Apple has updated its developer license agreement to allow the company to recover unpaid commissions and fees by deducting funds directly from app revenue it processes on behalf of developers. The changes, published on December 17, 2025, affect how Apple enforces payment compliance across in-app purchases, subscriptions, and paid app downloads, with implications for developers operating in multiple jurisdictions.
How Apple Will Recover Unpaid Fees
Under the revised agreement, Apple states it may “offset or recoup” any outstanding amounts it believes are owed, including funds collected from end users through Apple’s in-app purchase system. This means that if Apple determines a developer has underpaid commissions or fees, it can deduct those amounts directly from future revenues without requiring separate invoicing or additional authorization.
The policy applies broadly to revenue streams, including one-time app purchases, recurring subscriptions, and payments for digital goods and services. The agreement also notes that Apple can take these actions “at any time” and “from time to time,” giving the company discretion over when and how deductions are made.
Notably, the updated terms do not outline a detailed methodology for how Apple will assess whether a developer has misreported or underpaid what is owed, leaving questions about transparency and dispute resolution.
Impact on Apps Using External Payment Systems
The changes are most relevant in markets where developers are permitted to link to external payment systems due to local regulations. These include the European Union, the United States, and Japan. In such regions, developers who use alternative payment options are still required to report earnings to Apple so the company can collect applicable commissions.
The revised agreement provides Apple with a direct mechanism to recover what it considers the correct fee if it believes a developer has underreported revenue generated outside of Apple’s payment infrastructure. This comes as legal debates continue, particularly in the U.S., over the scope of commissions Apple is allowed to collect. A recent federal appeals court ruling sent aspects of this issue back to a lower court for reconsideration, underscoring the ongoing uncertainty around enforcement boundaries.
Extended Liability Across Corporate Structures
Another significant update expands financial liability beyond a single developer account. Apple now reserves the right to collect unpaid amounts from affiliates, parent companies, or subsidiaries associated with the account in debt. In practical terms, this means Apple could deduct funds from other apps owned by the same developer group or from applications published under a related corporate entity.
These provisions are detailed in Schedules 2 and 3, section 3.4 of the updated agreement, and reflect a broader approach to ensuring fee recovery across complex corporate structures.
EU Fee Changes: From CTF to CTC
For developers operating in the European Union, the agreement also reiterates upcoming changes to Apple’s fee framework. The current Core Technology Fee (CTF), which charges €0.50 per first annual install beyond one million, is set to be replaced in January 2026.
The new model, known as the Core Technology Commission (CTC), will shift to a percentage-based fee. It will apply to apps distributed under alternative business terms or those using external payment methods in the EU, aligning Apple’s fee structure more closely with revenue performance rather than download volume.
Privacy and AI-Related Policy Updates
Beyond financial terms, the updated agreement introduces new rules affecting AI and privacy. Apple has added requirements for voice-based assistants and AI chatbots that can be activated via the iPhone’s side button, signaling closer scrutiny of how such tools integrate with core device functions.
The policy also explicitly bans applications designed to facilitate recordings made without user awareness. This restriction applies to audio, video, and screen recordings, including tools commonly used by developers for debugging, user testing, or interface analysis. Developers will need to ensure their apps clearly notify users and comply with consent requirements when any form of recording is involved.
Apple did not respond to requests for comment prior to the publication of the updated agreement.
What Comes Next for Developers
The revised terms reinforce Apple’s ability to enforce compliance through direct control of app revenue flows, particularly as alternative payment options become more common. For developers, the changes highlight the importance of accurate reporting, internal compliance checks, and a clear understanding of regional fee obligations.
As regulatory scrutiny continues in the U.S. and Europe, and as new fee models like the Core Technology Commission come into effect, developers may face a more complex financial and legal landscape when operating within Apple’s ecosystem.
