What Apple’s Brazil Settlement Means for iOS Payments and Web Stores
TL;DR
Brazil has forced Apple into a binding regulatory settlement that will open iOS to external payments, third-party app stores, and a new regulated fee regime. Apple has 105 days from the settlement date to implement the changes, putting the practical deadline around April.
While the general fee model is already defined by CADE, Apple has not yet published official developer terms. The framework mandates side-by-side coexistence between Apple IAP and alternative payments and introduces a unique 0% static-text referral path to web stores.
Background: Apple’s Regulatory Dispute with CADE
After a prolonged regulatory and legal battle, Apple has reached a binding settlement with Brazil’s competition authority, CADE, requiring fundamental changes to how the iOS App Store operates in Brazil.
From the moment the decision becomes effective, Apple has 105 days to fully implement the new regime, placing the practical compliance deadline around April.
The Binding Settlement and 105-Day Compliance Timeline
The settlement is binding and imposes a fixed implementation window. Apple is required to operationalize all mandated changes within 105 days of the settlement taking effect.
While the regulatory obligations are final, the platform-level implementation has not yet occurred.
What Apple Is Required to Allow on iOS in Brazil
Under the settlement, Apple must allow:
• External payment links
• Third-party payment methods inside apps
• Distribution of apps through third-party app stores
Unlike the U.S. model, the Brazilian framework mandates a side-by-side coexistence model. Alternative payment options must be presented alongside Apple’s In-App Purchase system.
Apple is prohibited from designing user experiences that bias the choice toward its own payment method or that introduce friction for alternative options. As a result, external payments cannot fully replace Apple IAP as a standalone option.
Mandatory Side-by-Side Payment Presentation
The coexistence requirement is a core structural element of the Brazilian framework.
Alternative payment methods must be displayed in parallel with Apple IAP, rather than as a replacement flow. UX designs that steer users toward Apple’s payment system or degrade the usability of alternative options are explicitly prohibited.
Brazil’s iOS Fee Framework (As Defined by the Settlement)
The settlement also defines a new and detailed fee structure.
Importantly, Apple has not yet published official Brazil-specific developer guidelines or contractual terms reflecting this model. At present, the fee framework is derived from Apple’s binding regulatory commitments to CADE, not from live Apple Developer documentation.
Fee Breakdown: Apple IAP, External Payments, and App Stores
According to the settlement framework:
• Purchases made via Apple IAP remain subject to a 10% or 25% commission, plus an additional 5% transaction fee.
• External payment referrals made via static text only, without a clickable button or link, carry no Apple fee.
• Clickable external payment buttons or links are subject to a 15% fee.
• Third-party app stores are subject to a 5% Core Technology Commission.
The Unique 0% Static-Text Referral Path
The static-text referral provision is unique to Brazil and has no parallel in any other jurisdiction.
This mechanism is expected to enable publishers to direct users from within the game to their web stores using non-clickable text and execute D2C purchases at an effective 0% regulatory referral fee.
What Has Not Yet Been Published by Apple
Based on Apple’s enforcement models in other regions, Brazil is also expected to introduce:
• Dedicated entitlements
• Mandatory UX requirements
• User disclosure obligations
• New developer contractual frameworks
However, Apple has not yet released any official documentation outlining how these requirements will be implemented in Brazil.
Current Status: Binding Obligations, Not Yet Live
At present, while the regulatory obligations are binding, Apple’s implementation layer has not yet been published.
As a result, the Brazilian model is not yet live at the platform level, and developers do not yet have access to finalized terms, entitlements, or enforcement guidelines.
