- iOS 27.2 and iPadOS 27.2 bring an alternative App Tracking Transparency prompt to the EU. [1]
- In Germany, France, Italy, Poland, and Romania it is the only prompt apps can show. [1]
- When you must ask for permission does not change. [1]
- The sheet carries your own Markdown copy and an optional Additional Information button. [2][3]
- In the EU you can ask again one year after the user’s last answer, yes or no. [4]
- The German commitments allow up to 4,000 characters of explanation and a single consent covering both the ATT prompt and your consent platform. [5]
- They run for seven years under an independent monitoring trustee. [6]
For five years the most consequential consent screen in mobile advertising was a small system alert with a warning hand on it and a sentence or two of the publisher’s explanation. Apple wrote the frame. The publisher got a line. The German competition authority opened a case over that frame in 2022, arguing that the frame did the persuading, and in August Apple agreed to change it. [6][5]
On September 16, 2026, Apple told developers what that means in practice. Beginning with iOS 27.2 and iPadOS 27.2, apps can use an alternative version of the App Tracking Transparency prompt in the EU. [1] In five countries it is the only version available. [1] And in the same announcement, one sentence that decides most of what follows: the requirements for when you must seek permission to track users will remain the same. [1]
A system alert. One or two sentences of your purpose text, as Apple prescribed. A warning hand next to the question. [5]
Why these five countries
Apple’s announcement gives “legal requirements” as the reason and names Germany, France, Italy, Poland, and Romania. [1] The Bundeskartellamt fills in the rest. Besides its own case, it says, the competition authorities of France, Italy, Romania, and Poland have conducted or are still conducting separate proceedings on the framework, and they coordinated through the European Competition Network with the Commission involved. [5] Two of those ended in fines, and one ended in commitments that now bind Apple for seven years.
| Country | Authority | Where it stands |
|---|---|---|
| Germany | Bundeskartellamt | Commitments made binding, announced August 17, 2026, for seven years [6] |
| France | Autorité de la concurrence | Fined €150 million on March 31, 2025 [7] |
| Italy | Competition authority | Fined €98.6 million in 2025 [6] |
| Poland | Competition authority | Separate proceeding, conducted or ongoing [5] |
| Romania | Competition authority | Separate proceeding, conducted or ongoing [5] |
The French decision is the clearest statement of the complaint. The Autorité found that Apple abused its dominant position between April 2021 and July 2023: the framework’s implementation multiplied consent pop-ups until third-party apps became excessively complex to use, the rules for how those pop-ups interacted undermined its neutrality, and smaller publishers paid the most. [7] The German case made the same point about design. Its preliminary view was that the ATT prompt steered users toward refusing, while the prompt Apple uses for its own personalized ads steered them toward consenting, through the symbols, the wording, the space allowed to explain, and the order of the options. [5]
What Germany got in return is binding. Apple has four months from service of the decision to implement the changes, will test them with app publishers first, and is held to them for seven years under an independent monitoring trustee. [6] In Germany, the authority says, only the new ATT prompt and a correspondingly amended version of Apple’s own prompt will be shown. [5]
What the system actually shows, and where
The regional behavior is spelled out in Apple’s developer documentation, and it depends on two things at once: where the device is, and which country the Apple Account is set to. [2]
The new sheet, whatever you request. The system displays the Markdown text you supply in a full-page sheet regardless of the setting you pass, and adds an Additional Information button if you supply an action. [2] Without the Markdown key, it falls back to your ordinary purpose string. [3]
Your choice. The system displays your Markdown text if you supply it, shows the full-page sheet only if you ask for the expanded interface, and adds the Additional Information button if you supply an action. [2] You can keep the old alert, or run the new one and measure it against the five countries where it is mandatory.
Two details in that documentation will surprise product teams. Tapping Additional Information dismisses the sheet without recording an answer and runs your own code, so your app shows its explanation and then has to call the prompt again to get a decision. [2] And in the EU, once a person answers, the system will not show the prompt again for a year. After that you can ask once more, whether the earlier answer was yes or no, unless the person has switched off the setting that lets apps ask, which the EU build renames Allow Apps to Request to Link Your Activity Across Companies. [4][2]
One consent screen instead of two
The part of the German decision that changes the most work is not the design. It is the permission to stop asking twice. Until now, a publisher that needed consent under data protection law ran its own consent management platform and then showed Apple’s prompt on top of it, for partly identical requests. [5] The commitments give three ways out of that.
