Brasília, December 23, 2025 —Brazil’s antitrust authority CADE has formed a majority to approve a settlement with Apple in an investigation into alleged anticompetitive practices in the iOS ecosystem, paving the way for significant changes to app distribution and in-app payment rules.
The proposed Termo de Compromisso de Cessação (TCC) addresses concerns that Apple restricted competition by prohibiting developers from distributing third-party digital goods and services through iOS apps and by mandating the exclusive use of Apple’s in-app payment system (IAP). The investigation also examined anti-steering clauses that prevented developers from informing users about alternative payment options outside Apple’s system.
Key Commitments
Under the agreement, Apple commits to allowing developers to promote external offers and direct users to complete transactions outside the app. Developers will also be permitted to offer alternative in-app payment methods alongside Apple’s own payment solution, displayed side by side to enhance consumer choice.
The settlement further requires Apple to allow alternative app distribution channels, including third-party app stores, within the iOS ecosystem. Any warnings or notices shown to users must be neutral, objective, and limited in scope, without creating friction or degrading the user experience.
Specific safeguards aimed at protecting children and minors were incorporated into the agreement, developed jointly with Apple.
Fees, Duration, and Enforcement
The TCC establishes a new fee structure aligned with the revised rules, with the stated objective of ensuring that developers and users experience tangible pro-competitive effects.
Apple will have up to 105 days to implement the changes. Once in force, the agreement will apply for three years and may be reviewed if the measures fail to achieve their intended objectives.
Non-compliance could result in fines of up to BRL 150 million (approximately $27.1 million) and the reopening of the investigation, including the reinstatement of interim measures.
Case Background
The investigation began in December 2022 following a complaint by Mercado Livre, alleging abuse of dominance in the distribution of iOS applications. In November 2024, CADE’s investigative arm ordered interim measures expanding developers’ freedom to choose payment systems and distribution channels. Those measures were upheld by CADE’s tribunal in May 2025.
In June 2025, CADE’s investigative authority recommended that Apple be found liable. The company subsequently sought to negotiate a settlement, leading to the suspension of the interim measures during talks.
With the approval of the TCC, the administrative proceeding will be suspended while Apple complies with the agreed obligations, without prejudice to future enforcement in case of new conduct. The full text of the agreement is expected to be published shortly.
