Britain’s Competition and Markets Authority (CMA) on Tuesday, October 20, 2026, published a proposed conduct requirement that would force Apple to open the near field communication (NFC) chip in UK iPhones to rival payment apps, banks and other developers on “fair, reasonable, transparent and non-discriminatory” terms. The proposal is the first NFC remedy the regulator has drafted under its new digital markets regime, and it targets the two things UK fintechs say have kept them off the iPhone: the technical route Apple allows and the fees Apple charges for it.
The consultation runs until November 17, 2026. After that the CMA will decide whether to impose the requirement, which under the draft would take effect three months after a final decision. For retailers, card issuers and payment providers, the document is the clearest signal yet that tap-to-pay on the iPhone in the UK could stop being an Apple Pay monopoly within roughly a year.
In short
- What happened: the CMA proposed an NFC access conduct requirement for Apple’s mobile platform under the Digital Markets, Competition and Consumers Act 2024, published at 11:00 UK time on October 20.
- Technology: Apple would have to offer both HCE and SE, the two international contactless standards. Today it offers only the secure element route in the UK.
- Fees: the CMA will not set a price, but it expects charges to be substantially lower than Apple’s current fees, set by cost, value and flexibility principles.
- Why now: two years after Apple’s NFC & SE Platform reached the UK, the CMA says there is no evidence of a single NFC app launching, while five rival wallets launched in Europe after the EU forced free access.
- Timeline: responses close November 17, 2026; any final rule would apply three months after the decision, with the next iOS release required to carry the plumbing.
What exactly did the CMA propose on October 20?
The CMA published a consultation document of more than 140 pages titled “NFC Access Conduct Requirement: Apple’s Mobile Platform,” alongside a press release and a case page on GOV.UK. The proposal sets out a single conduct requirement (CR) with several obligations, a provisional assessment of whether it would work, and a provisional assessment of whether it is proportionate. It follows the regulator’s designation of Apple as having strategic market status (SMS) in its mobile platform in October 2025.
The core obligation is simple to state. Apple would have to grant developers who request it access to NFC on iOS devices in the UK, through either host-based card emulation (HCE) or a secure element (SE), at the developer’s choice. Apple could refuse or interrupt access only in limited circumstances, such as serious harm to the security, privacy or integrity of iOS or of user data.
Around that core sit supporting duties. According to the consultation document, Apple would have to publish its access terms, run an authorization process and a dedicated complaints process, and give developers an API that tells them whether their app is the user’s default contactless app. It would also have to provide the iOS functions that power Express Mode and Power Reserve, so that rival apps can handle transit taps and low-battery transactions the way Apple Wallet does.
The legal hook: fair dealing and open choices
Under the Digital Markets, Competition and Consumers Act 2024, the CMA can impose conduct requirements on a designated firm if they serve one of the statutory objectives. The NFC proposal rests on two of them: “fair dealing,” meaning developers get access on reasonable terms, and “open choices,” meaning consumers can pick between Apple’s services and rivals. The document lists each obligation against the “permitted types” of requirement in the Act, including trading on fair terms and not restricting interoperability.
The CMA also used its process to blunt a common objection. The consultation states that any non-disclosure agreement a company has with Apple should not stop it from responding, and that Apple has confirmed it will not use confidentiality provisions to prevent responses. That matters because most of the stakeholder evidence in the document is redacted, and many banks and wallet providers negotiate with Apple under NDA.
Why does the CMA say Apple’s current terms are not working?
Apple’s position is that it already opened the iPhone. In October 2024 it made its “NFC & SE Platform” available to developers in the UK and several other jurisdictions, and Apple told the CMA there is “significant and growing interest” in it. Apple has also pointed to Mastercard and Visa, which have both released tools built on the platform: Mastercard announced its Wallet Services in July 2026, and Visa said in September 2026 that its token service now supports iOS secure element use cases.
The CMA’s answer is the outcome. “Two years after the platform became available there is still no evidence of NFC apps launching in the UK using the platform,” the consultation states. The press release puts it more bluntly: unlike in the EU, “not a single firm has launched a wallet-type product to compete with Apple’s in the UK.”
