Brasília, December 19, 2025 — Brazil’s CADE has released a technical report summarising the main contributions presented during its public hearing on competition in mobile digital ecosystems, focusing on Apple’s iOS and Google’s Android platforms.
The report systematises oral and written submissions made at the public hearing held on February 19, 2025. It maps key areas of debate on competitive dynamics, regulatory approaches, and alleged unilateral conduct within mobile operating system ecosystems.
Regulatory Approaches and Enforcement Tools
One section of the report addresses regulatory and institutional frameworks for digital markets, highlighting diverging views on whether traditional ex post enforcement is sufficient to address competition concerns in mobile ecosystems. Several contributors argued for the potential need for asymmetric ex ante tools targeting platforms with gatekeeper characteristics, while others cautioned against regulatory intervention that could undermine legal certainty, innovation, or efficiency.
The submissions also discussed coordination between competition enforcement and sector-specific regulation, weighing the risks and benefits of hybrid approaches.
Competitive Dynamics of iOS and Android
Another section examines the structure and functioning of the Android and iOS ecosystems, including differences in business models, degrees of openness, vertical integration, and relationships between users, developers, and device manufacturers.
Participants expressed differing views on the intensity of competition between the two ecosystems. While some pointed to rivalry for users and developers, others highlighted switching costs, patterns of single-homing and multi-homing, and potential limits to competitive discipline, particularly at the level of app stores.
Alleged Unilateral Conduct
The report also compiles alleged unilateral practices raised during the hearing. These include pre-installation agreements and default app settings, anti-steering rules, mandatory use of native payment systems, commission policies, access to technical functionalities and restrictions on alternative distribution channels.
Contributors assessed how such practices could affect prices, quality, innovation, market contestability and rivals’ access to key inputs within mobile ecosystems.
International Perspectives
Finally, the report incorporates an international perspective, referencing cases and regulatory initiatives in jurisdictions including the European Union, the United States, the United Kingdom, Germany, Japan, the Netherlands, and Australia. These examples illustrate different combinations of competition enforcement and sectoral regulation and inform the discussion on whether, and to what extent, similar approaches could be applied in Brazil.
CADE stressed that the report is descriptive in nature and does not reflect the authority’s position on the issues discussed.
