[Zak]

There's only a risk of fines if Apple doesn't comply with the regulation, or tries to appear compliant while sabotaging the intended goals of the regulation.

Apple is, of course prone to doing exactly that, but it doesn't have to be. The EU recently fined Apple, and a US judge sanctioned them for violating a previous ruling, both with regard to developers offering subscription payment methods other than Apple's.

It's not hard to let developers put whatever they want for subscription payments in their apps, which would fully comply and eliminate the risk. Apple just doesn't want to because it feels entitled to a cut of that revenue.

[graeme]

There isn't really a good way to know if the EC will find a violation. The legal rulings are much more substance based than rule based. This sounds good but it creates uncertainty. The previous enforcement chief routinely touted the potential for large fines.

The safest approach is not to bring in new features that might be deemed non compliant.

If the EU nonetheless threatens fine that weighs into the cost benefit analysis.

Your last paragraph focussed on the app store, but the DMA covers everything. There is no feature of the iphone excluded from potential rulings that it must be interoperable.

[Zak]

As I understand it, Apple's compliance officer (a position the DMA requires) can talk to the EC and get feedback on whether a planned feature creates compliance issues. Following the guidance that comes out of such a discussion is a near guarantee they won't get fined.

Simply avoiding self-dealing is also a near-guarantee they won't get fined. According to my inexpert reading of the DMA, including a translation app wouldn't create any compliance risk if:

* It allows the use of third-party hardware

* It documents any APIs such third-party hardware needs to support

* The app and OS allow third party access to said APIs

* Apple imposes no barriers to a third party creating a competing translation app

* Users can uninstall Apple's translation app

These are not complicated requirements if Apple actually wants to comply. Of course, Apple does not want to comply, and the risk of fines shows up when Apple tries to preserve a degree of control that the law intends to take from them.