Brazil Opens iOS: The CADE Ruling and New Distribution

Under the agreement it reached with Brazil's competition authority CADE (Conselho Administrativo de Defesa Econômica), Apple is making a fundamental change to iOS: starting with iOS 26.5, developers in Brazil can distribute apps on alternative app marketplaces, operate their own marketplaces, and process payments outside of Apple In-App Purchase. This is the largest Latin American market where Apple has opened up alternative distribution since the EU and Japan, and it means a timeline requiring action by July 6, 2026 for every team touching the iOS ecosystem in Brazil.

💡 Pro Tip: The authorization to operate an alternative marketplace doesn't depend on a single condition, but on the full set of mandatory commitments: registering as an organization + publishing content/moderation terms, anti-fraud monitoring, a transparent data policy, and an intellectual property review mechanism. In the final financial/scale item on the list, you choose one of two paths — a $1,000,000 USD standby letter of credit OR 2+ consecutive years of good standing membership plus an app with 1M+ first-year installs worldwide in the previous calendar year.

Table of Contents

• The CADE agreement and the three new options it opens
• The iOS 26.5 threshold and geographic scope
• Notarization and the marketplace authorization process
• Child safety and content protection requirements
• Comparison with the EU regime: similarities and distinctions
• License agreement acceptance timeline (July 6, 2026)
• Commission and fee table
• Checklist for teams expanding into Brazil
• FAQ
• How does alternative distribution work on iOS in Brazil?
• What's the difference between the EU model and the Brazil model?
• When do I need to accept the new license agreement?
• What conditions do I need to meet to operate an alternative marketplace?
• What are the alternative payment restrictions for underage users?
• What does Notarization check?
• Conclusion
• Sources

The CADE agreement and the three new options it opens

According to Apple's developer announcement dated June 18, 2026, under a recent agreement reached with Brazil's competition authority CADE, Apple is making changes to iOS. The announcement text is clear: "Beginning with iOS 26.5, developers can distribute apps on alternative app marketplaces, operate alternative app marketplaces, process app payments... outside of Apple In-App Purchase" (developer.apple.com/news/?id=dhwadr2x).

The three concrete options that emerge from this can be summarized as follows:

• Distribution on an alternative marketplace: You can offer your app to users in Brazil outside the App Store, through a third-party marketplace.
• Operating an alternative marketplace: You can set up your own marketplace and distribute other developers' apps.
• In-app payment processing: You can work with a payment provider other than Apple In-App Purchase.

After listing these three, the announcement continues with "and more." The three options are independent of one another — you don't need to set up a marketplace just to use alternative payment, nor do you need to distribute your own app through the marketplace you operate.

The iOS 26.5 threshold and geographic scope

The technical threshold is clear: iOS 26.5 and later. On earlier versions, alternative distribution and alternative payment flows don't work — so the percentage of your user base already on 26.5 determines the real reach of alternative distribution.

The geographic scope is also narrow: these changes apply only to the Brazil market. Apple's official support page title confirms this: "App distribution in Brazil" (developer.apple.com/support/app-distribution-in-brazil/). Don't confuse this with the EU's DMA regime — the two rest on separate legal foundations and terms; the differences are covered under a separate heading below.

The practical consequence: without a Brazil-specific build variant or regional feature-flag strategy, you need a mechanism that enables alternative distribution/payment flows only for the Brazil App Store region.

This matters for testing too. When adding alternative payment or marketplace integration to QA, ensure test devices have both the correct region (a Brazil App Store account) and version (iOS 26.5+) — otherwise the alternative flows never trigger, and an apparent "feature doesn't work" bug may just be environment mismatch. This adds a new dimension to the CI/CD matrix for multi-region apps: each region × version × payment-path combination needs separate verification.

Notarization and the marketplace authorization process

New options also open new risk surfaces. Apple's announcement says this directly: "open new avenues for malware, fraud, scams, and privacy and security risks... with a special emphasis on child safety." Among the protections Apple lists against these risks, three stand out: Notarization, the marketplace authorization process, and child protection requirements.

Notarization is a security review that also applies to apps distributed outside the App Store. The support page describes it: "Through a combination of automated checks and human review, Notarization helps check that apps are free of known malware, viruses, or other security threats." If malware is found afterward, the consequence is severe: "If Apple determines that an app contains known malware after it's been installed, it will be prevented from launching, and new installations will be revoked."