Combine them. Put the information your consent platform must show on its first layer into the prompt’s purpose text, and the granular settings behind the Additional Information button, so one Allow or Reject answers both. [5]
Show them separately, with a note. Keep your consent platform as it is and say in the prompt that the user already consented under data protection law. If they refused there, you may not show the prompt at all. [5]
Show them separately, as before. You still get the new layout and wording. [5]
Apple’s own guidance agrees with the direction and keeps the liability where it was. In the EU you can use the Additional Information button to surface more information and more granular consent controls to comply with local privacy laws, but anything you show there is entirely your responsibility, and you still cannot touch the advertising identifier until the user grants permission in the prompt. [4]
What to do before 27.2 ships
Start with the copy, because for the first time you have room for it and nobody else will write it. A purpose string that was one sentence can now be a short page, and the German authority’s point was precisely that publishers could not explain what personalized advertising pays for. [5] Write it the way the regulator asked for: accurate about what happens to the data, plain about what the user gets, and not a sales pitch, because the consent it produces is the consent you will have to defend.
Then measure it like the natural experiment it is. The same app, the same week, will show the new sheet in five countries and whatever you choose everywhere else in the EU. [2] Split your consent reporting by country and prompt version, count Additional Information taps, and leave the old alert running somewhere you can compare. If your measurement partner reports one blended EU rate, you will learn nothing from the most controlled change Apple has ever made to this screen.
Keep one sentence from the Bundeskartellamt taped to the dashboard. It is expressly not the authority’s aim to help achieve the highest possible levels of consent, only that users can make a free and informed decision. [6] If the rate barely moves, the remedy still worked. The number you can plan against is the one you measure yourself, in the five countries where Apple has already run the change for you.
Sources
- Apple Developer · Updates to App Tracking Transparency in the European UnionSeptember 16, 2026. The alternative prompt, iOS 27.2 and iPadOS 27.2, the five countries, and the unchanged requirement.
- Apple Developer Documentation · requestTrackingAuthorization(usingExpandedInterface:additionalInformationAction:completionHandler:)The behavior in the five countries, the rest of the EU, and outside it, and what happens when someone taps Additional Information.
- Apple Developer Documentation · NSUserTrackingMarkdownUsageDescriptionThe Markdown purpose string and its regional availability.
- Apple Developer · User Privacy and Data UseThe Additional Information button, the yearly re-prompt in the EU, the renamed setting, and the FAQ on combining the prompt with consent controls.
- Bundeskartellamt · Consent requests for the use of user data for advertising purposes in apps: FAQs (B7-54/25)The objections to the prompt design, the 4,000-character purpose string, the three consent options, and the other national proceedings.
- Bundeskartellamt · Apple changes its rules for personalised advertising in appsAugust 17, 2026. The binding commitments, four months to implement, seven years with a monitoring trustee, and the French and Italian fines.
- Autorité de la concurrence · Targeted advertising: the Autorité de la concurrence imposes a fine of €150,000,000 on AppleMarch 31, 2025. The abuse between April 2021 and July 2023 and the finding on neutrality.
Frequently asked questions
What is Apple changing in App Tracking Transparency?
The prompt, not the rule. Apple says that beginning with iOS 27.2 and iPadOS 27.2, developers can use an alternative version of the App Tracking Transparency system prompt in the EU, and that the requirements for when you must seek permission to track users will remain the same.
Which countries get the new prompt?
Apple says that due to legal requirements, only the alternative version is available for apps distributed in Germany, France, Italy, Poland, and Romania. Elsewhere in the EU developers can choose it. Apple’s documentation adds that the regional behavior depends on the device being located in the country and signed in with an Apple Account set to that country or region.
Why those five countries?
They are the countries whose competition authorities pursued Apple over the framework. The Bundeskartellamt says that besides its own proceeding, the competition authorities of France, Italy, Romania, and Poland have conducted or are still conducting separate proceedings on it. France fined Apple €150 million in March 2025, and the Bundeskartellamt puts Italy’s fine at €98.6 million.
What does the new prompt look like?
In the five countries the system shows your Markdown-formatted explanation in a full-page sheet and, if you supply an action, an Additional Information button. Under the German commitments the publisher’s explanation can run to 4,000 characters, where Apple’s prescribed standard was one to two sentences, and the warning hand symbol and the word tracking are removed.
Can I ask users again if they said no?
In the EU, yes, after a year. Apple says you can re-prompt a user one year after their previous choice, whether they accepted or rejected, unless they have turned off the system setting that lets apps ask. In the EU that setting is renamed Allow Apps to Request to Link Your Activity Across Companies.
Can I combine the ATT prompt with my consent management platform?
Under the German commitments, yes. The Bundeskartellamt describes three options: combine your consent request with the new prompt so one Allow or Reject covers both, show them separately with a note in the prompt that consent was already given, or keep them separate as before. Apple’s FAQ adds that the Additional Information button can surface more granular consent controls to comply with EU privacy law.
Will opt-in rates go up?
Nobody has published a measured answer. Apple’s announcement gives no estimate, and the Bundeskartellamt says it is expressly not its aim to achieve the highest possible level of consent, only that users can decide freely. Treat the five countries as a test you run and measure, not a lift you can book.
Mikołaj Salecki
Writes about media, tech, and AI business for people who actually run digital. Former agency lead. Skeptic of frameworks that read better than they perform.
