Google’s August 19, 2025 proposal would give developers more ways to direct European users to offers outside Google Play and revise the fees attached to those transactions. It did not make external checkout unrestricted or fee-free. As of August 2026, Google’s later rules are in effect in stages: the relevant programs still require enrollment, technical integration and disclosures, and Google’s expanded fee and billing-choice rollout began June 30, 2026.
What Google proposed in August 2025
Google proposed changes to its External Offers Program for developers serving users in the European Economic Area (EEA). The announcement followed European Commission scrutiny of Play Store rules under the Digital Markets Act (DMA). The proposal had two central parts: more ways to steer users to external offers, and a revised model for fees and Play services. The announcement was a proposal, not proof that the Commission had approved every detail or that the same terms would remain current.
Under the proposal, developers would have greater flexibility to link users from an app to an external destination to view an offer or make a purchase. Later changes also enabled links to approved app downloads. Google described a tiered approach to services: a basic tier with functions such as app listings, ratings, compliance information, security scanning, developer verification, content ratings and data-safety information; and an enhanced tier with additional discovery and merchandising, including broader search, recommendations, editorial surfaces and enhanced listings. Contemporary reporting described a lower, shorter initial-acquisition charge and separate ongoing-service tiers, rather than the earlier roughly 10% external-transaction charge. Those 2025 descriptions are not a current fee schedule. Read the August 2025 proposal coverage.
Why the European Commission challenged Google Play
The Commission’s preliminary concern was that Google’s rules did not let developers effectively steer users to offers, payment systems or distribution channels of their choice, as required by the DMA. It also questioned whether Google’s fees were justified when they continued to apply to digital purchases over an extended period after Google had helped a developer acquire a customer. These were preliminary regulatory findings, not a statement that Google’s later implementation had been finally approved. Read the European Commission document.
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Three concepts matter because the rules for them differ:
- Steering: telling or linking users to an offer outside the app.
- Alternative billing: letting users pay inside the app through a system other than Google Play Billing.
- External offers or distribution: sending users outside the app to complete a purchase or, under a separate approved flow, download an app.
Google had EEA alternative-billing options before the 2025 proposal. The company announced DMA-related policy changes in March 2024, and developers offering EEA alternative billing were required to use Google’s APIs from March 13, 2024. Google’s March 2024 policy announcement and alternative-billing requirements explain that earlier framework.
What applies now, and where
Google’s external-offers program is for EEA users, not all of Europe and not all Play Store markets. It covers Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden. The user’s location is the relevant scope: a developer based outside the EEA may serve covered users, while an EEA developer does not thereby bring US or Canadian users into the EEA program. Google’s current EEA program requirements list the scope.
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Google’s documentation says developers must enroll before promoting external offers. Participation does not amount to permission to place any payment link in any app. Depending on the flow, developers must satisfy eligibility and policy rules, integrate Google’s required APIs, provide prescribed disclosures, use permitted destinations, report qualifying activity and pay applicable fees. Developers also handle customer support and refunds for purchases completed outside Play. The practical requirements and transition dates are set out in Google’s EEA external-offers changes and program documentation.
External app downloads are a separate, controlled flow
Google says updated APIs for linking EEA users to app downloads became available in December 2025. Developers must enroll, select a service tier, integrate the APIs and obtain approval for linked downloads. Google reviews linked apps for compliance with applicable Play Developer Policies, though its documentation identifies policies such as Payments that do not apply to those linked apps. This is not unrestricted sideloading from any website; the link, destination and app remain subject to Google’s process.
Existing participants had migration deadlines
Google’s documentation gave developers already enrolled before August 19, 2025, until November 30, 2025, for a transition cited in the external-offers rules. It also lists January 28, 2026, as a deadline for certain previously enrolled developers to adopt updated purchase-link requirements. Applicability depends on the developer’s existing program and flow, so participants should verify their status against the current Play Console and policy documentation rather than assume older integration remains sufficient.
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External offers and alternative billing are not interchangeable
| Feature | External offers | Alternative billing |
|---|---|---|
| Where payment happens | Outside the app, at an external destination | Inside the app, through a non-Play payment system |
| Main purpose | Steer users to an external offer or checkout | Replace Google Play Billing for an in-app payment |
| Enrollment and technical requirements | Enrollment and applicable link/API, disclosure and reporting rules | Enrollment and applicable alternative-billing API and program rules |
| Google fees | Applicable service fees remain | Applicable service fees remain |
| Can it be combined with Play Billing? | Google says external-offer links cannot be combined with Google Play Billing or User Choice Billing in the applicable flow; developers must use the alternative-billing-without-user-choice framework | Combination depends on the specific billing program; do not infer permission from the external-offers rules |
| Distinct operational work | External checkout, customer support, refunds, reporting and link compliance | In-app payment integration and payment operations |
Google’s current external-offers documentation says developers using those links may not combine them with Google Play Billing or User Choice Billing in the applicable flow. They must enroll in and comply with the alternative-billing-without-user-choice framework instead. This is why an app cannot assume it may simply show a Play payment button beside a website-checkout button under the external-offers program. Check Google’s current rules for the exact program and transition status.
