Apple Agrees to Rework App Tracking Transparency Prompts in Germany

Apple has agreed to redesign the consent prompts used by App Tracking Transparency in Germany, bringing a four-year competition investigation to a close. The country's Federal Cartel Office, the Bundeskartellamt, accepted and made the company's commitments legally binding after finding that differences between Apple's own consent prompt and the prompt required for third-party apps could steer users toward different choices.



"Apple is allowed to provide for a level of protection for its users that exceeds the minimum legal requirements," said Andreas Mundt, President of the Bundeskartellamt. "However, if Apple sets up additional rules within its ecosystem for the use of data, these rules must, under Germany's special abuse provision for large digital companies, not treat its own offerings better than those of its competitors."


The commitments require Apple to redesign the ATT prompt shown by third-party apps so it is neutral in content, wording, and layout, while also amending the Personalized Ads prompt used for its own offerings. The new ATT prompt will remove discouraging symbols and wording, including the warning hand symbol and the term "tracking," and bring the wording and order of choices much closer to Apple's own prompt.

App publishers will also be able to add a customizable purpose string of up to 4,000 characters explaining the relevance and advantages of personalized advertising for their business model, replacing Apple's current one- to two-sentence standard.

Developers will also gain more flexibility to combine or connect the ATT request with consent prompts required under data protection law. Depending on their implementation, they will be able to combine both requests into a single prompt, keep them separate while noting that the user has already consented under data protection law, or continue displaying them separately as before.

Mundt said the goal is not to increase consent rates, but to ensure users can make a free and informed decision either way. "Users who do not wish to allow their data to be used for personalised advertising must be able to make an equally free and informed decision as users who intend to consent to such data use," he said.


Apple has four months from service of the commitment decision, dated August 13, 2026, to implement the changes in iOS and iPadOS. Before rolling them out, the company will conduct technical testing with app publishers. The commitments will remain in force for seven years following implementation and be overseen by an independent monitoring trustee.

The changes apply to users with App Store billing addresses and devices located in Germany. The Bundeskartellamt said the outcome may also influence the future design of App Tracking Transparency in other EU member states.

The Bundeskartellamt opened the proceeding in June 2022 under Section 19a of the German Competition Act and Article 102 TFEU. After issuing its preliminary assessment in February 2025, it market-tested Apple's proposed commitments later that year and requested further amendments before making them binding. Throughout the case, Apple maintained that App Tracking Transparency was designed to better protect user privacy and reinforce its position as offering a particularly high level of data protection, while industry associations representing the branded-goods, media, and advertising sectors argued that the framework unfairly restricted advertising-funded business models.

France and Italy previously imposed fines on Apple in separate competition proceedings involving App Tracking Transparency. Italy fined the company €98.6 million in 2025, while France imposed a €150 million penalty, according to the Bundeskartellamt.