Apple Proposes New Fee Structure for External App Purchases

The Latest Salvo in a Multi-Year Battle

Apple filed a new proposal this week seeking to establish a commission structure on digital purchases made outside its App Store infrastructure. The move arrives more than four years into its legal confrontation with Epic Games, and marks the latest attempt by Cupertino to define what revenue it can capture when developers route users beyond Apple's payment rails.

The filing comes at a moment when both companies are navigating a narrow corridor carved out by successive court rulings. At DailyTechWire, we've tracked how this case has evolved from a binary question about in-app purchase mandates into a complex negotiation over what constitutes fair platform compensation when transactions occur elsewhere.

Epic responded within hours, calling Apple's proposal "far outside of the bounds" of prior judicial guidance. The exchange underscores a fundamental tension: Apple believes its platform infrastructure justifies ongoing fees even when it processes no payment; Epic and many developers argue that once a user leaves the App Store ecosystem, Apple's entitlement evaporates.

Judicial Context and Current Status

The immediate backdrop is a ruling issued in April 2025 by California district court judge Yvonne Gonzalez Rogers. In that decision, the judge found Apple had "willfully" failed to comply with the injunction she issued in 2021 following the original Epic Games v. Apple trial. That 2021 injunction required Apple to permit developers to include external purchase links, but left open the question of whether Apple could charge for transactions completed via those links.

Apple's non-compliance finding was significant. It meant the company could not, under the current framework, take any commission on purchases made through external links. For a period spanning more than a year, developers offering external payment options operated in a rare window where Apple's reach did not extend beyond its own checkout system.

However, a Ninth Circuit Court of Appeals panel has since weighed in, creating an opening for Apple to argue anew. The appellate court did not reverse the district court's compliance finding outright, but its guidance suggested that some form of fee structure might be permissible if properly justified and proportionate. Apple's latest filing attempts to thread that needle.

What Apple Is Proposing

While the full details of Apple's proposed fee structure remain partially under seal, the filing outlines a framework that would allow the company to collect a percentage of revenue from digital goods and services purchased via external links embedded in iOS apps. The exact rate has not been publicly disclosed, but industry observers expect it to land somewhere between the 15 percent and 30 percent rates Apple charges for in-app purchases, likely tiered by developer size and revenue.

Apple's rationale hinges on the value it claims to provide even when transactions occur off-platform. The company points to App Store distribution, developer tools like Xcode and TestFlight, security vetting through App Review, and the installed base of iOS users as justifications for ongoing compensation. In Apple's view, a developer who acquires a customer through the App Store and then redirects that customer to an external payment page is still benefiting from Apple's ecosystem investments.

This argument is not new. Apple has made variations of it in filings across multiple jurisdictions, including in the European Union under the Digital Markets Act and in South Korea following that country's in-app payment choice law. In each case, Apple has sought to preserve a revenue stream by redefining what it charges for: not payment processing per se, but platform access and customer acquisition.

Epic's Counterargument

Epic's response filing challenges both the legal basis and the practical implications of Apple's proposal. The company argues that the district court's compliance ruling was unambiguous: Apple cannot impose fees on external transactions under the current injunction. Allowing Apple to do so now, Epic contends, would effectively nullify the injunction's purpose, which was to reduce Apple's control over developer monetization.

Epic also raises a competitive concern. If Apple can charge commissions on external purchases at rates approaching its in-app purchase fees, developers gain little economic benefit from offering alternative payment methods. The administrative burden of managing two payment systems, combined with Apple's external fee, could leave developers worse off than before. Epic argues this outcome would entrench Apple's dominance rather than erode it.

The filing points to international precedents where regulators have rejected similar proposals. South Korea's telecommunications regulator, for instance, has pushed back on Apple's and Google's attempts to charge high fees for third-party payment options, viewing such fees as circumventing the intent of the law. The European Commission has opened investigations into whether Apple's compliance with the Digital Markets Act, which includes fees on external transactions, meets the regulation's spirit.

What the Courts Must Decide

The district court now faces a layered question. First, does the Ninth Circuit's guidance permit any fee structure on external purchases, or does the willful non-compliance finding preclude Apple from collecting such fees entirely? Second, if fees are permissible, what rate and structure would be consistent with the original injunction's goal of reducing anti-competitive barriers?

Judge Gonzalez Rogers has shown willingness to impose detailed remedies when she finds Apple's compliance lacking. Her April 2025 ruling included specific language about what constitutes genuine external linking versus obfuscated alternatives. If she determines that Apple's proposed fee structure undermines the injunction, she has the authority to reject it outright or to impose her own framework.

The Ninth Circuit, meanwhile, has signaled that it views some degree of platform compensation as reasonable. The appellate panel's opinion acknowledged that Apple provides services beyond payment processing, and that a blanket prohibition on fees might overcorrect. But the panel did not specify a ceiling or methodology, leaving that task to the district court.

Broader Implications for Platform Economics

This dispute extends well beyond two companies. Developers across mobile and desktop platforms are watching to see whether courts will recognize a new category of platform fee - one tied not to transaction processing but to ecosystem access and distribution. If Apple prevails, other platform holders may adopt similar models, arguing that their infrastructure investments justify ongoing revenue shares even when they do not directly facilitate a sale.

The outcome will also influence regulatory approaches in jurisdictions still drafting or refining digital platform rules. Policymakers in Japan, India, Australia, and elsewhere are calibrating how much control and compensation platform operators should retain. A ruling that endorses Apple's framework could slow momentum toward more aggressive unbundling; a ruling that sides with Epic could accelerate it.

For developers, the stakes are immediate. Many have delayed implementing external payment options, uncertain whether the administrative complexity and potential Apple fees would justify the switch. A clear judicial answer - either permitting reasonable fees or prohibiting them - would let developers model their economics and decide whether to invest in alternative payment infrastructure.

What Comes Next

Both parties have requested expedited briefing, and the district court is expected to rule within the next several months. In the interim, Apple remains barred from collecting fees on external purchases under the April 2025 compliance order. That means developers who have implemented external links continue to operate in a fee-free window, though many are wary of building business models around a potentially temporary state of affairs.

Epic has indicated it will appeal any ruling that allows Apple to impose fees on external transactions, setting up the possibility of another trip to the Ninth Circuit or even the Supreme Court. Apple, for its part, has preserved its right to seek damages for what it claims is lost revenue during the period it was barred from collecting external fees.

The dispute has now outlasted multiple product cycles, several iOS versions, and shifts in both companies' broader strategies. Epic's Fortnite remains absent from the iOS App Store in the United States, though it has returned in the European Union under the Digital Markets Act's alternative app marketplace provisions. Apple has launched its own subscription services and advertising business, reducing its reliance on App Store commissions as a share of total revenue, but the platform fees remain a significant and highly profitable line item.

At DailyTechWire, we expect the resolution of this fee structure question to shape the next phase of platform regulation globally. Whether courts view ecosystem stewardship as a service worthy of perpetual compensation, or as a gatekeeper rent that competition law should curtail, will determine how much leverage developers can gain in the years ahead.

For now, both sides are dug in, and the legal system is being asked to draw lines that neither legislation nor market forces have yet settled.