The Legal Wings Institute respectfully submits this statement to the Competition and Markets Authority (CMA) in response to the Call for Evidence published on April 1, 2026, concerning the app store rules of Apple and Google.
In Brazil, practices relating to app distribution, payment systems, and anti-steering restrictions have already been examined by the country’s antitrust authority, the Administrative Council for Economic Defense (Conselho Administrativo de Defesa Econômica, “CADE”), in investigations involving both Apple and Google that resulted in the execution of Cease and Desist Agreements (Termo de Compromisso de Cessação, “TCCs”)
The express reference to Brazil’s experience in the Call for Evidence, underscores the relevance of considering this national background in the CMA’s assessment. Accordingly, this submission aims to shed light on the Brazilian experience, particularly with respect to steering restrictions and alternative app distribution channels. To that end, it draws on the analysis conducted by CADE and highlights a set of lessons that may help illuminate the competitive effects associated with app store rules.
Therefore, this submission presents the solutions adopted in Brazil and the competitive parameters that informed CADE’s approach, with a view to contributing to the comparative analysis being undertaken by the CMA.
