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On March 13, 2024, Epic Games asked a federal judge to hold Apple in civil contempt, arguing that Apple had formally allowed U.S. App Store developers to link customers to outside purchases but made that option costly and cumbersome. Epic pointed to a commission of up to 27% on some linked-out purchases, along with limits on link design and a warning screen. Apple said its January 2024 changes complied with the court’s order and defended its rules as safeguards for its platform and users.
The dispute has since moved beyond allegations: a district court found Apple in civil contempt in 2025, and the Ninth Circuit affirmed the core finding that Apple’s 27% commission and restrictions could make external purchasing prohibitively difficult in context. The Supreme Court agreed to hear a limited part of Apple’s appeal in June 2026; as of August 16, 2026, it had not decided the merits.
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What Epic asked the court to do
Epic’s March 2024 filing was a request for enforcement, not a new lawsuit asking the court to design an App Store payment system from scratch. Epic asked the U.S. District Court for the Northern District of California to find that Apple had violated the existing anti-steering injunction, hold Apple in civil contempt, and require Apple to change rules that Epic said continued to block meaningful steering to outside purchasing options. The motion challenged Apple’s implementation of the injunction, including provisions associated with App Store Review Guideline 3.1.3.
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What the 2021 injunction required—and what it did not
After Epic sued Apple in 2020, the district court issued an anti-steering injunction in September 2021. It barred Apple from prohibiting developers from including buttons, external links, or other calls to action in apps or app metadata that direct customers to purchasing mechanisms outside Apple’s in-app purchase system. It also addressed developers’ ability to communicate with customers using contact information customers voluntarily provided through account registration. The Ninth Circuit affirmed the injunction in 2023 and later described its scope in its 2025 opinion.
The order did not require Apple to abandon in-app purchases or make all external transactions commission-free. The underlying case largely favored Apple on Epic’s broader antitrust claims; Epic’s relevant relief came under California’s Unfair Competition Law and concerned anti-steering restrictions. That distinction matters: this was not a ruling that Apple’s entire App Store payment model was unlawful.
What Apple changed in January 2024
Apple said it had complied with the injunction as of January 16, 2024, by changing U.S. App Store rules to let developers include buttons or links directing users to alternative purchasing mechanisms and to communicate with customers about those options. But permission to link came with conditions.
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Under the structure reported at the time, developers outside Apple’s Small Business Program could owe Apple a 27% commission on certain purchases made outside an app after a user followed a link. Qualifying Small Business Program developers were described as subject to a 12% rate. The terms also included a seven-day attribution period for some linked-out purchases. These were not universal rates for every developer or every transaction: the applicable terms depended on the developer and the arrangement. Apple’s rules also constrained the appearance and placement of links, required a plain-button style, displayed a warning when users left Apple’s purchasing environment, restricted dynamic links that could lead to a particular product or logged-in account, and required a general landing page rather than a more direct product-specific checkout route. The details are described in contemporary coverage of Apple’s changes and Apple’s later Supreme Court filing.
Epic argued that the combined effect mattered more than the existence of a link. A developer considering external checkout would still have to account for Apple’s linked-out commission, a payment processor’s fees, and the costs of fraud handling, refunds, tax, customer support, and commerce operations. Sending a customer out of an app can also lead to abandonment. A warning screen, generic landing page, and less prominent link can add more friction. So even a lower nominal commission would not automatically mean a developer or customer saved money.
The finance question is therefore not answered by comparing two headline commission percentages alone. The outcome depends on the Apple rate that applies, payment-processing and operating costs, tax and refund treatment, and how many customers complete a purchase after leaving the app. The dispute did not establish one universal savings calculation.
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Apple’s defense: compliance, costs, and user protections
Apple’s position was more specific than simply denying the injunction. It argued that it had complied with the order’s text by allowing external links and calls to action, and that the injunction did not expressly bar Apple from charging a commission on purchases completed outside the App Store. Apple also argued that fees could compensate it for platform technology, intellectual property, developer tools, review, distribution, and related services.
Apple further defended its restrictions as ways to address security, privacy, fraud, deceptive interfaces, and user confusion. It said an unrestricted external-link system could make Apple’s own in-app purchase option effectively invisible or expose users to risks. The legal question was not whether a platform may have any user-protection rules or charge any fee. It was whether particular rules and fees crossed the line from implementation safeguards into barriers that defeated the injunction.
What civil contempt means
Epic sought civil contempt, which is generally used to compel compliance with a court order or compensate for noncompliance. It is different from criminal contempt, which is punitive and involves different procedures. The district court’s later order also referred Apple for possible criminal investigation, but the Ninth Circuit’s December 2025 decision chiefly addressed civil contempt and sanctions. A contempt finding does not by itself mean that every restriction Apple adopted was unlawful or that all fees had to disappear.
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How the courts assessed Apple’s rules
In April 2025, the district court found Apple in civil contempt and imposed sanctions. On December 11, 2025, the Ninth Circuit affirmed the core contempt finding, concluding that clear and convincing evidence supported it. The appeals court held that Apple’s 27% commission was effectively prohibitive in context and that Apple’s link-design restrictions prevented or severely hindered meaningful external purchasing. Some restrictions also conflicted with the injunction’s wording; others violated its implicit command not to take steps designed to defeat the relief the court had ordered.
The appellate decision was mixed, rather than a blanket victory for either side. The Ninth Circuit left room for Apple to retain some restrictions—for example, a limit preventing a developer’s external option from being more prominent than Apple’s payment option when both were offered—and to enforce generally applicable content standards. It also found that the district court’s blanket prohibition on commissions for linked-out transactions was overbroad in its existing form. The district court must consider a properly tailored fee or commission structure.
The Ninth Circuit indicated that a permissible fee should be tied to genuinely and reasonably necessary costs of coordinating external links and should account for relevant intellectual-property use. It should not simply fold in costs of security and privacy features associated with Apple’s own in-app payment system. The result is not “Apple can charge anything” or “Apple can never charge a fee”; the court left open a narrower fee framework while finding the challenged approach prohibitive.
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Supreme Court review is still pending
Apple is now the petitioner in Apple Inc. v. Epic Games, Inc., No. 25-1311. The Supreme Court granted Apple’s petition on June 30, 2026, limited to Question 1. After the Court denied Apple’s request for an administrative stay of district-court proceedings on August 13, 2026, the docket still showed the case proceeding to merits briefing, with Apple’s brief due September 14 and Epic’s due November 13. As of August 16, 2026, the Supreme Court had not upheld or overturned the contempt finding on the merits. Its docket is the source for the current procedural status.
What the dispute means for developers and customers
For developers, an external-payment link is not necessarily a simple way to avoid an App Store commission. Developers have to weigh any Apple fee against payment processing, fraud, refunds, taxes, support, checkout operations, and the possible loss of customers who do not complete a purchase after leaving the app. The 2025 appellate ruling says a fee can be permissible in principle, but not if its practical effect is to prohibit or severely hinder the external option protected by the injunction.
For customers, the dispute concerns both choice and friction. A link can offer a route to another purchasing mechanism, but a warning, generic destination, or extra checkout steps may make that route less useful. Whether an outside purchase is cheaper is a separate question; the legal rulings do not guarantee a lower price or savings for every buyer.
The injunction and this contempt dispute concern the U.S. iOS and iPadOS App Store storefronts. They should not be treated as a worldwide rule. Apple’s current App Review Guidelines distinguish among storefronts and entitlement categories, and other places—including the European Union and Japan—have separate rules and legal regimes. Exceptions for types of apps and transactions can also matter.
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