Apple Rewrites Its Tracking Prompt for Five EU Countries
Software / analysis
Apple Rewrites Its Tracking Prompt for Five EU Countries
Beginning with iOS 27.2, apps in Germany, France, Italy, Poland and Romania must show a reworded App Tracking Transparency prompt, after regulators in those countries fined Apple a combined 248.6 million euros or forced a settlement over the old one.

Apple told developers on Sept. 16 that a reworded version of its App Tracking Transparency prompt will become mandatory in five European Union countries starting with iOS 27.2 and iPadOS 27.2, ending a dispute with national antitrust regulators that has run since 2022.
The change appeared in an Apple developer news post titled "Updates to App Tracking Transparency in the European Union," which frames the rewrite as the result of "agreements with select European competition authorities." Apps distributed in Germany, France, Italy, Poland and Romania must use the new wording once iOS 27.2 ships; developers elsewhere in the EU may use it but are not required to. Apple's post does not change what triggers the permission prompt in the first place, only its wording and button labels.
What the new prompt actually says
According to MacObserver and ppc.land, which each reviewed the beta wording independently, the prompt's refusal button changes from "Ask App Not to Track" to "Reject," and the underlying settings toggle changes from "Allow Apps to Request to Track" to "Allow Apps to Request to Link Your Activity Across Companies." The opening sentence drops the word "track" in favor of language describing an app's ability to "link your app activity with data from other companies' apps, websites, or with offline data, for personalized advertising or to measure advertising effectiveness." The new version also adds an "Additional Information" button that the current prompt does not have. iOS 27.0 shipped Sept. 14; as of Sept. 16, iOS 27.2 remained in beta with no release date announced. Under both the old and new wording, ppc.land reports that iOS records the date of a user's answer and will not show the prompt again for a year, regardless of whether the user allowed or rejected tracking, unless the person changes the setting manually first.
What happens when a user says no
A rejection does not leave developers with nothing. ppc.land reports that install measurement then falls back to Apple's own aggregated frameworks, SKAdNetwork and AdAttributionKit, which report campaign performance without identifying individual users. Apple's own advertising business uses a separate system, the AdServices API, that third-party ad networks cannot access at all, a distinction close to the one the Bundeskartellamt flagged in its February 2025 preliminary findings when it concluded Apple's tracking rules could treat outside developers less favorably than Apple's own services. Apple has not said whether the AdServices API is covered by any of the five countries' agreements or remains outside their scope entirely. Mobile analyst Michal Nováček, who flagged the change to other app-industry professionals on LinkedIn, framed it as required reading for anyone running paid user acquisition into the five affected countries.
Four regulators, four different outcomes
Germany's Bundeskartellamt opened the first formal case, in June 2022, after complaints from app publisher and advertising trade groups, and issued preliminary findings in February 2025 concluding Apple's rules could "treat third-party developers less favourably than Apple's own services." Rather than issue a fine, the Bundeskartellamt accepted binding commitments from Apple on Aug. 13, 2026, without a formal infringement finding. France's Autorité de la concurrence took the harder line, fining Apple 150 million euros on March 30, 2025. Italy's competition authority followed with a 98.6-million-euro fine on Dec. 22, 2025, over what it called the prompt's "double-consent burden." Poland's UOKiK brought its own charges in late 2025, and Romanian authorities have an investigation open; neither had reached a public resolution as of Apple's Sept. 16 announcement.
| Country | Regulator | Outcome | Date |
|---|---|---|---|
| Germany | Bundeskartellamt | Binding commitments, no fine | Aug. 13, 2026 |
| France | Autorité de la concurrence | 150 million euro fine | March 30, 2025 |
| Italy | Competition authority | 98.6 million euro fine | Dec. 22, 2025 |
| Poland | UOKiK | Charges brought | Late 2025 |
What Apple will and will not say
Apple's position, as described by ppc.land, is that its own apps "do not use personal data collected from apps to target ads," and that it applies the same tracking rules to itself as to outside developers when they similarly avoid cross-app data linkage. Apple has not published the specific text of the commitments it gave German regulators, has not said whether it expects the remaining Polish and Romanian cases to end in fines or settlements like Germany's, and has not said whether the reworded prompt will eventually replace the global version rather than stay confined to five countries.
The five-country carve-out puts Apple in a position other platforms have faced before: running two versions of the same permission screen depending on where a user's device is registered. Google's Play Store has drawn its own regulatory pressure over billing rules, which is part of what pushed the messaging app Conversations to abandon Play billing entirely after 12 years rather than keep adjusting to it. Apple's change here is narrower: it rewrites the words developers must show users, not the underlying mechanism, and does not touch the commission structure that has drawn the bulk of the EU's separate Digital Markets Act scrutiny.
The dispute also sits inside a wider pattern of governments taking different approaches to overseeing powerful technology platforms, from Brussels' country-by-country antitrust enforcement against Apple to Washington's rejection of binding international rules, a divide visible when Sam Altman and Dario Amodei briefed the U.N. Security Council on artificial intelligence oversight in September while the U.S. declined to back enforceable global rules.
For developers, the immediate task is mechanical rather than legal. Apple's post links to its existing user-privacy and data-use documentation rather than issuing new integration code, meaning the prompt text is expected to update automatically for apps in the five countries once a device runs iOS 27.2. Whether that satisfies the Polish and Romanian regulators still weighing their own cases, or whether the AdServices carve-out draws a fresh complaint once developers notice it, is the question Apple's Sept. 16 post left unanswered.
Sources
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