Stakeholders told the regulator that the fees and the non-price terms are the reasons. The document records complaints that Apple’s terms include non-negotiable limits on permitted use cases, that Apple can change, deny or delay access at any time, that diverging technical approaches between the UK, the EU and Android make products hard to scale, and that developers cannot easily tell whether their app is the default. On the evidence gathered, the CMA concludes that Apple’s current fees “are too high to support commercially viable entry and expansion for many developers.”
How Apple’s NFC fee structure works, according to stakeholders
Apple does not publish a simple public rate card for NFC access, and the CMA redacted the figures it received. What the document does describe is the structure. Two stakeholders said Apple charges a periodic provisioning fee per credential plus a per-transaction fee, and one complained of a fixed fee element and charges that rise once a certain number of users is reached.
That structure is costly in two specific cases, the stakeholders argued. A card that sits in a rival wallet but is rarely used still incurs the provisioning fee, so the wallet can pay Apple more than it earns. And because the per-tap charge does not shrink with the basket, the effective cost rises as the average transaction value falls, which hits debit cards hardest because their interchange income is lower. For a grocery or convenience retailer whose shoppers tap for small amounts, that is the exact profile of their checkout.
How would HCE and SE access change what rivals can build?
The technical choice sounds arcane but it decides who can enter. A secure element is a dedicated, tamper-resistant chip inside the phone that stores credentials on the device. HCE stores the sensitive data in the cloud and sends the phone a small number of one-time tokens for each transaction, so the app emulates a card in software.
Apple currently offers only SE in the UK. The CMA proposes that it must offer both, and it says the evidence it has seen “suggests that neither technology raises inherent security concerns.” The regulator notes that both standards were developed outside Apple and are already used across mobile ecosystems, including on Android.
| Feature | Host-based card emulation (HCE) | Secure element (SE) |
|---|---|---|
| Where credentials live | Off-device, in secure cloud storage; phone holds one-time tokens | On a dedicated security chip inside the phone |
| Available on iPhone in the UK today | No | Yes, via Apple’s NFC & SE Platform |
| Available on iPhone in the EEA | Yes, free of charge since the 2024 EU commitments | Yes |
| Typical strengths cited to the CMA | Fast to build; apps already live in Europe can be ported | Offline performance, high-assurance credentials, mandated standards |
| Under the CMA proposal | Must be offered at the developer’s request | Must be offered at the developer’s request |
The practical effect is speed. The CMA observed that developers launched HCE payment apps within six months of access opening on iOS in the EEA, and stakeholders told it that having a live HCE iPhone app in another country would make a UK launch faster and cheaper. Banks, fintechs and industry groups also said they view SE as valuable for offline use and for credentials where standards require it, which is why the regulator wants developers to be able to choose.
Apple’s counter-argument on cost and security
Apple argued in its submissions that, if any intervention is needed, it should focus exclusively on SE. It told the CMA that porting an EEA HCE app or an Android HCE app to the UK iPhone would not be simple or cheap, citing UK-specific APIs, onboarding and entitlement processes, commercial models and design choices, and noting that iOS and Android are different architectures. It also said it had seen no evidence that SE solutions cost developers more to build than HCE ones.
Publicly, the company framed its objection around user protection. “We do not believe the CMA should require Apple to adopt an approach with lower privacy and security protections,” an Apple spokesperson said, according to Reuters and the PA news agency. “We will continue to engage constructively to reach an outcome that is in the best interest of our users.” Apple also said its NFC & SE Platform already supports in-store payments, transit passes, car keys and event tickets while keeping data secure.
How do the proposed fee rules work?
The CMA is not proposing a price. Instead, the draft requirement says Apple “may require a Developer to pay an NFC Access Fee,” but must be able to show the regulator that each fee is fair, reasonable and non-discriminatory, and no higher than a fee set under three principles. The press release adds the expectation that charges would be “substantially lower than Apple’s current fees while still fairly rewarding Apple for providing access.”
- Cost-based principle: fees must take account of Apple’s direct and indirect costs of providing and maintaining NFC access, plus a reasonable rate of return on the related investments.
- Value-based principle: fees must reflect the value of what Apple contributes, adjusted for the effects of Apple’s market power, so that both sides are fairly treated.
- Flexibility principle: Apple must offer different fee structures for different kinds of use, taking into account tap frequency, whether the use case is new or still developing, and whether and how revenue is generated per tap. Developers must be able to switch structures when another fits better.
