Small UK firms developing payment apps, digital keys or loyalty services have a new opportunity to explain what they need from iPhone contactless access. The Competition and Markets Authority has published detailed proposals and is inviting responses until 17 November 2026.
The CMA announcement concerns near field communication, usually shortened to NFC: the technology behind many tap-to-pay and other short-range phone interactions. For a small developer, the immediate task is to assess the proposals and gather evidence about costs and technical barriers.
What has changed since June?
This is a new stage in a longer investigation. BritishSME’s June coverage of app-store payment proposals also described an earlier call for evidence on NFC. The regulator has now moved to consulting on a specific proposed contactless access requirement. App-store steering and access to the phone’s contactless technology remain separate issues.
The Apple mobile-platform case page records that progression from the June evidence exercise to the 20 October consultation. A final decision on the new proposals will follow assessment of responses. Businesses should keep that distinction in mind when planning products or discussing availability with customers.
Access and price both matter
The CMA proposes giving developers access through both main international approaches to contactless technology, known as secure element and host-based card emulation. Apple currently offers only the secure-element approach in the UK. Providing both could give developers more choice about how to build their services.
Potential uses extend beyond payments to digital identity, travel passes, loyalty schemes and keys for cars, hotels or workplaces. These are possibilities the regulator identifies, rather than a list of products newly available today.
The CMA also wants access to work commercially. It proposes pricing principles rather than setting a particular price, and expects substantially lower access charges than Apple’s current fees. That expectation concerns developers’ access to the technology; it does not establish a reduction in a shop’s card-processing bill.
Turn experience into useful evidence
A small software business considering a response can start with one real product or abandoned idea. Explain what the service would do, which customers it would serve and where existing access arrangements have affected development. Concrete examples will make the business impact easier to assess than a general request for cheaper technology.
Separate the technical questions from the commercial ones. Record the functionality needed, any differences between markets, the charges relevant to the proposed service and the assumptions behind its forecast. Label estimates clearly, and explain where a cost or restriction changes whether the product could be viable.
Include the work involved for a small team: development time, testing, customer support and the cost of maintaining different versions. Where an idea was shelved, explain which obstacle stopped it. Keep supporting records so the response can distinguish a documented problem from a concern about what might happen.
The consultation page says an Apple non-disclosure agreement should not prevent a response. The detailed document asks businesses to mark confidential information clearly and provide a version that can be published. Responses can go through its consultation portal or to mobilesms@cma.gov.uk by 5pm on 17 November 2026.
Keep customer promises tied to confirmed terms
For retailers and hospitality firms buying payment or loyalty tools, a useful next step is to ask suppliers which features are available under existing arrangements and which depend on future decisions. Keep those answers alongside the contract, pricing and support details when comparing services.
Developers can use the consultation period to test their assumptions and prepare a response by 17 November. Build any proposed future access or pricing into a separate planning scenario. A published proposal is useful evidence of the regulator’s direction, but product commitments still need confirmed access conditions and a workable delivery timetable.
