Apple Faces £2 Billion Legal Action on behalf of Thousands of UK App Developers Over App Tracking Transparency (ATT) Framework
London, 3 September 2026 – Apple faces a £2 billion collective action, filed on behalf of thousands of UK app developers in the UK Competition Appeal Tribunal (CAT) by ATT Collective Action Limited whose director Ann Pope is the former Senior Director for Antitrust at the CMA. The claimants argue that Apple's App Tracking Transparency (ATT) framework was designed and implemented unfairly and without proper consultation, imposing stricter requirements on third-party app developers than on its own services and leaving UK app developers unable to adapt their business models in time to avoid significant losses.
The introduction of ATT on 26 April 2021 fundamentally altered how many developers provide their services.
Many app developers in the UK are small businesses. According to the Department for Science, Innovation and Technology, 70% employ fewer than 10 staff, with the most common company size consisting of just two employees.
Many of these businesses rely on digital advertising and app discovery tools to attract users and sustain free-to-use services. They have also faced commercial pressure from App Store fees, restrictions on steering users to alternative payment options, and limitations introduced under ATT.
The legal case
Apple’s ATT framework introduced rules for third-party app providers on the use of data on iPhones and iPads. Third-party iOS apps must obtain user consent under data protection law, as well as an additional consent through a prompt, predefined by Apple. However, these rules do not apply to Apple’s own offerings and Apple uses its own prompt to request user consent to personalised advertising.
As a result, the double consent requirement for third party apps is harmful to developers, whose business model relies on the sale of advertising space, as well as to advertisers and advertising intermediation platforms.
Leveraging its gatekeeper status, Apple imposed the framework unilaterally across the iOS ecosystem without consulting developers, or imposing the same restrictions on its own services, leaving third-parties with little practical choice but to comply if they wished to continue reaching Apple users.
The claim alleges that Apple applied less burdensome requirements to its own advertising and data collection activities than those imposed on third-party app developers. These differences gave Apple's advertising ecosystem a competitive advantage while imposing additional restrictions on businesses that depend on the App Store.
An opt-out collective action
As an opt-out legal action, UK app developers who generated revenue from advertising within a third-party iOS app and/or spent money on advertising to attract users to a third-party iOS app are automatically represented by this claim.
Ann Pope, director of the proposed class representative in the claim, commented:
“Privacy is an important protection for consumers, but it should be applied fairly and in a way that ensures businesses of all sizes can compete on a level playing field. It cannot become a reason for digital platforms to play by one set of rules while forcing app developers to play by another.”
“This action is important to protect the rights of British businesses that depend on Apple, to ensure that the rules that Apple applies are fair, and to compensate the losses that British companies have suffered.”
Luke Streatfeild, Partner at Hausfeld and lead solicitor for the claim against Apple, said:
“This claim raises important questions about how powerful digital platforms should behave, and about the intersection of privacy protections and fair markets.”
“The ATT Policy got this balance wrong. It was introduced unfairly and unilaterally, without consultation, in a manner that damaged British app developers without justification, while allowing Apple’s business to flourish. It is vital for the health of our economy that powerful companies treat other market participants properly and give their businesses a fair opportunity to grow.”
Regulators around the world are scrutinising Apple's ATT implementation
The impact on app developers of Appe’s ATT implementation has been scrutinised by regulators around the world. Apple's introduction of ATT triggered investigations by competition authorities in France, Italy, Germany, Poland and Romania.
In August 2026, the German regulator’s investigation into ATT resulted in Apple agreeing to ensure that third-parties are treated more in line with Apple’s own apps by removing potentially discouraging wording and symbols and making the consent process clearer and more neutral. These sweeping changes are likely to be implemented across Europe. The Romanian Competition Council is reportedly open to adopting similar remedies, whilst also considering issuing a fine against Apple for abuse of dominance.
French regulators concluded that Apple abused its dominant position in iOS and iPadOS app distribution and imposed a fine of approximately £127 million.
Italy's competition authority also found that Apple abused its dominant position in the mobile app market, fining the company and its subsidiaries approximately £84 million, and requiring that Apple immediately cease its anti-competitive conduct.
In the UK, the CMA has noted that Apple’s expansion of its own advertising business coincided with the introduction of ATT, and further identified that some businesses reported significant declines in advertising income following the introduction of ATT, while others were forced to shift towards subscription-based or in-app purchase models in order to sustain their operations.
Relatedly, Apple has been designated by the CMA as having Strategic Market Status (SMS) in relation to its mobile platform, including its App Store, reflecting its gatekeeper status in the provision of iOS apps.
Media enquiries
Please send your media enquiries to: pope@thorndonpartners.com
Media
GCR (subscription)
Reuters
Silicon Republic
The Lawyer (subscription)
Notes to editors
About the claim
Website for affected organisations to register their interest and find more information: appleapptrackingclaim.co.uk
About the proposed class representative
Ann Pope is a competition law expert and economist who has spent her career working in UK antitrust law. With more than 30 years of experience in competition and consumer enforcement, she began her career at the Office of Fair Trading, the predecessor to the Competition and Markets Authority in 1988. Between 2014 and 2024, she served as the CMA’s Senior Director for Antitrust, leading the competition watchdog’s investigations into firms’ abuse of market dominance.
About the legal team
Hausfeld, led by Partners Luke Streatfeild and Amandine Gueret, with assistance from Charles Laporte-Bisquit, Ginevra Bicciolo, Demica Kaur Nettleford, Cara Nicholson, George Bailey, Gemma Davis and Skye Blackshaw.
A counsel team of Gerry Facenna KC, alongside Nikolaus Grubeck from Monckton Chambers, Narinder Jhittay and Eoin MacLachlan from Maitland Chambers. The claim also relies on the expertise of Dr Andrea Coscelli, Senior Partner at Keystone, and Dr Reuben Binns, Associate Professor of Computer Science at the University of Oxford. The claim is funded by TR Global Funding X (Jersey), LP.
Additional sources
CMA investigates Apple over suspected anti-competitive behaviour (2021)
CMA - Mobile ecosystems market study final report (2022)
CMA confirms Apple and Google have strategic market status in mobile platforms (2025)
The Italian Competition Authority fines Apple over 98 million euro for abuse of a dominant position (2025)
Bundeskartellamt - Apple changes its rules for personalised advertising in apps (2026)
Dr. Rachael Kent v Apple Inc. and Apple Distribution International Ltd
