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Apple Modifies Personalized Advertising Rules in Germany

Bundeskartellamt Accepts Apple's Commitments to Neutralize Internal Competition and Avoid Advantages in Its Ecosystem.

By Miguel SandovalPublished Aug 17, 20262 min readEurope
Conceptual representation of Apple's advertising and personal data rules

Apple will implement changes to the rules governing user data use in personalized advertising on iOS devices. Following scrutiny from the Bundeskartellamt, the German competition regulator, Apple has accepted binding commitments to align the rules applicable to its App Tracking Transparency Framework (ATTF). This change aims to level the playing field for third-party apps and Apple's own applications in advertising.

Context of the Bundeskartellamt's Intervention

The Bundeskartellamt intervened after identifying that data use in the ATTF favored Apple applications with more user-friendly consent interfaces. Apple argued that the ATTF protects user privacy and complies with competition laws. However, the regulator concluded that the discrepancies in conditions for third parties were beyond what could be justified by different methods of data processing.

Andreas Mundt, President of the Bundeskartellamt, commented: "Our objective is not to achieve high consent rates for personalized advertising, but to ensure users can decide freely and with full information."

Specific Changes to the ATTF

The difference between the conditions for Apple applications and those for third parties will be minimized. The new consent windows offered will be neutral in content and form, allowing app publishers to explain the importance of personalized advertising for their business model.

  • Simplified sequence: App creators will be able to combine the consent window required by Apple with the necessary privacy consent inquiries under the law.
  • Removal of barriers: Symbols and language that discourage consent for third parties will be eliminated.

European Cooperation and Potential Impact

Competition authorities in other European countries are also evaluating the ATTF. Companies such as the French Competition Authority and the Italian Competition Authority have imposed fines on Apple. Collaboration seeks to ensure consistent application of competition law across Europe.

Regulatory Framework and Monitoring

The procedure was based on § 19a of the German Act Against Restraints of Competition (GWB) and Article 102 of the Treaty on the Functioning of the European Union. The German regulator noted Apple's significant market position in 2023, supported by the German Supreme Court in 2025.

Apple has four months to implement the changes and will cooperate with app publishers to test the new system. The commitments will be valid for seven years, under the supervision of a Compliance Monitor.

The supplementary Q&A document provides more details on the procedure and the future application of the ATTF.

Tags

applebundeskartellamtpersonalized-advertisingcompetitiontechnology

About the author

Miguel Sandoval

Miguel Sandoval

Regulatory Affairs Correspondent

Miguel Sandoval tracks gambling legislation, licensing, and regulator enforcement — from Spain's DGOJ and the Latin American authorities to the UKGC, the MGA, and the state-by-state map in North America. The reports answer three questions precisely — what changed, where, and who it affects — with jurisdictions, dates, and penalties cited exactly as published. Operators and compliance officers read Miguel Sandoval to know which rulebook moved before their next meeting.

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