The support page defines Notarization as follows: "Notarization for iOS apps is a baseline review that applies to all apps, regardless of their distribution channel." In practice: distributing on an alternative marketplace doesn't mean publishing without any review — the review mechanism changes, it isn't removed.

For those who want to operate an alternative marketplace, there's a separate authorization threshold. Per developer.apple.com/support/alternative-app-marketplace-br/, to qualify for the entitlement you need to be registered with the Apple Developer Program as an organization and accept the full set of commitments for the apps you'll distribute: publishing content/business model terms, a transparent data policy, continuous monitoring for fraudulent or malicious apps, and a pre-review mechanism for IP infringement. The final item asks you to choose one of two financial/scale paths:

1# Alternative marketplace entitlement: first all the mandatory commitments, then one of these two paths
2# source: alternative-app-marketplace-br
3PATH_A="A $1,000,000 USD standby letter of credit from a financial institution rated BBB- or above (must be maintained for at least 6 months after the marketplace begins distribution)"
4PATH_B="2+ consecutive years of good standing membership in the Apple Developer Program AND an app with 1M+ first-year installs worldwide on iOS and/or iPadOS in the previous calendar year"
5 
6echo "Do you accept the full set of mandatory commitments?"
7echo "Does your team meet PATH_B?"
8echo "  - Is program membership age >= 2 years, consecutive and in good standing?"
9echo "  - Was an app's first-year installs > 1,000,000 in the previous calendar year?"
10echo "If both aren't 'yes', the letter of credit (PATH_A) is required."

Technically, an alternative marketplace consists of an iOS marketplace app that uses the MarketplaceKit framework, a company website, and a server. The critical difference is this: the marketplace app itself is installed not from the App Store, but from the marketplace's own server (alternative-app-marketplace-br/).

Child safety and content protection requirements

Apple mandates an extra protection layer for child users in alternative payment flows. The three separate rules on the support page are as follows:

• Kids category apps: "Purchase flows within your app using an alternative payment processor must be preceded by a parental gate. Apps cannot provide an out-of-app offer to purchase on a website."
• All apps outside the Kids category: "Apps outside of the Kids category must support parental purchasing controls and require parental consent when offering alternative payment options." — parental purchasing control and parental consent support are mandatory.
• Users under 18 (also for apps outside the Kids category): "For users under 18 years old, your app can offer purchase flows within your app using an alternative payment processor. It must provide those options behind a parental gate. It cannot provide an out-of-app offer to purchase on a website."

The common thread of the Kids and under-18 rules: the alternative payment flow must always sit behind a parental gate for underage users, and an out-of-app offer directing them to the web is never permitted. Adult users (18+) fall under separate out-of-app rules, but the scenario specifically banned here is routing an underage user to the web.

On the engineering side, relying on a single "user age" flag won't be enough. In apps that don't reliably capture age (most don't ask for a date of birth at signup), you'll need to design which trigger activates the parental gate — a category-based default (keeping the flow on for every Kids-category app) is the least risky starting point.

A simple decision tree can be built as follows:

1// Simplified decision logic — source: app-distribution-in-brazil (Kids/Under-18 rules)
2func alternativePaymentFlow(userAge: Int, appCategory: String) -> (allowed: Bool, requiresParentalGate: Bool, outOfAppWebOfferAllowed: Bool) {
3    let requiresRestrictedFlow = userAge < 18 || appCategory == "Kids"
4    if requiresRestrictedFlow {
5        return (allowed: true, requiresParentalGate: true, outOfAppWebOfferAllowed: false)
6    }
7    return (allowed: true, requiresParentalGate: false, outOfAppWebOfferAllowed: true)
8}

Comparison with the EU regime: similarities and distinctions

It's important not to confuse this opening in Brazil with the EU's Digital Markets Act (DMA) regime — the two rest on separate legal foundations and took effect at separate times, with separate terms (for details on the EU side, you can check Apple's EU DMA guide). At a structural level, the two regimes have common points: both recognize alternative marketplace/distribution capability, both have Apple applying a security review (a notarization-like process), and in both, Apple maintains a commission/fee mechanism.

On specific fee rates, though, comparing the two regimes in one table wouldn't be accurate: the EU side is specific to DMA obligations, rests on a separate fee structure, and Apple's own DMA page is the only reliable source for terms currently in effect. You'll find Brazil's commission/CTC rates in a detailed table further below.

