iPhone showing Apple's alternative App Tracking Transparency prompt with Allow and Reject buttons for EU users

Apple changes the ATT prompt in the EU: alternative version mandatory in five countries from iOS 27.2

analyticsSeptember 26, 2026
By Antonio Fernandez

TL;DR

  • From iOS 27.2 and iPadOS 27.2, the alternative ATT prompt is the only version for apps distributed in Germany, France, Italy, Poland and Romania, and optional elsewhere in the EU.
  • Apple's documentation, as reported by PPC Land, lets EU apps ask again one year after a user's last answer, whether it was Allow or Reject.
  • The sample prompt drops the word 'track', uses Allow and Reject buttons, and can add an Additional Information button that returns notDetermined when tapped.
  • Apple says the rules on when tracking permission is required stay the same; users outside the EU keep the original ATT alert.

Apple is introducing an alternative version of the App Tracking Transparency (ATT) prompt in the European Union, starting with iOS 27.2 and iPadOS 27.2. In Germany, France, Italy, Poland and Romania it will be the only version available to apps, while developers elsewhere in the EU can choose to use it. Apple announced the change in a developer news post on 16 September 2026, saying it comes "as part of agreements with select European competition authorities" and that the rules on when an app must ask permission to track stay the same. Apple's updated documentation also lets apps ask EU users again one year after their last answer, according to PPC Land's reading of it.

What Apple announced on 16 September 2026

Apple's own notice, titled "Updates to App Tracking Transparency in the European Union", is short. It makes four statements. The changes are made as part of agreements with select European competition authorities. From iOS 27.2 and iPadOS 27.2, developers will have the option to use an alternative version of the ATT system prompt in the EU. The requirements for when an app must seek permission to track users will remain the same. And "due to legal requirements", only the alternative version of the prompt is available for apps distributed in Germany, France, Italy, Poland and Romania.

The notice does not name the competition authorities, say how many agreements exist, or give a release date for iOS 27.2. It links to Apple's User Privacy and Data Use page, which Apple rewrote on the same day. The detail below about how the new prompt works comes from that page and Apple's developer documentation, as reported by the trade publication PPC Land. Where a point is PPC Land's interpretation rather than Apple's text, it is labelled that way.

How the alternative ATT prompt works

A new method and a Markdown purpose string

According to PPC Land, the change centres on a new method, requestTrackingAuthorization(usingExpandedInterface:additionalInformationAction:completionHandler:), available from iOS 27.2, iPadOS 27.2 and Mac Catalyst 27.2. It takes two new parameters. preferExpandedInterface is a Boolean that asks for a full-page sheet instead of the familiar system alert. additionalInformationAction is a closure that runs when the user taps a new "Additional Information" button; passing nil removes the button.

A new Info.plist key, NSUserTrackingMarkdownUsageDescription, carries the developer's explanation in Markdown. PPC Land reports that bold, italics, bullet lists and paragraph breaks are supported, underlining is not, and the key is optional: if it is missing, the system falls back to the existing NSUserTrackingUsageDescription string. Apple's documentation also carries a tip to keep the description short and specific, and notes that the app's name already appears in the prompt.

Behaviour by region

The table below summarises how the prompt behaves by location from iOS 27.2, based on Apple's documentation as PPC Land reported it.

Behaviour by region
Where the user isWhat the app can show from iOS 27.2
Germany, France, Italy, Poland, RomaniaOnly the alternative prompt; the full-page sheet with the developer's Markdown text appears whatever the app passes for preferExpandedInterface
Other EU countriesAlternative prompt is optional; the full-page sheet appears only if the app sets preferExpandedInterface to true
Outside the EUBoth new parameters are ignored; the original alert with NSUserTrackingUsageDescription is shown
EU users who already answeredThe app may ask again after one year, whether the user allowed or refused, unless the Settings switch is off

PPC Land reports that eligibility requires two conditions at once: the device must be located in a specific EU country, and it must be signed in with an Apple Account whose country or region is set to an EU country or region. The publication also notes that Apple's two documentation pages describe the middle case, EU countries outside the five, slightly differently, so developers may want to test that path directly.

New wording and a Reject button

PPC Land describes the example screen Apple published. It asks for permission to "link your app activity with data from other companies' apps, websites, or with offline data, for personalized advertising or to measure advertising effectiveness", discloses that the app "may also share your information with data brokers", and closes with two buttons, "Allow" and "Reject". The word "track" does not appear in the sample. In the EU, the Settings switch "Allow Apps to Request to Track" is renamed "Allow Apps to Request to Link Your Activity Across Companies", according to Apple's updated page as quoted by PPC Land.

The one-year re-ask

In the EU, the system records the date of an answer and will not show the prompt again until a year has passed, PPC Land reports from Apple's page. After that the app may ask again, whether the user allowed or refused. A user who has switched off the Settings toggle cannot be asked at all. PPC Land notes that Apple's page makes no equivalent provision for users outside the EU.

What the Additional Information button does to measurement

Tapping Additional Information does not record a decision. According to PPC Land's account of Apple's documentation, it dismisses the sheet without an answer and runs the developer's closure, where the app shows its own screen. The completion handler still fires and returns the status notDetermined, and the app must call the method again to get an answer.

PPC Land points out the measurement consequence: an app that sends users to a secondary screen and back will log an indeterminate status in between, so reporting built around a single authorised or denied event may count the detour as an abandoned request. For analytics teams that report consent rates, this is the most concrete change to check in event design.

