Selling Digital Goods Without Apple IAP: A 2026 Guide for SaaS and App Developers

Selling digital goods on iOS in 2026? EU, US, UK rules compared. Real fee stacks, compliance checklist, and what you inherit when you leave the App Store.

BY SANDRO ZWEIG

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For over a decade, selling digital goods on iOS meant one thing: Apple's In-App Purchase system, a 30% cut, and no negotiation. That model is done. Court rulings, the EU's Digital Markets Act (DMA), and Apple's own entitlement frameworks have opened real, legal paths for selling outside the App Store in multiple markets. The question today is not whether you can route payments elsewhere. It is where, under which rules, and what you take on operationally when you do.

The shift from one rule to many

The flat 30% commission was expensive but simple. What replaced it is a region-by-region framework of entitlements, fee stacks, disclosure requirements, and reporting obligations. Each market has its own conditions. Each condition has something that will get your app rejected or your entitlement revoked if you miss it.

The markets where external payments are now live or arriving shortly: the EU (live, with a single business model announced for January 2026), the US (live since May 2025, but in legal flux), South Korea (live under a specific local law), the UK (rules pending in H1 2026), and Japan (third-party marketplaces live since early 2026)

The EU: the most developed, most complex market

The Digital Markets Act (DMA) forced Apple to open its payment ecosystem across all 27 EU member states. Apple announced January 1, 2026 as the target date for consolidating its revised fee structure into a single business model, though the full rollout is still taking shape. This is where the real engineering, compliance, and commercial decisions live for most developers with EU users.

How the fee stack works now

Apple replaced its flat EU commission with a modular system. The components:

Core Technology Commission (CTC): 5% on all digital goods and services revenue across every EU distribution path, including the App Store, Web Distribution, and alternative marketplaces. Apple has announced this will replace the 0.50 EUR per-install Core Technology Fee, though some developers remain on the CTF until the transition completes.

Store Services Fee, Tier 1: 5%. Covers basic app delivery, trust, and safety. Excludes search ranking, automatic updates, and editorial placement.

Store Services Fee, Tier 2: 13% (10% for Small Business Program members). The full App Store experience: discovery, analytics, auto-updates, editorial placement.

Initial Acquisition Fee: 2%, charged for the first six months of payments from new users acquired through the StoreKit External Purchase Link Entitlement.

Stack the components for a developer using external purchase links on standard Tier 2 terms: 5% CTC + 13% Tier 2 + 2% IAF on new users = approximately 20%. Small Business Program members land closer to 15%: the store-services discount drops from 13% to 10%, and the 2% acquisition fee is waived entirely, leaving 5% CTC + 10% = approximately 15%. For context, Apple's own data shows that 88% of EU developers pay no commission at all, and 75% pay a reduced commission through programs like the Small Business Program. The 30% versus 20% debate applies to a minority, and even for that minority, the added engineering and compliance cost often narrows the gap further than the headline numbers suggest.

How to access external payment rights in the EU

Two formal paths exist. You cannot simply add an external payment link to your app.

The Alternative Terms Addendum allows you to inform users about offers available outside the app. You can display pricing, describe your external subscription, and explain how to purchase elsewhere. You cannot include a tappable link that completes a transaction.

The StoreKit External Purchase Link Entitlement (EU) Addendum allows direct, tappable links to external payment destinations. To use it, your Apple Developer Program Account Holder must agree to the addendum, you must implement the StoreKit External Purchase APIs, you must show a system-provided disclosure sheet before each user's first external transaction, and you must report all external purchases via the External Purchase Server API.

One constraint that trips up developers: if your app uses external purchase links on an EU storefront, it cannot also offer Apple's In-App Purchase on that same storefront and platform. You pick one or the other.