The practical difference: the Brazil regime results from a bilateral agreement with CADE and covers only the Brazil region, while the EU regime arises from the DMA's "gatekeeper" obligation and covers all EU member states. Teams operating in both regions need to keep their compliance matrix separate by region — even though the DPLA terms accepted in Brazil and the EU are part of the same contract text, the technical and commercial obligations operate independently by region.

This also has a concrete architectural consequence: region detection should determine not just language/localization but which payment flow and distribution channel is active. A build offering alternative payment in Brazil while following a different compliance path in the EU (or vice versa) requires the feature-flag layer to reliably read the App Store region.

License agreement acceptance timeline (July 6, 2026)

The most concrete, easy-to-overlook side of these changes is the timeline. Apple's announcement sets a clear deadline: "By July 6, 2026, all current members of the Apple Developer Program will need to agree to the latest update to the Apple Developer Program License Agreement." This is a general contract update covering all Apple Developer Program members, regardless of whether they operate in Brazil.

The legal body of the update is clarified in a separate announcement: Attachment 12 of the Apple Developer Program License Agreement was revised to specify terms for iOS apps in Brazil (alternative distribution, alternative payments, out-of-app offers, and the Core Technology Commission) (developer.apple.com/news/?id=umq9wxmm). That announcement also notes translations of the updated agreement will publish on the Apple Developer site within a month.

The deadline is July 6, 2026 — if you haven't accepted the agreement yet, check your account today; a contract that hasn't been accepted can disrupt your activities in Brazil and in the Apple Developer Program in general.

Commission and fee table

If you're a team evaluating alternative distribution or alternative payment, seeing the commission/fee table clearly directly affects the quality of your decision. The rate card on the app-distribution-in-brazil/ page can be summarized as follows:

Let's make these rates concrete with a simple calculator — let's compare a $100 USD digital product sale across three different scenarios:

1#!/usr/bin/env bash
2# Simple commission comparison — source: app-distribution-in-brazil rate card
3PRICE=100
4 
5general_iap=$(echo "$PRICE * 0.21 + $PRICE * 0.05" | bc)   # 21% commission + 5% IAP processing fee
6sbp_iap=$(echo "$PRICE * 0.10 + $PRICE * 0.05" | bc)       # 10% commission (SBP) + 5% IAP processing fee
7marketplace_ctc=$(echo "$PRICE * 0.05" | bc)               # only 5% CTC (alternative marketplace)
8 
9echo "General program + Apple IAP       : Apple's share = ${general_iap} USD"
10echo "SBP participant + Apple IAP       : Apple's share = ${sbp_iap} USD"
11echo "Alternative marketplace (CTC only): Apple's share = ${marketplace_ctc} USD"

Output: Apple's share is 26.00 USD under the general program, 15.00 USD for a Small Business Program participant, and 5.00 USD in the alternative marketplace + CTC scenario (calculation: 100×0.21+100×0.05=26; 100×0.10+100×0.05=15; 100×0.05=5). These three figures clarify which distribution model makes sense for which scale of product — even though the CTC of the alternative marketplace looks attractive for a low-volume/high-price product, meeting the prerequisites for marketplace operating authorization (mandatory commitments + letter of credit, or the 2-year + 1M installs path) is a separate threshold.

One more technical requirement for developers offering alternative payment: "you must include the StoreKit External Purchases or Offers Entitlement," and Apple In-App Purchase must be shown with at least equal prominence as other payment options on screen (developer.apple.com/support/payment-options-on-the-app-store-in-brazil/). Read together, the design constraint is clear: a UI that foregrounds alternative payment and pushes Apple IAP into the background violates the prominence rule even if it technically meets the entitlement requirement. Keep the two options symmetric in visual weight, button size, and ordering.

The reporting obligation is also on you: "You're also required to track and send Apple a report of all alternative payment transactions" — sent monthly, within 15 days after the end of the calendar month.

Rather than evaluating these variables one by one, turn them into a team decision meeting: legal/compliance, product, and engineering reviewing the commission table and authorization thresholds together prevents the decision from resting on one department's assumptions. Since operating a marketplace requires a hard-to-reverse commitment, clarifying unclear points early via Apple's official support pages is cheaper than a later contract violation.

