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My response to UK CMA's potential remedies for mobile browser competition

This is my personal submission to the the Potential Remedies Working Paper from the UK's Competition and Markets Authority regarding mobile browser competition. Feel free to take inspiration/borrow from it and submit your own response by 29th August 2024. See Open Web Advocacy's article for more info!

In response to Competition and Markets Authority’s Mobile browsers and cloud gaming market investigation potential remedies.

I am a Web Developer resident in the UK, leading the development team for the London-based web agency Series Eight. This response is my personal concerns and comments rather than the position of any of my clients or employers, past or present. Series Eight is a website design and development agency that builds award-winning eCommerce and marketing websites for companies and brands within and outwith the UK. As a web developer at Series Eight I work with browsers and websites extensively and my comments come from my experience developing a large number of websites and web apps.

I have previously submitted my experiences and thoughts to the Competition and Markets Authority, and my responses are available in full on gov.uk:

These responses detail the difficulties that developers like myself face when working with Safari, the impact that the lack of iOS browser competition has on developers and businesses, and the importance and current limitations of Progressive Web Apps on Android and iOS.

I commend and appreciate the work and remedies proposed by the CMA, and believe they make a significant impact towards reducing monopolies by device vendors and opening up web access and capabilities.

I am however concerned by an area not covered by the proposals which may provide a way for Apple to follow the proposals whilst violating their intention.
The proposals make the recommendation that Apple opens up equivalent access to other browsers equal to their Safari browser. My concern with this is that Apple has regularly shown that it it willing to hamper the functionality of Safari browser if it suits their other interests. We saw this earlier this year, where for EU users Apple disabled progressive web app installation within Safari for all users, before eventually backtracking due to public pressure.

This is commonly thought to be due to Apple's conflict as a browser vendor and also an app store provider. By limiting the functionality available to web software via Safari, it encourages developers to build iOS-specific apps sold and distributed via the App Store where app-store fees can be imposed.

My concern is that if browser functionality is pegged against Safari functionality, Apple will effectively kill Progressive Web Apps by hampering Safari rather than allow third-party browsers to enable more competition against native apps from the web. Apple could prevent other browsers from installing web apps to the home screen, or limit the access to Software and Hardware APIs to significantly weaken the capabilities and usefulness of web apps.

The success of Progressive Web Apps is in my opinion essential to opening up access and competition to mobile devices. Progressive Web Apps would all app creation to have a lower barrier to entry, lower fees, and allow for more interoperability between devices.
In my capacity in working for the web within a small agency, Progressive Web Apps are a vital tool allowing businesses and agencies to produce better user experiences at a more affordable cost than native apps. The success of Progressive Web Apps through both Safari and third-party browsers would be hugely impactful to web developers, agencies and businesses where native app development would be prohibitively expensive. This allows big international companies with higher budgets to maintain entrenched advantages on iOS via the app store.

Open Web Advocacy — a group I am a member of — has proposed four additional remedies focused on ensuring that the web can compete fairly on iOS and that Apple is unable to get around the proposed remedies as I have described:

  1. "Apple shall allow third-party browsers to install and manage Web Apps using their own browser engine."
  2. "A requirement for Apple to implement Install Prompts for iOS Safari."
  3. "A requirement for Apple to grant all software and hardware access to APIs to browsers using alternative browser engines that they require to port their engines and implement stability, functionality, security and privacy. Restrictions on this can be subject to only strictly necessary, proportionate and justified security grounds."
  4. "Where feature parity between Web Apps and Native Apps is possible, Apple must technically enable it and it should not be artificially prevented either by OS rules or OS design. Apple must not self-preference their own Apps, Apps sold via their App Store or their own Services over Web Apps."

I believe these remedies would be sufficient to ensure iOS is a platform that does not limit and hamper the web. Particularly remedies 3 and 4 I think are vital to ensuring it is extremely clear that Apple must provide equal access to web apps and cannot continue to limit them in order to prefer and push their app store and native apps.

My comments are of a personal capacity and do not represent any organisation I work for. I would like my response to be attributed to me by name, and you have my permission to publish or quote from this document with or without attribution.

Best Regards,
Alistair Shepherd

Thoughts or comments?

If you have any comments or feedback on this article, let me know! I'd love to hear your thoughts, go ahead and send me an email at alistair@accudio.com or contact me on Mastodon.