Alternative App Marketplaces in the EU in 2026: The Operator Eligibility Checklist

Apple's guidance on operating an alternative app marketplace in the EU is blunt: this is not a distribution setting you switch on in App Store Connect. It is an authorized business with its own entitlement, its own fee basis, and its own liability for everything it distributes. The capabilities are only available to EU users on devices running at least iOS 17.4 or iPadOS 18, and the operator must be approved first.

That matters for two groups. If you intend to run a marketplace, the checklist below is the order Apple reviews you in. If you are a developer being courted by a marketplace, the same list tells you whether the operator in front of you can actually stay in business. We have kept every threshold exactly as Apple publishes it, because the numbers are where most applications fail.

The first gate is structural: to qualify for the Alternative App Marketplace Entitlement you must be enrolled in the Apple Developer Program as an organization. An individual membership cannot hold it, regardless of how many apps or installs it has. If the account you plan to use was registered as an individual, this is an account-level problem to solve before anything else — and one that has its own review cycle.

Apple has moved to a unified business model in the EU, and the Alternative Terms Addendum for Apps in the EU has been superseded by Attachment 14 of the Apple Developer Program License Agreement. Every marketplace operator must agree to the updated agreement, and the signature must come from the Account Holder. Agreeing does not require resubmitting the entitlement request — but fees and commissions accrued under the old Addendum remain payable.

• Development entitlement — assigned to the account shortly after submission, so you can start building and testing the marketplace components in Xcode immediately.
• Distribution entitlement — the one that actually lets you distribute. It requires review and verification of your eligibility and takes materially longer.

Request the development entitlement first and ship your internal build while the distribution review runs. A stalled distribution review does not block engineering, and the bundle ID you register early is what you will need for regional requests later.

Apple accepts one of the following. Read them as a menu, not a ladder — a two-year-old account with a hit app qualifies just as legitimately as a venture-funded company:

• Fee waiver — you are a nonprofit, accredited educational institution, or government entity already approved for an Apple Developer Program fee waiver.
• D&B Global Business Ranking — your organization's GBR score from Dun & Bradstreet falls in the “Low Risk” or “Below Average Risk” band. This is the cheapest route for an established company, and the reason a clean D&B record is worth maintaining.
• Public listing — you are publicly traded, or part of a group that is, on an exchange listed with the World Federation of Exchanges or operated by Euronext.
• Venture funding — funded by a firm on the Midas List, Midas List Europe, Invest Europe, or the HEC-Dow Jones ranking. There is no minimum amount; the identity of the investor is what counts.
• Stand-by letter of credit — USD 1,000,000 from an institution rated at least BBB- by S&P, Fitch, or Moody's, maintained for at least six months after the marketplace starts distributing apps.
• Financial audit — confirmation of an audit with an unqualified and unmodified opinion conducted within the last three years by an accredited firm, for example under the EU Statutory Audit Directive. Apple states it will not assess your financial standing or asset value.
• Scale — two continuous years in the program in good standing, plus an app with more than 1,000,000 first annual installs worldwide on iOS or iPadOS in the prior calendar year.

These are commitments made in the entitlement request, and Apple treats them as ongoing obligations rather than a launch-day formality:

• Build an app whose primary purpose is discovery and distribution of other notarized apps.
• Publish terms for the apps you distribute, including content and business model.
• Publish transparent data collection policies and give users control over how their data is collected and used.
• Follow the laws of the jurisdictions you operate in.
• Be responsible for handling governmental and other takedown requests for listings.
• Run ongoing monitoring and detection of fraudulent, malicious, or illegal apps, activity, and developers.
• Do not distribute apps that infringe intellectual property, including Apple's.
• Review other developers' apps for IP infringement before distributing them.
• Provide a process for IP disputes involving your marketplace or the apps in it.

An alternative app marketplace is a marketplace app built on the MarketplaceKit framework, a company website with a download button, and a server. The marketplace app installs from your server rather than the App Store; users download it from your website through authorized browsers; and the system installs notarized apps that your marketplace receives from other Apple Developer Program members. App Store Connect distribution tools additionally let individual developers notify marketplaces of app updates, which is how automatic updates work on your store.

Marketplaces and the apps distributed through them are subject to a 5% Core Technology Commission (CTC) on sales of paid apps and digital goods or services, including one-time purchases and auto-renewing subscriptions. The charge covers four situations: sales inside the marketplace or inside apps distributed by it; sales required to access or download the marketplace or its apps, including access subscriptions and catalog subscriptions; and sales made within seven days of a user tapping an actionable link that opened the web for a digital purchase. That last window is the one operators forget when modelling out-of-app promotions.

Apple waives the CTC on the fees your EU marketplace app charges for downloads of the marketplace, or subscription fees for access to apps it distributes — but only if both conditions hold: global revenue below €10 million in the last 12 months, and total lifetime revenue below €1 million from those download or subscription fees. Global revenue includes business activity inside and outside your apps — physical, digital, advertising, or otherwise — plus revenue from associated corporate entities that control, are controlled by, or are under common control with your company. Use the most recent 12-month financial statement on record and convert foreign currency at the spot rate at the end of that period. The waiver is narrow: it does not cover in-app sales of digital goods, only the marketplace's own download and access fees.

As the operator you report your transactions of digital goods and services to Apple — including transactions that did not result in a completed sale. That covers what you sell, paid downloads of apps on your marketplace, paid downloads of the marketplace itself, and subscriptions to a catalog of apps you distribute. Developers distributing through you report their own in-app and link-out transactions separately. Reporting runs through the Core Technology Commission reporting APIs in MarketplaceKit; wiring it after launch is how operators end up reconciling manually against Apple's invoices.

Approval does not travel. If you already operate a marketplace in another region, such as Japan or Brazil, Apple still requires a separate request to operate in the EU, and asks for the marketplace app's bundle ID to speed up the process. Plan the regional rollout as a sequence of filings, each with its own review clock, rather than one global launch.

The eligibility list explains why very few small studios operate marketplaces: the cheapest reliable route is a two-year-old organization account with a million-install year, or a standing million-dollar letter of credit. The support duties are the second filter — Apple states plainly that it cannot assist with fraud, IP disputes, payment disputes, or refunds inside your marketplace, so those costs sit with the operator.

For everyone else, the practical decision is unchanged: publish on the App Store, and use the developer-side paths that do not require operating infrastructure — external purchase links, alternative payment providers in permitted regions, and the store services fee tiers that apply to your business. Choose a marketplace to distribute into only after checking that its operator satisfies items 1 through 5 above, because if the entitlement is revoked, your app's distribution goes with it.