Checklist for teams expanding into Brazil

As you turn the table and authorization thresholds above into a decision, go through this list in order:

• Contract: Accept the updated DPLA by July 6, 2026.
• Version threshold: Measure your user base's iOS 26.5+ rate, plan a Brazil-specific feature flag.
• Authorization path: If you want to operate a marketplace, clarify whether the letter of credit or the 2-year + 1M installs path fits, alongside the mandatory commitments.
• Entitlement: Add the StoreKit External Purchases/Offers Entitlement for alternative payment.
• Child protection: Enforce the parental gate flow for underage users, block out-of-app web offers.
• Cost model: Compare general/SBP/marketplace scenarios against the commission table based on your product's price range.

FAQ

How does alternative distribution work on iOS in Brazil?

On iOS 26.5 and later, developers can distribute through an alternative app marketplace outside the App Store; those who want to set up a marketplace prepare an iOS marketplace app that uses the MarketplaceKit framework, a company website, and a server component. Apple In-App Purchase can't be used in apps distributed from an alternative marketplace, and digital products/services sold become subject to the Core Technology Commission (CTC) (developer.apple.com/support/app-distribution-in-brazil/).

What's the difference between the EU model and the Brazil model?

Both regimes recognize alternative marketplace/distribution capability and apply a security review (notarization), but they rest on different legal foundations: the CADE agreement in Brazil covers only the Brazil region, while the DMA regime in the EU covers all EU member states. Fee structures are also determined separately; for the terms currently in effect on the EU side, you need to check Apple's own DMA page.

When do I need to accept the new license agreement?

By July 6, 2026. Apple's announcement is clear: "By July 6, 2026, all current members of the Apple Developer Program will need to agree to the latest update to the Apple Developer Program License Agreement." This covers not just those operating in Brazil, but all current members of the Apple Developer Program.

What conditions do I need to meet to operate an alternative marketplace?

First, you need to be registered with the Apple Developer Program as an organization and accept the full set of mandatory commitments, including content/moderation terms, a transparent data policy, continuous fraud monitoring, and intellectual property pre-review. On top of these, one of two paths: a $1,000,000 USD standby letter of credit obtained from a financial institution rated BBB- or above, which must be maintained for at least 6 months after the marketplace begins distribution, OR 2+ consecutive years of good standing membership in the Apple Developer Program and an app with more than 1 million first-year installs worldwide on iOS and/or iPadOS in the previous calendar year (developer.apple.com/support/alternative-app-marketplace-br/).

What are the alternative payment restrictions for underage users?

In apps in the Kids category, and generally for users under 18, purchase flows made with an alternative payment provider must always be behind a parental gate. In both cases, an out-of-app purchase offer directing users to the web cannot be provided.

What does Notarization check?

Notarization is a baseline review applied to all apps regardless of distribution channel. Apple's support page describes the process as "a combination of automated checks and human review"; its purpose is to verify that the app is free of known malware, viruses, or other security threats. If malware is detected after the process, the app is made unable to launch and new installations are revoked.

Conclusion

This opening in Brazil is one of the largest markets outside the EU where Apple has accepted alternative distribution, and the July 6, 2026 deadline concerns all Developer Program members. The decision facing your team isn't simple: weigh many variables at once, from whether you meet the marketplace operating thresholds to how commission scenarios affect your product pricing.

If you want to evaluate the topic in a broader context, you can check out the post covering the EU's DMA regime, on the revenue side the real strategy analysis of $1 million on the App Store, for server-side payment validation the StoreKit and Play Store receipt validation guide, on the subscription side the StoreKit 2 production subscription guide, and for child safety/age rating reform the App Store age rating reform post.

Sources

• Apple Developer News — Changes for developers distributing apps in Brazil — Official announcement of the CADE agreement, the iOS 26.5 threshold, and the July 6, 2026 contract deadline.
• Apple Developer Support — App distribution in Brazil — Official rate card for Notarization, child protection rules, and commission/fee rates.
• Apple Developer News — Update to the Apple Developer Program License Agreement — DPLA Attachment 12 revision and translation timeline.
• Apple Developer Support — Alternative app marketplaces in Brazil — Marketplace operating authorization requirements and MarketplaceKit technical components.
• Apple Developer Support — Payment options on the App Store in Brazil — Alternative payment entitlement requirement and IAP prominence rule.
• Apple Developer Support — Changes for apps in the European Union — Apple's own reference page for DMA terms on the EU side.