The fees must also not discriminate between Apple and developers, between categories of developers, or between developers who prefer HCE and those who prefer SE. That last clause closes an obvious route for steering everyone back to the technology Apple favors.
The comparison the CMA draws is with Android. Google told the regulator that it provides open and free access to HCE to make Android more attractive, and it facilitates third-party use of the secure element on Pixel phones. Because the underlying technology was not developed by Apple and is “often provided for free or with minimal fees” by others, the CMA said it “would expect any resulting fees to be low and substantially lower than Apple’s current charges.”
What card issuers pay Apple today
The document gives one window into the money at stake, though a heavily redacted one. In 2025, UK card issuers paid Apple a total that the CMA would only disclose as falling within a range of zero to GBP 150 million (up to about USD 200 million at the October 19 reference rate of USD 1.3331 per pound) in per-tap fees for point-of-sale transactions processed by Apple Pay. “Even a small percentage decrease in per-tap fees as a result of competition could result in substantial savings,” the CMA wrote.
Those fees are separate from NFC access fees charged to third-party wallets, but the regulator links the two. If alternative wallets can enter, it argues, competition would put “downward pressure on Apple Pay fees,” and one card issuer told it that lower wallet costs would strengthen the case for investing in payment features and security.
How does the UK plan compare with the EU’s Apple Pay settlement?
The European Commission got there first. On July 11, 2024, it accepted legally binding commitments from Apple to give third-party wallets free access to NFC for payments using HCE in the European Economic Area, along with supporting features such as the ability to set a default wallet. The commitments closed an antitrust investigation rather than relying on the Digital Markets Act.
The results are the CMA’s main exhibit. Six months after the EU commitments were accepted, Norway’s Vipps MobilePay launched what it called the world’s first alternative to Apple Pay on iPhone, on December 9, 2024. PayPal followed in Germany in May 2025, Curve in June 2025, BBVA in Spain in October 2025 and Klarna, with tap to pay across 14 markets, in December 2025, according to the consultation.
| Question | EU / EEA (2024 commitments) | UK today | UK under CMA proposal |
|---|---|---|---|
| Legal basis | Antitrust commitments accepted by the European Commission | Apple’s voluntary NFC & SE Platform | Conduct requirement under the DMCC Act 2024 |
| Technology offered | HCE for payments (SE also available) | SE only | HCE and SE, developer’s choice |
| Access fee | Free of charge | Provisioning and per-transaction fees (amounts redacted) | Permitted, but “substantially lower” and principle-based |
| Default contactless app | Users can choose a default wallet | Limited information for developers on default status | API to check default status; prompting not capped |
| Scope beyond payments | Payments focus | Payments and some other uses under Apple terms | Payments plus IDs, keys, tickets, loyalty and new use cases |
| Rival wallets launched | At least five (Vipps, PayPal, Curve, BBVA, Klarna) | None, per the CMA | To be seen |
Reuters reported that the UK proposal is less onerous for Apple than the EU measures, because it allows Apple to charge for access rather than requiring it to be free. It is broader in another way, however: it covers both technologies and explicitly reaches non-payment uses such as digital IDs, travel passes, hotel and car keys, and loyalty services. Retailers following the European rollout can read more about how account-to-account schemes are trying to reach the till in our analysis of Wero’s path to French retail checkout, a scheme that depends on exactly this kind of phone-level access.
What would the change mean for retailers and merchants?
Merchants are not the target of the remedy, but they sit at the end of every tap. In the UK, contactless already dominates: UK Finance estimates contactless payments, by card or phone, rose 2% to 19.2 billion in 2025, or 39% of all payments, compared with 3% a decade earlier. Which? found in 2026 that 62% of UK adults use a digital wallet and that Apple Wallet is the most popular, at 50%.
The CMA estimates that about 22 million people in the UK use Apple Pay or Apple Wallet at least once a month. Any shift in how even a fraction of those taps is routed, priced or rewarded will show up in merchant economics, loyalty programs and checkout design. US retailers saw how much wallet acceptance matters to shoppers when Walmart turned on Apple Pay in August after a decade of holding out.
