The Impact of Apple's DMA Compliance on the Business of Games
The Doors Have Opened: How Apple's DMA Compliance Is Reshaping Mobile Monetization in Europe
There are rare moments in platform policy when change feels truly transformative. The European Union's enforcement of the Digital Markets Act (DMA) is one of them. After years of frustration from developers and mounting legal pressure, Apple has made structural changes to its App Store operations in Europe. These adjustments introduce new opportunities for mobile game monetization, but they are layered with complex opt-in procedures, nuanced fee structures, and strategic tradeoffs that require developers to navigate with clarity and precision.
A Turning Point for the App Store in Europe
On June 26, 2025, Apple released an update to its EU App Store policy to meet the DMA's compliance deadline and avoid additional penalties beyond the €500 million fine imposed in April. For the first time, developers in Europe can now guide users to make in-app purchases through external web-based payment flows. However, gaining access to this capability requires developers to adopt new business terms and apply for what Apple calls the "StoreKit External Purchase Link Entitlement."
Developers opting in must move the affected app into what Apple defines as "Tier 1." This status allows the use of external payment links but comes with significant tradeoffs. Specifically, Tier 1 developers lose access to 28 key App Store features, including App Store featuring, curated search enhancements, expedited app review, custom product pages, in-depth performance dashboards, and developer marketing tools. By default, all developers remain in Tier 2, which retains full platform support but prohibits any form of in-app steering to off-platform purchases. Developers may switch an app between tiers once per quarter, on a per-app, per-storefront basis.
The Fee Structure: Lower on Paper, Complex in Practice
Apple's revised business model introduces a three-part fee system for Tier 1 developers using the External Purchase Link Entitlement. First, a 2 percent initial acquisition fee is applied to users who make an external purchase within seven days of installing the app. Second, a 5 percent Store Services Fee is charged for access to limited App Store infrastructure such as baseline security, distribution, and technical support. Third, a new 5 percent Core Technology Commission applies to every external transaction completed via an approved link. This replaces the previously proposed €0.50 per-install Core Technology Fee, which Apple plans to sunset on January 1, 2026.
In total, developers using external links under Tier 1 face an effective commission of 10 to 12 percent, depending on user behavior and transaction timing. This represents a notable reduction from Apple's traditional 30 percent cut. However, the lower rate comes at the cost of platform visibility, marketing support, and technical insights that many developers rely on for growth and retention.
Furthermore, developers are required to display a prominent in-app alert—sometimes referred to as a "scare screen"—before users are redirected to an external payment flow. While user consent is only required once per app, the visual weight of the warning may discourage some purchases and introduce friction to the user experience.
Apple has also stated its intention to unify all EU developers under a single business model by January 1, 2026. Whether that future model further simplifies or complicates developer options will likely depend on how the European Commission responds to Apple's current approach. The Commission is actively reviewing the updated terms and is expected to seek feedback from market participants before making a final ruling. In the meantime, Apple has confirmed that it will appeal the existing fine, with a formal deadline set for early July.
Strategic Implications for Mobile Game Developers
The ability to monetize directly through external links is a long-awaited development, but the decision to opt in must be approached carefully. Developers with established brands, strong off-platform user acquisition funnels, and a solid direct-to-consumer infrastructure stand to benefit the most from the new model. For these studios, the lower fees can result in up to 25 percent more retained revenue per transaction, which can be reinvested into user acquisition, live operations, or loyalty programs.
However, developers who rely on App Store search visibility, promotional features, and real-time analytics may find the Tier 1 tradeoffs difficult to justify. The loss of curated search placement and marketing visibility could impair discoverability, especially for newer or growth-stage titles. Developers must also weigh whether their team has the capacity to support external payment infrastructure, customer support, and the added compliance burdens that come with owning the entire purchase flow.
Xsolla's Buy Button: Enabling a D2C Strategy in the DMA Era
To support this evolving monetization landscape, Xsolla has expanded its Buy Button for Mobile Games to serve European developers navigating the new regulatory framework. The Buy Button is already widely adopted in the United States and allows developers to embed a seamless, browser-based checkout experience directly within their iOS game interface.
This solution is built to be fully compliant with Apple's new rules and includes features such as global tax handling, GDPR compliance, loyalty and VIP systems, branded gift cards, and built-in parental controls. In the U.S., developers using the Buy Button have seen up to 70 percent of mobile revenue shift to direct channels. The European rollout extends this opportunity to developers who are ready to take control of their business model and maximize D2C monetization.
What Developers Should Do Now
Game developers operating in the EU should immediately assess the tier model's financial and operational implications. This includes calculating the effective commission savings under Tier 1, estimating potential revenue loss from diminished App Store visibility, and evaluating internal capabilities to support external payments and customer engagement.
It is equally important to stay informed. Apple's appeal of the €500 million fine is pending, and the European Commission has yet to issue a final judgment on whether the latest policy updates meet DMA requirements. Further changes are likely, particularly as Apple prepares to consolidate its business model for all developers in the region by early 2026.
Looking Ahead
The introduction of external payment entitlements marks a real, if complicated, shift in the mobile app ecosystem. For the first time, developers have a legitimate and sanctioned path to build a direct commercial relationship with their iOS users in Europe. But with that freedom comes complexity, friction, and the loss of platform perks that have long been taken for granted.
The road ahead is open but not without obstacles. Developers who approach this moment strategically—grounded in data, supported by partners, and aligned with their long-term vision—will be the ones best positioned to thrive in this new regulatory era.
Chris Hewish is President, Communication & Strategy, at Xsolla and a recognized leader in the global games industry. This article is part of the "Impact on the Business of Games" series, which explores transformative developments shaping the future of interactive entertainment.