How the fees changed—and why one percentage is misleading
The 2025 announcement discussed a revised initial-acquisition charge and ongoing service tiers. By 2026, Google’s documentation described a more detailed model with initial-acquisition and ongoing-service fees, different treatment for subscriptions and other digital offers, and terms affected by whether the user is a new or existing install, which program is selected and whether Play Billing remains involved. Google says the first phase of its expanded billing-choice and new service-fee rollout in the EEA, United Kingdom and United States began June 30, 2026. The headline proposal’s fee descriptions should therefore not be quoted as the rates a developer pays today.
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| Fee or policy element | What the current documentation establishes | What to verify before implementation |
|---|---|---|
| Initial-acquisition fee | Part of Google’s current EEA fee model; the applicable charge depends on the program and transaction circumstances. | Rate, qualifying acquisition window and treatment for the app’s user/install status in the live terms. |
| Ongoing-service fee | Part of the current model; service tier and transaction type affect the terms. | Selected tier and whether a transaction is a subscription or another digital purchase. |
| Google Play Billing | Google’s rollout documentation gives a 5% billing fee in the EEA when Play Billing is used under the new model. | That rate’s applicable rollout, program and transaction conditions; it is not a universal commission for all external offers. |
| Apps Experience or Games Level Up | Google says designated programs may offer lower service-fee rates. | Eligibility, enrollment and the exact rate for the relevant app or game. |
| External app downloads | Different terms apply from purchase transactions. | Applicable service tier, linked-download approval and current fee terms. |
Google’s help pages do not support reducing the current policy to “the fee is X%” for every developer. The rate can turn on geography, rollout, install status, transaction type, billing method and program participation. In particular, the 5% billing fee stated for use of Google Play Billing under the new EEA model is not the total service fee for every external transaction. Use Google’s rollout and lower-service-fee documentation, EEA conditions and external-offers requirements for the applicable current terms.
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Google’s stated case for retaining fees is that Play provides services such as security scanning, updates, app verification and discovery. That is Google’s rationale for its service model, not an independently established valuation of those services. Developers should compare the full cost of external checkout—not just Google’s fee—with Play Billing’s operational convenience.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What the changes could mean for users
External links can give users more visibility into a developer’s offers and a choice of payment destination. A developer may offer a lower price outside Play if its costs allow, but the rules do not require it to pass savings to customers. Any reduction depends on the developer’s pricing decisions and its costs for payment processing, taxes, fraud, support and engineering.
A purchase made on a developer’s site may use different refund, dispute, parental-control and fraud-support processes from a Play purchase. Users should check who takes payment, how subscriptions renew and cancel, what refund terms apply, and which company handles account or billing problems. External app downloads introduce additional security and update considerations; Google’s approval controls do not make every external destination equivalent to an app installed through Play.
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Google has also explained its concern that external flows may weaken user protections. That is the company’s stated position, and users should assess the actual safeguards and support offered by the developer and payment provider rather than assume either that external checkout is unsafe or that it carries the same protections as Play.
Who should consider external checkout?
External offers may be worth evaluating for a subscription business or digital-goods seller with substantial EEA revenue, an established web checkout and the staff or providers to manage payment operations. The decision is less attractive if the likely savings are small, users are likely to abandon a flow that leaves the app, or the developer relies heavily on Play discovery and merchandising.
- Existing web-commerce operation: Compare the marginal integration and support cost against applicable Play fees and any conversion loss from sending users out of the app.
- Small publisher or modest EEA sales: Play Billing may remain simpler if a separate checkout, tax handling, fraud controls, refunds and reporting would cost more than the potential savings.
- Subscription app or game with multiple payment channels: Account for entitlement synchronization, renewals, cancellations and customer support across channels; Google’s lower-rate programs may have eligibility conditions.
- Developer without payment infrastructure: Decide whether the business needs a processor, a merchant of record or subscription-management software, and assess their cost and operational fit. None removes Google’s own program requirements or fees.
- Physical goods seller: Do not assume the digital-goods external-offers framework governs every physical-commerce transaction; confirm the applicable Play Payments policy.
Pricing parity is another separate issue: Google’s EEA documentation addresses contractual restrictions on offering different prices or conditions through other channels. That question is distinct from whether an app can steer users to an external offer. See Google’s EEA distribution and parity-clause explanation.
What developers and users should watch next
The rules have moved beyond Google’s August 2025 proposal, but the proposal itself did not settle the DMA compliance question. Developers implementing a flow should rely on the current Play Console enrollment, API and fee terms for their market and transaction type; the Commission’s oversight remains relevant to whether the implementation meets the DMA. Users should treat “pay outside Google Play” as a change in who processes the transaction, not as a guarantee of a lower price or identical refund and support arrangements.
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