On 20 October 2026, the Competition and Markets Authority (CMA) announced proposals to require Apple to open up access to contactless technology on its iPhones, potentially encouraging greater competition and innovation in digital payments and other services.
The proposals represent the latest in a growing series of interventions under the CMA's digital markets competition regime. However, its express identification of digital IDs as a potential beneficiary raises interesting questions about the role of an independent competition and consumer protection regulator, particularly where the use of the technologies being promoted (even subtly) are themselves controversial.
What is the CMA proposing?
The CMA is concerned that Apple's fees, technical restrictions and contractual terms for accessing Near Field Communication (NFC) technology, which enables contactless interactions between iPhones and compatible devices, may prevent competitors from developing commercially viable services.
It is therefore proposing some key interventions:
Wider technical access | Apple would be required to support both Secure Element (SE) and Host-based Card Emulation (HCE) technology, giving competitors greater flexibility. |
Lower access fees | Principles governing access charges, expected to result in substantially lower fees whilst fairly remunerating Apple. |
Fairer access terms | Commercial arrangements intended to enable businesses to develop viable competing services. |
The potential impact is significant. More than 60% of UK adults use a digital wallet, with Apple Wallet being the most popular. Yet, unlike in the EU, no competing wallet-type product has been launched on the iPhone in the UK.
The CMA considers that removing these barriers could encourage innovation, market entry and consumer choice.
Digital IDs: is the CMA presupposing their desirability?
Perhaps the most striking aspect of the announcement is the CMA's express identification of digital IDs and age-verification tools as potential beneficiaries of its intervention.
This is particularly noteworthy given the significant public opposition to the Government's digital ID proposals. A parliamentary petition opposing the introduction of digital ID cards attracted almost three million signatures, making it one of the most-signed petitions in UK parliamentary history.
Importantly, concerns extend beyond mandatory digital ID schemes. Civil liberties organisation Big Brother Watch has warned that even ostensibly voluntary digital identification could become effectively compulsory as businesses and public services increasingly require it for everyday activities, potentially excluding those who cannot or do not wish to use it.
Against that backdrop, is the CMA, by presenting digital IDs as an example of the innovation its intervention could unlock, implicitly presupposing that their wider adoption is wanted or desirable?
The CMA is, after all, an independent competition and consumer protection regulator, not a body tasked with promoting particular government policy objectives.
Of course, facilitating competition in contactless technology is not the same as endorsing digital identification. Nor does the CMA's proposal itself require anyone to adopt digital IDs. Nevertheless, there is an important distinction between removing barriers to competition and presenting the proliferation of a politically contentious technology as an inherently positive outcome. Indeed, greater availability and convenience could contribute to the gradual normalisation of digital identification, even where its use remains formally voluntary. Whether that is desirable raises wider questions about privacy, individual freedoms and the preservation of meaningful non-digital alternatives, which cannot be answered by competition considerations alone.
An increasingly interventionist regulator
The CMA's digital markets competition regime, introduced under the Digital Markets, Competition and Consumers Act 2024 (DMCCA) in January 2025, enables it to designate businesses as having Strategic Market Status (SMS) and impose targeted conduct requirements without first establishing an infringement of traditional competition law prohibitions.
The CMA has already used these powers in relation to Google Search and pursued interventions concerning app stores and mobile payments. The Apple proposals therefore form part of an established pattern of increasingly targeted intervention. Such intervention includes access to technology as well as ensuring that the associated fees and restrictions do not make effective competition commercially unviable.
However, as the CMA's interventions increasingly influence the development and availability of important technologies, questions about regulatory independence, priorities and wider consumer interests become more significant.
Key takeaways: is greater choice always better?
There is a clear competition law rationale for opening up access to Apple's contactless technology. Removing barriers to entry could encourage innovation and greater consumer choice. However, the express reference to digital IDs raises questions about whether a regulator should present the development of a particular technology facing substantial public opposition as an example of an inherently positive outcome without acknowledging the wider debate surrounding its adoption.
The concern is particularly relevant where increased availability of digital identification could, over time, contribute to its widespread adoption in circumstances where meaningful non-digital alternatives become less accessible. After all, greater competition between digital services does not necessarily equate to greater consumer choice if consumers ultimately have less freedom to opt out of using those services altogether.
The consultation closes on 17 November 2026.