The EC enforcement backdrop

In April 2025, the European Commission found Apple non-compliant with DMA Article 5(4) and ordered it to stop charging fees on steered transactions beyond compensating Apple for the initial user acquisition. Apple had 60 days to comply, with potential ongoing penalty payments. The updated fee structure and expanded link permissions are a direct result of that order. The situation continues to evolve; track Apple's developer portal for changes as enforcement proceeds.

The United States: a court-ordered window

The US path came through litigation. The April 2025 ruling in Epic v. Apple required Apple to update App Store Review Guideline 3.1.1, eliminating the entitlement requirement for external links on the US storefront. Approved developers can include a link in their app directing users to a website to purchase digital goods – no separate entitlement needed

The commission on those external transactions: 0%, as of mid-2025. App Store IAP commissions still apply to any in-app purchases, but transactions completed after linking out carry no Apple fee under the current ruling.

The uncertainty is real. In April 2026, the matter was remanded to district court to determine what constitutes a reasonable fee. The 0% rate may not last. Developers building US external billing flows should model for a fee returning to somewhere between 5% and 15%, and build infrastructure that can adapt without a full re-architecture.

To add an external purchase link on the US storefront: implement the StoreKit External Purchase Link APIs, show the required neutral exit notice, and follow Apple's system requirements for link presentation and user flow. No separate entitlement application is needed

Other markets: what to watch

United Kingdom: The Competition and Markets Authority granted Apple 'Strategic Market Status' in late 2025. Steering rules that would give UK developers the legal right to direct users to external payments are expected in the first half of 2026. UK developers currently pay standard 15 to 30% commission with no external option. Building a web billing flow before the rules drop is cheaper than building it under deadline pressure.

Japan: The Mobile Software Competition Act (late 2025) forces Apple to allow third-party app marketplaces. The Epic Games Store and AltStore are live, but uptake has been slower than proponents expected.

South Korea passed a specific telecommunications law allowing apps to use qualifying third-party payment providers. The applicable commission rate is 26%, reduced from the standard 30%.

What you actually inherit when you leave the App Store

This is the part most developers underestimate.

When Apple processes your in-app purchases, it handles a substantial operational stack: payment processing, sales tax and VAT calculation and remittance across jurisdictions, fraud prevention, refunds, subscription management, dispute handling, and compliance with local payment regulations.

When you move to external payments, all of that moves to you.

In the EU, you are responsible for VAT compliance across 27 member states. In the US, sales tax rules vary by state, and nexus thresholds differ in every jurisdiction. In Japan, you need to comply with the Specified Commercial Transactions Act. Globally, accepting card payments means PCI-DSS compliance, SCA compliance for EU transactions, and fraud liability that Apple previously absorbed.

Most SaaS and AI product teams have not built this infrastructure. Building it from scratch while simultaneously managing EU fee reporting, Apple's External Purchase Server API requirements, and per-storefront configuration is a significant engineering commitment.

A Merchant of Record absorbs most of that complexity. A MoR legally stands as the seller of record for your transactions: it handles tax calculation and remittance, regulatory compliance, payment processing, refunds, and disputes. You receive net revenue; the MoR handles everything downstream of the sale.

Tiun combines a unified backend (auth, payments, customer database, analytics) with a Merchant of Record service for SaaS and AI companies. If you are already running customer and billing data through a unified backend, having your MoR service in the same system removes the reconciliation work that comes from stitching separate tools together. Tiun's transaction fee is 2.9% + 30 cents, with no platform fee, no international card surcharges, and no FX margins. Against Apple's EU external payment stack of 17 to 20% before processor costs, the math shifts considerably.

The point is not that any one tool is required. The point is that the compliance and tax stack is not optional when you leave the App Store, and it should be part of your cost model before you decide to move.

The 2026 compliance checklist

Map your eligible markets. EU/EEA is live. US is live but legally uncertain. UK is pending. Japan has alternative marketplaces. Know where your users are and prioritize accordingly.

