From Thursday, October 1, 2026, a company qualifies to run an alternative app marketplace in the European Union, or to distribute an app from its own website, if it meets any one of seven tests Apple lists on its developer support page. One of those seven is a letter of credit of USD 1,000,000, a specific, quotable figure that has drawn almost no attention next to the rate-card changes announced the same day.
The rule sits inside the same August 18, 2026 update that replaced the Core Technology Fee with a 5 percent Core Technology Commission. Apple frames both changes as part of a single set of business terms for apps in the EU, agreed with the European Commission.
Key facts on EU marketplace eligibility
| Item | Detail |
|---|---|
| Effective | October 1, 2026 |
| Number of qualifying tests | Seven, any one is sufficient |
| Financial-guarantee test | Letter of credit of USD 1,000,000 |
| Scale-based test | One million first annual installs worldwide |
| Review requirement | Notarization, for every alternatively distributed app, regardless of which test is met |
| Source | developer.apple.com/support/apps-in-the-eu/ |
Seven ways to qualify to run an EU app marketplace
Apple’s developer support page states that a company qualifies to operate an alternative app marketplace, or to distribute via its own website, if it meets any of the following:
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- Meets Dun & Bradstreet financial-stability standards.
- Is publicly traded.
- Has received venture funding.
- Has completed a financial audit.
- Is a government, educational, or nonprofit entity.
- Provides a letter of credit of USD 1,000,000.
- Has one million first annual installs worldwide.
That list widens eligibility beyond the large, already-audited or publicly traded companies that could meet the first four tests without changing anything about their business. The letter of credit and the installs threshold are the two routes built for a marketplace operator that does not already have public financials or venture backing to point to.
The $1,000,000 letter of credit path
A letter of credit is a bank’s written guarantee to pay a set amount if the party that requested it fails to meet an obligation. Apple’s page states the figure as USD 1,000,000 and does not specify the issuing bank, the term length, or what triggers a claim against it. It is listed as an alternative to the audit, public-trading, and venture-funding tests, not as an additional requirement stacked on top of them.
For a marketplace operator without a public listing, an outside audit, or venture financing to cite, the letter of credit is the clearest documented way into EU distribution rights, provided it does not instead qualify on the strength of one million first-year installs.
Notarization still applies to every alternatively distributed app
Apple’s page is explicit that meeting one of the seven tests does not remove Apple’s own app review. “All alternatively distributed apps still require Notarization review,” regardless of which eligibility path a marketplace operator used to get there. The eligibility tests decide who can operate a marketplace or run their own distribution website. Notarization decides whether an individual app on that marketplace passes Apple’s review.
What Apple has not said
- Apple has not published the criteria a bank or letter of credit must meet to satisfy the requirement, beyond the USD 1,000,000 figure.
- Apple has not said how long a letter of credit must remain valid, or what happens if it lapses after a marketplace is already operating.
- Apple has not published a public list of marketplace operators that have qualified under any of the seven tests.
- Apple has not said whether Notarization review times differ for apps distributed through an alternative marketplace versus the App Store.
The eligibility rule takes effect alongside the rest of Apple’s new EU business terms on October 1, 2026. Developers weighing an alternative marketplace can review the full criteria on Apple’s developer support page now, three weeks ahead of the deadline. Our coverage of iOS 27 and the iPhone 18 Pro tracks the software and hardware these marketplaces would ultimately need to run on.
