Apple’s EU marketplace contract changes on 1 October. Here is what operators must do

A contract change, not the first day of alternative stores

Apple’s developer support documentation sets 1 October 2026 as the date when Attachment 14 of the Apple Developer Program License Agreement supersedes the Alternative Terms Addendum for Apps in the EU. Existing EU marketplace operators must accept the updated agreement. Fees and commissions already accrued under the old addendum remain payable; replacing the contract does not cancel those obligations.

The broader unified fee model was announced in August and covered in our analysis of the new European terms. The operational question now is narrower: what must an operator change to keep its account, distribution permissions and reporting aligned? Alternative stores already exist. This deadline should not be read as the date on which distribution outside the App Store first becomes possible.

Development permission is not permission to distribute

An applicant can request a development entitlement or a distribution entitlement. Apple says the development entitlement is assigned shortly after submission, allowing work and testing in Xcode. Distribution requires eligibility checks. If approved, that entitlement is assigned on 1 October 2026 or the approval date, whichever is later. Building the marketplace and being allowed to offer it to customers are therefore separate stages.

There are routes to earlier distribution. Applicants approved to operate a marketplace in Japan or Brazil, or approved through the standby letter-of-credit or million-install routes, may request it before October, provided they accept the old EU addendum. An overseas authorisation does not itself transfer to Europe: a separate EU request remains necessary. For launch planning, approval, entitlement assignment and the public opening date should be tracked separately.

Seven alternative eligibility routes

Beyond organisational membership and ongoing operating commitments, applicants must satisfy one of seven criteria: an approved Developer Program fee waiver for an eligible nonprofit, school or government entity; a qualifying Dun & Bradstreet risk score; a qualifying stock-exchange listing, including through a corporate group; funding from a venture firm on one of Apple’s specified lists; a standby letter of credit; an eligible financial audit; or an app exceeding one million first annual installs worldwide in the preceding calendar year.

The details prevent a simple rich-versus-small classification. The funding route has no minimum investment amount. The letter of credit is for $1 million or its local-currency equivalent, from an institution rated at least BBB− or equivalent, and must remain in place for at least six months after distribution starts. The install route requires two continuous years of membership in good standing. The audit must be within three years and unqualified and unmodified; Apple says it does not assess asset values under that route. None of these rules establishes a minimum headcount.

A limited waiver, not free distribution for every small app

Apple describes a 5 percent Core Technology Commission on relevant digital sales through alternative marketplaces and their apps, including qualifying web purchases within seven days of an outgoing link tap. A small marketplace operator can obtain a waiver for its marketplace download charge or subscriptions granting access to distributed apps. That waiver should not be presented as an automatic exemption for every developer selling through the store.

To qualify, the operator must have less than €10 million in global revenue over the last twelve months and less than €1 million in lifetime revenue from those EU marketplace download or access-subscription fees. Global revenue includes associated entities and business outside apps. The two thresholds answer different questions: one measures recent business size, the other cumulative receipts from specified marketplace charges. An operator needs both calculations, rather than a single annual app-revenue total.

Reporting is part of the operating cost

Marketplace operators must report their digital-goods and services transactions to Apple, including transactions that did not complete as sales. App developers have their own reporting responsibilities, covering purchases inside their apps and through outgoing links. Operators also assume duties involving fraud, intellectual-property disputes, payments and refunds for which Apple says it cannot provide assistance.

That makes the commission rate only one part of the business case. A marketplace needs systems that distinguish attempts from completed purchases and distinguish its own transactions from developers’ transactions. The documentation does not justify treating every abandoned basket as an invoice, but it does show why collecting commissionable revenue is not the whole reporting job. Teams should map the reporting instructions to their actual purchase flows before launch.

The action for an existing operator

The membership’s Account Holder must accept the updated licence agreement containing Attachment 14. Apple says an operator already approved under the old addendum need not resubmit an entitlement request. The unified terms apply to its account from 1 October 2026 or its acceptance date, whichever is later. That account-specific rule is more precise than saying that every developer must apply again before the deadline.

An existing operator should therefore identify the person authorised to accept, verify the account’s agreement status and retain a record of outstanding liabilities under the earlier terms. A new applicant should separately verify its eligibility route and distribution entitlement. Both should check reporting and waiver calculations. The contract is being unified; the practical responsibilities of running a marketplace remain distinct and substantial.