Japan Gets Options. China Gets the Wall.

Across major markets, Apple is forced to loosen the rules. In China, it still defends the strictest lock-in—keeping developers trapped and consumers paying more.

Yesterday/December 18, Apple rolled out a Japan-only set of iOS and App Store changes—opening doors it has long kept shut elsewhere. Under Japan’s Mobile Software Competition Act (MSCA), Apple says developers can now choose how to take payment for digital goods and services (including using alternative payment providers inside apps), point users to a website to complete a purchase, and distribute apps via alternative marketplaces rather than relying exclusively on the App Store.¹

Apple’s message to Japanese users is familiar: more openness, it warns, can mean more risk—malware, fraud, scams—and Apple will try to manage that risk through guardrails such as “notarization,” automated checks, and human review. Apple’s message to everyone else is even clearer. Apple said it “doesn’t have plans to bring these changes to other countries”, arguing its existing system strikes the best balance between safety and opportunity.

That creates an awkward contrast with China—one of Apple’s most consequential markets—where the “Apple tax” debate is no longer a niche developer complaint but increasingly a legal and regulatory story.

In Shanghai, a consumer antitrust suit widely described in Chinese media as a landmark “Apple tax” case has moved through first-instance proceedings and into appeal, with courts and commentators scrutinizing how Apple’s App Store rules shape competition.² And in October, 55 Chinese iPhone users filed³ an antitrust complaint with China’s top market regulator, arguing that Apple’s App Store practices restrict competition and effectively force users into paying up to a 30% commission through Apple-controlled rules.

Put simply: in Japan, Apple is now building a regulated pathway for competition inside iOS. In China, Apple is still trying to preserve a model defined by two core controls—how apps are distributed, and how digital purchases are paid for.

The two controls behind the “Apple tax”

Most public arguments about the “Apple tax” focus on a headline number—30%. But the frustration in many markets, including China, has always been about two linked constraints.

First is pricing power. Apple’s standard App Store commission for many digital goods and services is between 15%–30% depending on the developer’s program status and business model.⁴ Developers argue that the commission is often passed on to consumers, raising effective prices inside apps.

Second is routing power: Apple’s rules have historically restricted developers from placing buttons, links, or other calls-to-action that steer users to external purchase mechanisms for digital content—i.e., the ability to say: “Buy on our website.” Apple’s own App Review Guidelines and subsequent updates make clear that such allowances can be jurisdiction-specific and policy-tied, rather than a global default.⁵

Together, those controls help explain why the debate keeps returning even when Apple offers partial discounts. A lower rate matters—but so does the ability to route transactions outside Apple’s rails.

Japan shows Apple can engineer “openness with conditions”

Japan’s MSCA now forces the debate onto Apple’s preferred terrain: compliance design. Apple’s response is not simply to “allow everything.” Rather, it is to create an architecture where competition is permitted, but on terms Apple can monitor: approved alternative marketplaces, security checks, and a menu of payment paths.⁶

Crucially, Japan’s package demonstrates that Apple can operationalize alternative payments and alternative distribution without abandoning its safety narrative. Apple may dislike that trade-off, but Japan is now a live example of Apple building exactly what it often claims is impossible: an iPhone ecosystem that is more open, yet still governed.

For Chinese readers, the obvious question is: if Apple can do it for Japan, why is China treated as an exception?

Apple’s annual reporting underscores why the China question matters. In its latest 2025 Form 10-K⁷, Apple lists net sales by geographic segment, including Japan and “Greater China.” Japan remains a major segment, but smaller than Greater China in that fiscal year.

So the explanation cannot simply be market insignificance. China is large enough to matter—and contentious enough to attract legal scrutiny.

The China story is moving from opinion to procedure

China now has at least two parallel tracks that can anchor a serious, evidence-based discussion.

One is litigation. A Shanghai case, as a milestone in domestic “Apple tax” antitrust litigation, has reached China’s Supreme People’s Court where Apple is appealing aspects of the first-instance outcome.⁸ Whatever one thinks of the merits, the procedural fact itself is meaningful: Chinese courts are being asked to translate “platform commission” grievances into competition-law questions—market definition, dominance, exclusionary conduct, consumer harm.

The other is administrative oversight. A 55-consumer antitrust complaint points directly at the core competitive claim: that Apple’s rules restrict choice and impose a de facto mandatory commission.⁹ In China’s regulatory ecosystem, such a widely-reported filing can become a focal point for broader scrutiny—especially when other jurisdictions are openly reshaping Apple’s rules.

Apple’s selective flexibility: the Tencent precedent

Apple’s defenders might argue that China already gets “flexibility” through negotiation. Pei Li at Bloomberg exclusively reported¹⁰ in November that Apple reached a deal with Tencent under which Apple would handle payments for purchases in WeChat mini games and mini apps and take a 15% cut—well below the oft-cited 30%.

But that episode, if anything, sharpens the equity concern. It suggests that Apple’s “openness” is not a uniform policy principle; it is something Apple can grant through leverage and bespoke arrangements—typically to the largest counterparties. For the long tail of Chinese developers, the baseline remains Apple-set rules, Apple-approved paths, and limited ability to route around Apple’s payment layer.

That is not a stable foundation for a competitive digital economy—especially one that aspires to global scale.

“International practice” is no longer on Apple’s side

For years, Apple could plausibly claim that its model was consistent across major markets. That argument is steadily collapsing.

