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Apple's new EU tracking prompt: what changes for your app

By Zdeněk Dolák, Founder7 min read

From iOS 27.2, EU iPhone users get a redesigned tracking prompt. Where it is required, what other EU apps can choose and what to prepare before release.

From iOS 27.2, iPhone users in the EU get a redesigned App Tracking Transparency prompt. In Germany, France, Italy, Poland and Romania it will be the only version apps can show. Elsewhere in the EU, Czechia included, an app can choose the new version or keep the current one.

The rules on when an app must ask haven't changed. If your app doesn't track users across other companies' apps and websites, nothing changes for you. If it does, you have a new explanation to write, a choice to make for your other EU markets, and a chance to ask users again after a year.

iOS 27.2 is in beta for developers. As of 7 October 2026, Apple hasn't announced a release date.

What Apple announced

On 16 September 2026, Apple said it is changing App Tracking Transparency (ATT) in the EU "as part of agreements with select European competition authorities". ATT is the system prompt an app must show before it can track a user or read the device's advertising identifier.

Competition authorities in Germany, France, Italy, Poland and Romania have each investigated ATT. Germany's Bundeskartellamt closed its case in August 2026 by making Apple's commitments binding for seven years. It had objected to two things. The prompt steered users towards refusing, through a warning-hand symbol, the word "tracking" and little room for the app to explain itself. And apps often had to ask twice: once in their own consent banner and once in Apple's prompt. In Germany, Apple's own prompt for personalised ads is being aligned with the new design too.

What changes for developers, from iOS 27.2:

  • A new version of the prompt. Apple describes it as having modified formatting and language. It is a full-page sheet, and the app's explanation can use bold, italics, bullet lists and paragraph breaks. According to the Bundeskartellamt, the warning hand and the word "tracking" are gone, and the app's explanation can run to 4,000 characters.
  • An optional Additional Information button. Tapping it closes the sheet without recording an answer. The app then shows its own screen with more detail or more granular choices, and asks again. Until the user taps Allow in the system prompt, the app can't read the advertising identifier or track.
  • Asking again after a year. For users in the EU, an app may show the prompt again one year after the user's last answer, whether that answer was yes or no. It can't if the user has switched off tracking requests in Settings.
  • A renamed setting. In the EU, "Allow Apps to Request to Track" becomes "Allow Apps to Request to Link Your Activity Across Companies". Help pages and support answers that name the old setting will need updating.

Where the new prompt applies

Where the user isWhich prompt they seeWhat the app decides
Germany, France, Italy, Poland, RomaniaOnly the new full-page sheetThe explanation text, and whether to add the Additional Information button
Czechia and the rest of the EUThe current prompt, unless the app asks for the new sheetWhich version to request, per request
Outside the EUThe current promptNothing changes

"Where the user is" means two things at once. Apple's documentation requires the device to be located in the country and the user's Apple Account to have its country or region set to it. It doesn't depend on where the developer is based. A Czech company whose app is available in Germany will show the new sheet to its users there.

The change reaches only devices running iOS 27.2 or iPadOS 27.2 and later.

If your app doesn't track

Apple defines tracking as linking user or device data from your app with data from other companies' apps, websites or offline properties for targeted advertising or advertising measurement. Sharing user or device data with a data broker counts too. If none of this happens in your app, you don't show the prompt, and nothing in this change applies to you.

Check your third-party SDKs before you conclude that. Apple counts an SDK that combines data from your app with data from other developers' apps for ad targeting or measurement as tracking, even if you don't use it for those purposes. Analytics, attribution and marketing SDKs are the usual places to look.

If your app tracks

An illustrative case: a fintech app that measures which ad campaigns bring in new customers, using an attribution SDK and the advertising identifier.

Users in the five countries

They will see the new sheet whatever your app requests. Before iOS 27.2 is released:

  • Write the new explanation. It goes in a new key, NSUserTrackingMarkdownUsageDescription. If it is missing, the sheet shows your current one-line text. Translate it into the languages of the countries where your app is available.
  • Decide on the Additional Information button, and what your own screen behind it shows.
  • Move to the new request method in the app, which is what makes the button available.

Users in Czechia and the rest of the EU

Here the new sheet is a choice. Three questions help decide:

  • One flow or two? If your app is available in several EU countries, one version for every EU user is simpler to design, translate, test and describe in your privacy notice.
  • Do you need the room? The full-page sheet suits an app with a real reason to explain, such as a free service paid for by advertising, or a consent banner it wants to connect to the prompt.
  • What does a comparison show? The version is a parameter of each request, so an app can show some users one version and some the other. Each user answers at most once a year, so a comparison takes time. The Bundeskartellamt is explicit that the aim is a free and informed decision, not higher opt-in rates.

Asking again after a year

Plan when a repeat request makes sense, for example next to a feature where the explanation is relevant, not on every launch. The App Store Review Guidelines still forbid making features, content or rewards conditional on allowing tracking (guideline 5.1.2).

ATT and your consent banner

ATT is Apple's rule. It sits alongside the consent that privacy law requires, not in place of it. Under the GDPR and the EU's ePrivacy rules, apps need users' consent for certain processing for advertising, and usually collect it with their own consent banner.

For users in Germany, the Bundeskartellamt describes three ways the commitments let an app handle the overlap:

  1. Combine them. One answer in the new prompt covers both, provided every data-protection requirement is met. The information required up front goes in the explanation, and the granular choices go on the screen behind Additional Information.
  2. Keep them separate, with a reference. The app keeps its own banner, and the ATT prompt can refer to consent the user has already given there. If the user refused in the banner, the app must not show the ATT prompt.
  3. Keep them separate, as now. Users still get the new prompt.

Apple says anything you show behind the Additional Information button is entirely your responsibility. This article is general information, not legal advice. How your consent banner and the new prompt fit together is a question for your data protection officer or lawyer.

Measuring campaigns without permission

Users who decline still show up in campaign measurement. AdAttributionKit, which builds on SKAdNetwork, attributes installs and campaigns without the ATT prompt. Apple's announcement doesn't mention any change to it.

Agree with your marketing team which numbers come from AdAttributionKit and which depend on users allowing tracking. A change in the opt-in rate after iOS 27.2 shifts the second group, not the first.

What to do now

  1. Find out whether your app tracks. List every SDK and what it does with data, not only what you use it for.
  2. Check where your users are. App Store Connect shows downloads by country or region. Note whether you have users in Germany, France, Italy, Poland or Romania.
  3. Write the new explanation and translate it for those countries.
  4. Decide what Czech and other EU users see: the current prompt, the new sheet, or a comparison of both.
  5. Line up the prompt with your consent banner and your privacy notice, with whoever is responsible for data protection.
  6. Plan the repeat request a year after each answer.
  7. Test on the iOS 27.2 beta. The new sheet depends on device location and account region, so plan how you'll test it for each country.

If you would like a second opinion on what the new prompt means for a specific app, the mobile app development page describes how we work, and a short summary through the contact page is enough to start.

Sources

All sources checked on 7 October 2026.