Where We Are: The Litigation, Briefly 

Apple. Apple's new rules on external payment mechanisms can be traced back to the original Epic Games v. Apple injunction in 2024. On April 30, 2025, the Northern District of California found Apple in civil contempt for “willfully” violating that injunction, barring Apple from taking a commission on purchases made outside the app and from dictating how developers design and place their link-outs. Apple updated its U.S. App Review Guidelines accordingly. 

On December 11, 2025, the Ninth Circuit largely affirmed the contempt findings but disagreed as to a key point: it vacated the complete ban on commissions and sent the case back to the district court to set a commission “more reasonably tied to Apple’s actual costs.” As such, some fee will likely return, likely below the former 27% standard. The court also noted that Apple is permitted to impose modest restrictions on link design and require in-app parity of prominence. Apple then lost its bid for rehearing en banc in March 2026. 

The big update: On June 30, 2026, the Supreme Court granted cert — limited to the single question of whether a court can hold a party in contempt for violating the “spirit” of an injunction. Merits briefing runs into the fall, so a decision should be coming sometime in 2027. For now, the status quo holds: U.S. link-outs are allowed, and Apple isn’t collecting a commission on them. 

Google. Different case, different judge, and a very different result. A jury found Google had monopolized Android app distribution and billing, and the court entered a permanent injunction in October 2024. 

After the Ninth Circuit upheld the decisions (and the Supreme Court declined to intervene), Google rolled out a new tiered fee model and, on July 14, 2026, jointly withdrew a motion to further modify the injunction, signaling that this issue of external payments may finally be resolved – as far as the courts are concerned. 

What This Means: Requirements & Commissions

Here’s the part that can confuse many app developers: both the Apple and Google app stores now allow for external payments, but as of this writing, only Google will be imposing commissions on external purchases.

Apple: Link Out, But Keep IAP Running 

The injunction lifted Apple’s anti-steering rules; it did not touch the underlying requirement (Section 3.1.1 of Apple's App Review Guidelines) that apps use In-App Purchase ("IAP") to unlock digital content. A U.S. app can add a web-checkout button as a competing payment option and currently pay Apple nothing on those external sales, but it must offer IAP alongside any external links. As a refresher, any completed purchases via IAP are still subject to Apple's standard 30% commission. 

In short, remove IAP entirely without closely reading Apple's Guidelines, and you are very likely facing an app build rejection. Currently, there is no price-parity requirement, but there is product parity: anything you sell on the web must be buyable through IAP too. 

A quick word on exceptions to the IAP requirement: so-called “Reader Apps” (which Apple limits these to magazines, newspapers, books, audio, music, and video – think Spotify or Netflix) have never carried the IAP obligation. Plus, there are a few other narrow carve-outs under Apple's terms. Most apps don’t fit these exceptions, however, so most apps should keep IAP as an option for payments.

Looking Ahead. We will very likely see in the near future new fees imposed by Apple on external payments, along with potential parity requirements (e.g., you may not more prominently display the external link or provide discounts for external purchases). However, as of today, external payments through iOS are commission-free and absent such parity obligations.

Google: Link Out, But Pay the Service Fee 

This is the real divergence. In Google’s environment, you can drop Google Play Billing and route users to your own checkout, just like Apple – but Google collects a service fee on external purchases, unlike Apple. And the clock is now ticking. 

Google announced on July 22, 2026, that as of October 1, 2026, U.S. developers offering external payment (or what Google refers to as “alternative billing”) must report their transactions and pay Google’s relevant service fees. Those fees are as follows: 

NOTE: The lower Apps Experience / Games Level Up rates require following Google’s program guidelines and being approved by Google. 

Looking ahead. Apps on the Google Play Store need to start preparing for implementation of tracking external purchases and paying the required fees. Further, developers should start reviewing the new programs requirement now to get ahead of any major updates that might be needed to take advantage of those lower commission rates.

The Takeaway

External payment mechanisms are an attractive feature for app developers – but rolling out these features requires careful consideration and parsing of Apple and Google's relevant terms. Violation of Apple and Google's terms can carry a stricter penalty than a regulator: immediate and total removal of apps from the marketplace. 

If you have questions about structuring external payments in either store, feel free to reach out.