Loyalty, receipts and retailer-branded wallets
The most immediate retail opportunity in the document is not payments but everything around them. The CMA cites a 2026 Which? estimate that a digital wallet combining automatic loyalty points, receipt storage, ID storage and flexible cards could be worth around GBP 119 million a year to UK consumers (about USD 159 million). The list of use cases in the press release explicitly includes “loyalty and rewards services” and “tickets and travel passes.”
Today a retailer or bank that wants a tap on the iPhone to both pay and collect points must work within Apple Wallet’s rules. With HCE access and a default-app API, a supermarket app, a bank app or a payment provider could, in principle, run the full tap inside its own app and decide what data and rewards come with it. Whether any large UK retailer would build its own wallet is an open question; the economics of wallets are thin, as stakeholders told the CMA, and most will likely wait to see what banks and payment firms ship first.
Account-to-account payments at the till
The longer-term merchant angle is cost. Several stakeholders told the CMA that effective NFC access is one of the prerequisites for account-to-account (A2A) payments, such as open banking, to compete with card-based wallets at the point of sale. “One of the goals of A2A is to provide a lower cost alternative to card payments for merchants,” the document notes, citing a report by Ernst & Young and Open Banking Limited that estimated A2A could generate GBP 1.9 billion (about USD 2.5 billion) in business opportunities.
The Financial Conduct Authority endorsed that link. “Opening up this technology will also support the expansion of open banking, enabling more people to make payments directly from their bank accounts,” said David Geale, the FCA’s executive director for consumers, payments and competition. For merchants who have watched card costs climb, any credible A2A tap option at the counter would add a lever in negotiations that currently barely exists; the US debate over interchange shows how few such levers there are, as covered in our look at why swipe fees likely will not fall for US merchants in 2027.
Who could launch rival iPhone wallets in the UK, and how fast?
The likeliest first movers are firms that already run HCE wallets on iPhones in Europe. PayPal, Klarna, Curve and BBVA all have live iPhone tap-to-pay products in at least one EEA market, according to the consultation. Klarna and PayPal both have large UK customer bases, and Curve is a London-based fintech, which would make UK launches a natural extension if the economics work.
UK banks are the other obvious group. The CMA says multiple banks and fintechs told it they want to provide NFC transactions directly in their own apps rather than through a third-party wallet, and that payments are “a gateway to wider customer relationships.” Mastercard has said it is already working with partner banks developing digital wallet features using its iOS service, and expects consumers to start using new capabilities by the end of 2026.
The constraint is time. Under the draft, the requirement would come into force three months after a final decision, Apple would have to file an implementation plan within one month, and the first iOS version released after the decision would have to include the necessary technical infrastructure. If the CMA decides in early 2027, the earliest realistic window for UK HCE wallets is mid-2027, based on the six-month EU launch pattern the regulator itself cites.
| Date | Milestone |
|---|---|
| July 11, 2024 | European Commission accepts Apple’s binding NFC commitments (free HCE access in the EEA) |
| October 2024 | Apple opens its NFC & SE Platform in the UK and other jurisdictions |
| December 9, 2024 | Vipps MobilePay launches the first alternative iPhone payment app |
| October 2025 | CMA designates Apple with strategic market status in mobile platforms |
| June 30 – July 21, 2026 | CMA call for evidence on NFC access, technology and pricing |
| October 20, 2026 | CMA publishes the proposed NFC access conduct requirement |
| November 17, 2026 | Consultation closes |
| After responses | Final decision; requirement in force three months later |
What does this mean for Apple beyond the UK?
The UK is now the second major jurisdiction, after the EU, to move from asking Apple to open NFC to requiring it on defined terms. The difference in method matters. The EU route was a negotiated settlement with free access; the UK route is a statutory requirement that lets Apple charge but subjects its prices to regulatory principles and quarterly compliance reports. If it works, other regulators looking at mobile ecosystems will have two templates to choose from.
For Apple, the commercial stakes are visible in the fee line rather than the hardware. Apple earns per-tap fees from card issuers on Apple Pay transactions, and the CMA’s own framing is that alternative wallets would pressure those fees. The company has fought other CMA mobile measures in the past, and it is already facing UK litigation on separate competition issues, including the GBP 289 million class action over Apple and Amazon reseller deals.
