Apple has published its own account of how the European Union’s interoperability rules are working in practice. The report covers 102 requests logged between May 9 and December 31, 2025, counts 22 of them resolved with a released solution, and records zero instances where Apple says it missed one of the regulation’s own deadlines.
The report sits on Apple’s developer site alongside the same EU rules that shape how iPhone 18 Pro and iPhone Duo operate for European developers, and it runs on its own reporting schedule, separate from the iOS 27 release covered in Apple’s September event recap.
Key facts
| Item | Detail |
|---|---|
| Report period | May 9, 2025 to December 31, 2025 |
| Required by | European Commission decision, Case DMA.100204 |
| Requests received | 102 |
| Requests still pending at cutoff | 34 |
| Solutions released | 22 (18 fully released, 4 partly released) |
| Deadlines Apple reports missing | 0 |
What counts as a request, and where it goes
Apple’s report sorts the 102 requests it counted into categories before tracking their progress. Of those, 43 were requests Apple considered potentially within the scope of Article 6(7) of the Digital Markets Act, the interoperability obligation itself; 40 were requests Apple judged out of scope; 9 needed no determination because Apple says effective interoperability already existed; and 8 were closed without even a first decision, covering cases where a developer withdrew a request, left it blank, or submitted a duplicate.
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How far requests actually got
Apple’s process moves a request through three phases. By the report’s cutoff, 2 requests sat in Phase I, 2 in Phase II, and 30 in Phase III, the stage where a solution is built or released. Apple’s own percentages show 30.43 percent of requests moved from Phase I into Phase II, meaning 69.57 percent did not advance past the first phase. Of the requests that did reach Phase II, 97.29 percent moved on into Phase III.
| Timing KPI | Apple’s reported figure |
|---|---|
| Average time, request received to Phase I decision | 16.59 working days |
| Average time, Phase I decision to Phase II decision | 28.67 working days |
| Average time, Phase II decision to Phase III completion | 112 working days |
| Requests that did not move from Phase I | 69.57 percent |
| Requests that moved from Phase II into Phase III | 97.29 percent |
The smaller numbers: technical references, reviews and conciliation
Apple’s report also covers a narrower channel, where a developer asks for a technical reference rather than filing a full interoperability request. Apple says it substantively assessed five of these, published one, rejected three, and left one pending, alongside nine it counted as invalid. Separately, developers used Apple’s internal review mechanism in five situations, every one of them a dispute over a rejected request, and asked for outside conciliation on three requests, all three still open at the report’s December 31 cutoff with no settlement reached on any of them.
Nothing newer has been published since
Apple’s developer support page describes this as an annual report, and the version currently available carries a March 2026 publication date and the same May to December 2025 reporting window above. As of this month, no report covering interoperability requests from January 2026 onward has appeared on Apple’s developer site. Whatever has happened to the 34 requests still pending at the end of 2025, or to any request filed since, is not something Apple has published a number for.
What Apple has not said
- Any figures covering interoperability requests received after December 31, 2025.
- An explanation for why 69.57 percent of requests never advanced past the first phase.
- The outcome of any of the three conciliation cases still open when the report was published.
- Which individual developers or organizations filed the 102 requests the report counts.
Today is September 13, 2026. Apple’s own report, and the developer support page linking to it, remain the only published account of this process; check developer.apple.com for whichever version is current before citing a figure from this one. Until a newer report appears, the numbers above are the most recent Apple has put its own name to.
