Apple Clarifies Controversial “User Disclosures” Screen

Apple Warns About Third Party Payments

Apple has responded to backlash over the warning labels shown on apps using third-party payment systems in the European Union. The company says the “user disclosure” screen, now at the center of developer and regulatory criticism, has been in place since March 2024 as part of its Digital Markets Act (DMA) compliance plan. It insists the label is not new and was approved as part of its early rollout strategy.

The warning appears above the app’s icon and name and features a bright orange triangle with an exclamation mark. While critics claim the design mimics alerts reserved for serious risks like data loss, Apple maintains that it complies with EU regulations and follows internal design standards.

Apple: Screen Part of March DMA Compliance

Apple told me that the current disclosure screen was introduced at the beginning of its DMA compliance rollout. In August 2024, the company proposed changes to the screen as part of a broader update package. Apple says it was ready to implement the updated version but paused the rollout at the request of the European Commission. The Commission reportedly raised no objections to the new design but asked Apple not to move forward. Since then, Apple says no further guidance was provided.

Despite waiting for direction, Apple was fined €500 million in March for noncompliance. The company maintains it followed the process and held back changes in good faith while awaiting regulatory approval. The screen, according to Apple, is not intended to mislead but to inform users about alternative payment flows.

Critics Remain Skeptical

Developers and legal experts argue the warning screen still resembles alerts used for high-risk threats such as data loss. The icon—an orange triangle with an exclamation mark—appears above the app name, raising concerns that users may wrongly perceive third-party payment systems as unsafe. Critics say the approach contradicts Apple’s interface guidelines and may breach EU anti-steering rules.

As reported by Michael Tsai and others, the company does not apply similar warnings to major apps like Amazon or Safari, where external payments are standard. This inconsistency has raised questions about selective enforcement and potential anti-steering violations under the DMA.

While Apple says it acted in good faith and revised its approach months ago, the company’s continued friction with regulators suggests the dispute is far from over.

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