For merchants outside Europe, the immediate change is nil, and Apple’s NFC access in other countries remains on Apple’s own terms. Expansion of iPhone-based acceptance tools follows a separate, country-by-country path set by Apple, as our analysis of why Tap to Pay on iPhone likely skips India until 2028 lays out. But the UK proposal adds pressure on Apple to treat open access and lower fees as the default in large markets, rather than as an exception.
What happens next, and what should payment teams do before November 17?
The consultation closes on Tuesday, November 17, 2026. The CMA has asked specific questions in a final chapter, covering whether the proposed requirement would be effective, whether it is proportionate, how the fee principles should work in practice, and how Apple’s compliance should be monitored. Responses can be submitted through the CMA’s consultation page on GOV.UK.
Payment, loyalty and product teams at UK retailers and banks have three practical reasons to engage. First, the flexibility principle explicitly asks whether revenue is generated per tap, which means low-value and non-payment uses such as loyalty, receipts and access passes could secure lighter fee structures if respondents make the case. Second, the default-app API and the Express Mode functions decide whether a rival app can win the everyday tap, so merchants who care about checkout speed should say so. Third, the evidence in the document is heavily redacted, and the CMA has removed the NDA excuse for not responding.
Watch three things after the deadline: whether the final requirement keeps HCE in scope despite Apple’s push for SE only, whether the CMA puts any numbers on “substantially lower” fees, and whether a large UK bank or fintech commits publicly to a launch date. Sarah Cardell, the CMA’s chief executive, set out the regulator’s intent: “By removing barriers to entry, we can help create the conditions for brilliant British businesses with great ideas to develop new products and services here, from payment apps and digital IDs to travel passes and digital keys.”
Frequently asked questions
What is the CMA’s NFC access proposal for Apple?
It is a proposed conduct requirement under the Digital Markets, Competition and Consumers Act 2024 that would require Apple to give developers access to the iPhone’s near field communication technology in the UK, through both HCE and secure element routes, on fair, reasonable, transparent and non-discriminatory terms, including fees expected to be substantially lower than Apple’s current charges.
When does the consultation close?
The CMA opened the consultation on October 20, 2026, and it closes on Tuesday, November 17, 2026. The regulator will make a final decision after assessing the responses, and the draft says any requirement would come into force three months after that decision.
Will the CMA set Apple’s NFC fees?
No. The CMA is not proposing a specific price. It proposes cost-based, value-based and flexibility principles that Apple must follow, and Apple would have to show the CMA that each fee is fair, reasonable and non-discriminatory. The regulator says it expects the resulting fees to be low and substantially lower than today’s.
What is the difference between HCE and SE?
Host-based card emulation (HCE) keeps sensitive payment data off the device in secure cloud storage and sends one-time tokens to the phone. A secure element (SE) is a dedicated security chip inside the phone that stores credentials on the device. Apple currently offers only SE access in the UK; the proposal would require both.
Why has no rival to Apple Pay launched on iPhone in the UK?
According to the CMA, stakeholders blame fees that make entry commercially unviable, non-negotiable terms on permitted use cases, Apple’s ability to change or withdraw access, and technical differences from the EU and Android. Despite Apple opening its NFC & SE Platform in the UK in October 2024, the CMA found no evidence of NFC apps launching on it.
How is the UK approach different from the EU’s?
The EU accepted binding commitments from Apple in July 2024 that give wallets free HCE access for payments in the EEA. The UK proposal would let Apple charge, but under regulatory principles, and it covers both HCE and SE and a wider set of uses such as digital IDs, keys, tickets and loyalty services.
What does Apple say about the proposal?
An Apple spokesperson said the company does not believe the CMA should require it “to adopt an approach with lower privacy and security protections” and that it will “continue to engage constructively.” In its submissions, Apple argued that any intervention should focus only on the secure element.
How could retailers benefit from open NFC access?
Retailers could see rival wallets that bundle loyalty, receipts and rewards into the tap, more pressure on wallet and card costs, and a possible path for lower-cost account-to-account payments at the till. Any benefit depends on banks and fintechs launching products, which the EU experience suggests could take around six months after access opens.
Does the proposal affect iPhones in the United States?
No. The conduct requirement would apply only to Apple’s provision of NFC access in the UK. NFC access elsewhere, including in the US, remains on Apple’s own terms unless other regulators act.