UK CMA: Apple iPhone NFC access requirement

If imposed, Apple would have to let UK developers use the iPhone NFC controller through both host card emulation and the secure element, for payments and non-payment uses such as access badges, car and hotel keys, loyalty and ID, on fair terms with lower fees. The draft says it would take effect three months after the final decision, which has not been scheduled; Apple could appeal.

This is an NFC access rule whose reach goes beyond payments. If imposed, UK developers could use the iPhone NFC controller through host card emulation (HCE) as well as the secure element, for access badges, car and hotel keys, loyalty and ID as well as payments. RFID News reported in October 2026 that both methods use the same 13.56 MHz air interface, so to a reader at a terminal a tap looks the same.

That matters most to access control, transit and credential vendors, who could deliver a badge or key through their own iOS app rather than as a pass in Apple Wallet. We also reported that the draft would open up Express Mode, which lets a credential work without unlocking the phone, and Power Reserve, which keeps it working when the battery is low.

The consultation closes at 5pm on 17 November 2026. The requirement would take effect three months after a final decision, which has not been scheduled, and Apple could appeal.