
The Important Role of Consultations in the CMA’s decision making
The CMA’s consultation process genuinely shaped both final decisions, demonstrating meaningful stakeholder engagement. The authority received 23 consultation responses for Apple and 18 for Google, held over 100 bilateral meetings across both investigations, and commissioned independent consumer research. The CMA stated that all responses and representations have been considered (Apple para 1.1; Google para 1.2). See our blog on the process here.
Apple faced remarkable consensus with 20 of 23 stakeholders (87%) supporting SMS designation. Technology companies documented specific technical restrictions preventing innovation. Mozilla detailed how WebKit requirements delayed Firefox iOS development by seven years while preventing Web Bluetooth and comprehensive extension support. Vivaldi documented inability to provide advanced browser features due to engine restrictions. Google received substantial but less unanimous support with 13 of 18 stakeholders (72%) supporting designation while 4 organizations opposed it, reflecting more complex competitive dynamics around Android’s open architecture. Organizations that responded to both consultations revealed consistent patterns, with Which?, Mozilla, Radiocentre, and Mobile UK supporting both designations while CCIA and Consumer Choice Center consistently opposed both. This has been extensively covered here.
In its final decisions, the CMA carefully considered these competing perspectives (Google para 1.14; Apple para 1.13). While acknowledging arguments about dynamic competition and consumer satisfaction, the CMA found the evidence from platform-dependent businesses more compelling. The CMA concluded that both Apple and Google have substantial and entrenched market power, with limited effective competitive constraints from each other or from alternative platforms. The overwhelming stakeholder support from companies actually operating within these ecosystems, combined with evidence of high switching costs, powerful network effects, and formidable barriers to entry, provided strong foundation for the designations.
The CMA determined that the revenue-sharing agreement between Apple and Google further dampens competition between the two ecosystems, as both companies share an interest in maintaining the status quo (Apple paras 6.126-6.127). The forward-looking assessment found no evidence of expected or foreseeable developments likely to eliminate either company’s substantial market power over the next five years, including developments in AI technologies which the CMA concluded would more likely amplify rather than reduce platform control effects.
Forward-Looking Assessment and AI Integration
Both designations last five years from 22 October 2025 and open the door to potential conduct requirements. The Act requires the CMA to carry out forward-looking assessments of at least five years. The CMA examined potential technological developments that might affect market power over the next five years, with particular focus on artificial intelligence integration. Both platforms face similar AI integration opportunities with different strategic approaches that could amplify existing competitive advantages (Google paras 8.32-8.34). Apple emphasizes on-device processing through custom silicon potentially strengthening hardware-software integration advantages (Apple para 8.49). Google leverages cloud-based AI and data advantages potentially strengthening search and advertising integration (Google para 8.42). Multiple stakeholders, including Radiocentre, emphasized that AI-enhanced voice assistants could fundamentally alter device interaction, potentially allowing platforms to intermediate all digital interactions.
The CMA found no evidence of expected or foreseeable developments likely to eliminate either company’s substantial market power. The CMA concluded that while digital markets are dynamic, foreseeable changes will not sufficiently alter competitive dynamics to eliminate substantial and entrenched market power over the relevant period (Apple paras 8.40-8.41). Multiple stakeholders predicted AI integration could amplify rather than reduce platform control effects, making immediate regulatory intervention crucial before technological development further entrenches market power through new mechanisms.
The CMA considered various regulatory and legal developments in other jurisdictions but found they are not likely to be sufficient in scope, timeliness, and impact to eliminate either company’s market power in mobile platforms in the UK over at least the next five years (Apple para 8.57; Google para 8.50). Regarding the EU’s Digital Markets Act, the territorial reach does not extend to the UK, so both companies may carve out the UK from compliance measures. Even if they voluntarily extend DMA responses to the UK, these obligations aim for contestability and fairness, not eliminating market power directly (Apple para 8.59; Google para 8.52).
Conclusion
These parallel designations represent the most comprehensive regulatory intervention in mobile platforms undertaken anywhere in the world under a dedicated digital markets regime. The careful analysis reveals how different technical and business strategies can achieve similar competitive outcomes, with Apple’s vertical integration and Google’s strategic control points both creating substantial and entrenched market power protected by formidable barriers. The overwhelming stakeholder support, particularly from smaller firms dependent on these platforms, provides strong foundation for regulatory intervention. The divide between companies who documented quantified harm and academic organizations focused on broader economic theory reflects deeper questions about regulating platforms that provide genuine consumer benefits while maintaining systematic competitive barriers.
The CMA found that both companies have held unparalleled positions in their respective mobile platforms for extended periods, with Apple maintaining 50-60% UK share and Google commanding 40-50%, together forming what the CMA characterized as a stable duopoly. The revenue-sharing agreement between them further reduces competitive intensity, with Google paying Apple £1-3 billion annually to maintain default search status on iOS devices. As the CMA moves toward its first conduct requirements under the new regime, both companies’ extended periods of largely unchallenged dominance face their first serious regulatory test under a regime specifically designed for digital market dynamics.
The consultation processes can meaningfully shape regulatory outcomes, and the forward-looking assessment must account for how emerging technologies like AI may amplify rather than reduce existing competitive barriers. The UK’s approach may well set global precedents for how jurisdictions worldwide approach platform regulation in an era of rapid technological change. The investigations demonstrate that platform power operates as fundamental digital infrastructure affecting broad economic activity across multiple sectors, from browser competition to financial services to emerging AI technologies, requiring sophisticated regulatory responses that address varying control mechanisms while maintaining consistent competitive principles.
