App Store
Apple’s app marketplace, designated in the first round.
- Tier
- VLOP — very large online platform
- Provider
- Apple Distribution International Limited
- Sector
- App store
- Designated
- 25 April 2023
- Obligations from
- 25 August 2023
- EU users at designation
- 123 million
- Formal proceedings
- None to date
- Court challenges
- None
Designated 25 April 2023 on 123 million average monthly active recipients in the Union.
The App Store sits at the intersection of the DSA and the Digital Markets Act: the same distribution surface is a designated VLOP for systemic-risk purposes and a core platform service of a gatekeeper for contestability purposes, under two separate regimes with separate enforcement.
Where App Store sits in the tier
Designation is not a ranking, and the obligations do not scale with size: the smallest designated service carries exactly the same duties in Articles 33 to 43 as the largest.
A marketplace, a minors surface, and a gatekeeper service at once
An app store is a marketplace in DSA terms wherever developers sell paid apps or in-app purchases, so the Article 30 to 32 trader duties reach app developers as traders — identification, compliance by design, and the duty to inform buyers when something illegal was sold.
The Commission’s July 2025 guidelines on Article 28(1) name app stores explicitly as a surface where the protection of minors has to be designed in, rather than delegated downstream to the apps themselves.
Separately, the same distribution surface is a core platform service of a designated gatekeeper under the Digital Markets Act. Two regimes, two sets of obligations, two enforcement tracks — the DSA governs systemic risk, the DMA governs contestability.
- Articles 30–32
- Trader duties, applied to developers offering paid apps and in-app purchases.
- Separate regime
- Digital Markets Act obligations, enforced independently of the DSA.
App Store timeline
- 25 April 2023 Designated a VLOP by Commission decision.
- 25 August 2023 Articles 33 to 43 begin to apply, four months after notification.
What App Store has to do
Designation applies the asymmetric obligations in Articles 33 to 43. They are the same for every designated service, read against a platform surface. Terms used on this page are collected in the glossary.
- Article 34 Systemic risk assessment
- Article 35 Mitigation of risks
- Article 37 Independent audit
- Article 38 Recommender systems without profiling
- Article 39 Advertising repository
- Article 40 Data access for the Commission and vetted researchers
- Article 41 Internal compliance function
- Article 42 Transparency reporting
- Article 43 Supervisory fee
Related designations
Other app store services in the tier: Google Play.
Designated on the same day (25 April 2023): Google Search, Bing, YouTube, Google Play, Google Maps, Facebook, Instagram, Amazon Store, Wikipedia, TikTok, Pinterest, X, AliExpress, Snapchat, Zalando, Google Shopping, LinkedIn, Booking.com.