In Europe, the European Commission has moved from antitrust theory to large-ticket enforcement. In 2024, it fined¹¹ Apple over its App Store rules affecting music streaming providers—an “anti-steering” story at its core. In 2025, the Commission found¹² Apple in breach of the DMA’s anti-steering obligation and imposed another major fine, while Apple’s revised fee structures continue to draw criticism from developer and consumer coalitions.¹³

In the United States, a court-driven opening forced Apple to loosen restrictions on external links and calls-to-action in the U.S. storefront, though the latest appellate ruling leaves room for “reasonable” Apple fees rather than a blanket ban.¹⁴

In Japan, as of this week, Apple has implemented perhaps the most comprehensive “choice bundle” yet: alternative app stores, alternative payments, and easier defaults for browsers and search engines—while explicitly warning of risks and building compensating controls.

In other words, in Apple’s biggest rule-making arenas, pressure is producing movement. The center of gravity is shifting toward more choice.

Which brings the China question back into focus: why should Chinese developers and consumers be asked to accept a harder line than Japan, a looser line than the U.S., and a more contentious fee-and-compliance maze than Europe?

A restrained conclusion: what “alignment” could look like in China

A serious China discussion does not require slogans. It requires asking what a credible alignment with emerging international practice would mean.

It could start with the narrowest, least disruptive step: allow developers of digital goods and services to inform users—clearly, transparently—of alternative purchase options outside the app, without punitive consequences or retaliation in review. Europe’s enforcement actions show why this matters; Japan’s MSCA-driven updates show Apple can put guardrails around it.

Next, China could explore regulated alternative payment options inside apps, with clear consumer-protection and data-security requirements—again, something Apple is now doing in Japan under law. The point is not to abolish Apple’s system, but to end exclusivity.

Finally, if alternative distribution (third-party marketplaces) is viewed as a bridge too far for China’s near-term policy preferences, the debate can still progress meaningfully on payments and steering—the parts of the “Apple tax” that most directly touch consumer prices and developer margins.

via Shutterstock

While Japan has moved decisively to dismantle the “Apple tax” regime in Asia, China continues to stand out as the market with the highest Apple levies and the strictest platform controls worldwide.

Apple will argue that its closed model is safer. But Japan—one of the world’s most security-sensitive and rules-heavy markets—has now compelled Apple to prove that “more open” does not have to mean “unsafe.” China should not have to settle for less choice than Japan simply because Apple prefers it that way.

If Apple can redesign iOS for Tokyo, it can redesign its China posture with a timetable. The only remaining question is whether it will do so voluntarily—or wait for a court or a regulator to write the prompt.

1. Bloomberg, Dec 18, 2025, “Apple Makes Changes to iOS Software in Face of Stricter Japanese Rules” https://www.bloomberg.com/news/articles/2025-12-18/apple-aapl-makes-changes-to-ios-software-in-face-of-stricter-japanese-rules

2. 21世纪经济报道, Jul 4, 2024, “‘苹果税’中国反垄断第一案落锤后 苹果提起上诉 …” https://m.21jingji.com/article/20240704/herald/753f42a1568c51b652b8a72516b59e18.html

3. Reuters, October 20, 2025, China Consumers File Antitrust Complaint Against Apple over App Store Practices https://www.reuters.com/sustainability/boards-policy-regulation/china-consumers-file-antitrust-complaint-against-apple-over-app-store-practices-2025-10-20/

4. AP, Dec 2025, “Appeals court backs contempt finding against Apple, but reopens a door for iPhone app fees” https://apnews.com/article/307885f7c9677a6d2de632df4046aa58

5. Apple Developer, “App Review Guidelines” https://developer.apple.com/app-store/review/guidelines/

6. Reuters, Dec 18, 2025, “Apple opens iPhones in Japan to alternative app stores” https://www.reuters.com/technology/apple-opens-iphones-japan-alternative-app-stores-2025-12-18/

7. U.S. SEC (Apple Form 10-K), https://s2.q4cdn.com/470004039/files/doc_financials/2025/ar/_10-K-2025-As-Filed.pdf

8. 第一财经，July 4, 2024, 苹果提出上诉，“消费者诉苹果垄断案”打到最高院 https://www.yicai.com/news/102178478.html

9. 上海证券报，Oct 27, 2025, 一年入账超450亿元，“苹果税”国内争议再起 https://cj.sina.cn/articles/view/1905628462/7195952e01901njx4

10. Bloomberg, Nov 13, 2025, Apple, Tencent Agree to 15% Cut of WeChat Mini App Spending https://www.bloomberg.com/news/articles/2025-11-13/apple-and-tencent-agree-to-15-fee-on-wechat-mini-game-purchases?srnd=undefined

11. European Commission, Mar 4, 2024, “Commission fines Apple over €1.8 billion … (music streaming / anti-steering)” https://ec.europa.eu/commission/presscorner/detail/en/ip_24_1161

12. European Commission, Apr 22, 2025, “Commission finds Apple and Meta in breach of the Digital Markets Act” https://ec.europa.eu/commission/presscorner/detail/en/ip_25_1085

13. Reuters, Dec 16, 2025, “App developers urge EU action on Apple fee practices” https://www.reuters.com/sustainability/boards-policy-regulation/app-developers-urge-eu-action-apple-fee-practices-2025-12-16/

14. AP, December 12, 2025, Appeals court backs contempt finding against Apple, but reopens a door for iPhone app fees https://apnews.com/article/apple-epic-iphone-app-store-appeals-contempt-307885f7c9677a6d2de632df4046aa58