Choose your EU entitlement path. Alternative Terms Addendum (inform only, no tappable links) versus StoreKit External Purchase Link Entitlement (full link-out capability). You cannot run either alongside IAP on the same EU storefront.

Apply for the entitlement formally. Neither path is automatic. Your Account Holder must agree to the relevant addendum. Apple reviews the request and can decline or revoke access.

Implement the required APIs. Both EU and US external link paths require the StoreKit External Purchase Link APIs. The EU path also requires the External Purchase Server API for transaction reporting. Apps using external links without proper API implementation will be rejected in review.

Show the disclosure sheet. A system-provided disclosure sheet is mandatory before each user's first external transaction in both EU and US entitlement frameworks.

Solve the tax and compliance stack. Multi-jurisdiction tax remittance, SCA compliance for EU card payments, and dispute management need a real answer before you launch. Build it or buy it, but account for it in your unit economics.

Report your transactions. Apple requires developers using external purchase links to report external transactions via the External Purchase Server API. Missing reports can trigger entitlement revocation.

Model for rate changes. The US commission question, UK steering rules, and ongoing DMA enforcement are live proceedings. Build billing infrastructure that can absorb a rate change without a full re-architecture.

The bottom line

The App Store's hold on iOS billing is fragmenting, and 2026 is when that fragmentation became commercially real for most developers. The EU has a complete, if layered, framework for external payments. The US has a court-mandated opening with unclear long-term cost. Other markets are following.

The math on external payments is genuinely better in most scenarios. The operational complexity that replaces Apple's commission is also genuine. Developers who plan the full stack, not just the checkout flow, will keep most of the margin gain. Those who move without accounting for the tax, compliance, and reporting overhead will find the savings smaller and the headaches larger than projected.

The window is open. Go through it with your eyes open too.

Frequently asked questions

Can I use external payment links in the EU and still offer Apple In-App Purchase in the same app?

No. If your app uses external purchase links under either EU entitlement path, it cannot also offer Apple IAP on that same EU storefront and platform. You choose one approach per storefront. Some developers run parallel configurations, keeping IAP on non-EU storefronts while routing EU users through external links, but that split requires careful storefront-level implementation and separate billing logic for each region.

Is the 0% external transaction commission in the US permanent?

Not necessarily. The 0% rate came from the Epic v. Apple ruling, and in April 2026 the matter was remanded to district courts to determine what a reasonable fee looks like. The right to link out exists now, but the cost of that right may change. Developers building US external billing flows should model scenarios where a fee of 5 to 15% is reinstated, and build infrastructure that can absorb that adjustment without a full rebuild.

What happens to existing subscribers if Apple revokes your external payment entitlement?

Entitlement revocation is a real operational risk, not a theoretical one. Apple can revoke access if you violate the terms of your addendum, miss External Purchase Server API reporting requirements, or if a regulatory ruling changes the underlying legal basis. If that happens, your external payment links stop working. Users who try to purchase get sent nowhere, and any subscription billing you moved outside IAP stops renewing through the App Store. You need a continuity plan: either the ability to fall back to IAP quickly (which means keeping that infrastructure live even if dormant), or a direct relationship with users via email so you can communicate billing changes outside the app. Neither is complicated, but neither happens automatically. Build the fallback before you need it.

How do I handle users who purchased through IAP before I switched to external payments?

You cannot migrate existing IAP subscribers to external billing mid-subscription. Apple's terms treat each subscription as bound to its original purchase channel: a subscriber who started on IAP stays on IAP until they cancel or their subscription lapses. You can prompt them at renewal to switch, but the prompt cannot be an in-app tappable link if you are in the EU and have opted into external purchase links on that storefront. You have given up IAP on that storefront entirely. The practical path most developers use is a grace period: existing IAP subscribers renew through IAP until natural churn, while new users are directed to external billing. That means parallel infrastructure for potentially 12 to 24 months depending on your subscriber retention curve. Account for it in your migration timeline.

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