Apple's FAQ, as quoted by PPC Land, also says EU apps may use the Additional Information button to surface more granular consent controls required by local privacy law such as GDPR or ePrivacy. Everything reached through that button is the developer's responsibility, and the advertising identifier stays unavailable until the user grants permission in the ATT sheet itself.

What stays the same

Apple's notice says the requirements for when permission is needed do not change. PPC Land lists what that covers in Apple's page. Tracking still means linking data collected from an app with data from other companies' apps, websites or offline properties for targeted advertising or advertising measurement, and it includes sharing such data with data brokers. The advertising identifier still returns all zeros until a user grants permission. Hashed emails or phone numbers still cannot be used to track a user without permission, fingerprinting remains barred, and gating features on consent or offering incentives for it remains prohibited. The identifier for vendor (IDFV) can still be used for analytics across apps from the same developer, but not combined to follow users across other companies' apps. Install attribution still runs through AdAttributionKit.

Why the change is happening

Apple only says the change is part of agreements with competition authorities and, for the five countries, due to legal requirements. PPC Land places it against several cases. Germany's Bundeskartellamt closed its proceeding on 17 August 2026 with commitments dated 13 August under case reference B7-54/25. France's Autorité de la concurrence fined Apple 150 million euros on 30 March 2025. Italy's competition authority fined Apple 98,635,416.67 euros on 22 December 2025. Poland's UOKiK brought abuse-of-dominance charges over ATT in late 2025, and PPC Land reports that the Romanian investigation was listed alongside those cases. Apple has not said which legal requirement applies in which country beyond Germany.

PPC Land also reports that 9to5Mac published on 18 August 2026 a list of eight ATT changes Apple had committed to, including Markdown formatting, the optional information page, the yearly re-ask and the Reject label.

Where Apple's text and the German decision differ, according to PPC Land

This section is PPC Land's comparison, not Apple's. The German commitments give publishers a purpose string of up to 4,000 characters, but none of Apple's 16 September pages states a character limit. The German decision allowed a second ask after 12 months where the user had already consented in the publisher's consent management platform; Apple's EU rule is wider and covers any EU user who allowed or refused. The German commitments must be implemented within four months of formal service of the 13 August decision, which PPC Land calculates cannot fall before 13 December 2026, while Apple has given no public release date for iOS 27.2. The German commitments also cover Apple's own Personalized Ads prompt, which Apple's developer page does not address.

What this could mean for opt-in rates and attribution

No regulator, and not Apple, has published a forecast of how the new prompt will change consent rates, PPC Land notes. For context, the publication cites Adjust's Mobile App Trends 2026 report putting the industry average ATT opt-in rate at 38 per cent in the first quarter of 2026. It also reports that the Bundeskartellamt stated raising consent levels was not its aim.

The following is analysis. Three changes could move numbers in either direction: the removal of the word "track", the Reject label, and room for a longer explanation. The yearly re-ask gives EU refusals a second chance after 12 months, which means consent rates for long-lived EU users can change over time without any change in campaign setup. When users decline, install measurement falls back to Apple's aggregated frameworks, SKAdNetwork and AdAttributionKit, as PPC Land notes, so any change in EU opt-in rates flows directly into how much user-level attribution reaches ad platforms and analytics tools. And because the full-page sheet is compulsory in five markets but optional in the other 22, one app can show two different consent experiences inside the EU. Reporting that mixes EU countries into one opt-in rate may hide that split.

What app teams should check before iOS 27.2 ships

These are practical steps based on Apple's announcement and the documentation PPC Land describes, not instructions from Apple.

  • Confirm whether the app is distributed in Germany, France, Italy, Poland or Romania, where only the alternative prompt will be available.
  • Decide whether to write a NSUserTrackingMarkdownUsageDescription string, and localise it for the markets involved.
  • Add an event for the notDetermined status returned after an Additional Information tap, so consent reporting does not count it as abandonment.
  • Split ATT opt-in reporting by country, and by whether the full-page sheet was shown.
  • Plan for re-ask cohorts: EU users who answered a year earlier may see the prompt again.
  • If a consent management platform sits beside ATT, review Apple's FAQ conditions on linking the two, since the developer carries responsibility for that flow.

What this means for Thai marketers

Apple's notice covers the European Union only, and according to the documentation PPC Land describes, users outside the EU keep the original alert. Nothing in the source says the change applies in Thailand. The relevance for Thai businesses is indirect: Thai app publishers, games studios, travel and ecommerce apps with users in Germany, France, Italy, Poland or Romania will need to support the new method in those markets, and Thai advertisers running iOS app install or retargeting campaigns into the EU should expect their EU consent and attribution data to shift once iOS 27.2 reaches devices.

For teams that report across regions, the practical point is to keep EU iOS numbers separate from Thai and other Asian iOS numbers in dashboards, so a change in EU consent behaviour is not read as a campaign effect. That applies to Google Analytics 4 reporting, to Meta ads measurement for app campaigns, and to ecommerce app marketing where EU shoppers are part of the audience.

FAQ

Does the new ATT prompt apply in Thailand?

No, Apple's notice covers the European Union only. According to Apple's documentation as reported by PPC Land, outside the EU the system ignores the new parameters and shows the original ATT alert.

Which countries must use the alternative ATT prompt?

Germany, France, Italy, Poland and Romania. Apple said on 16 September 2026 that, due to legal requirements, only the alternative version is available for apps distributed in those five countries; elsewhere in the EU it is optional.

When does the change take effect?

It starts with iOS 27.2 and iPadOS 27.2, and Apple has not given a public release date. PPC Land reports that iOS 27.2 entered developer beta testing in the week of the notice, citing The Apple Post.

Can apps ask EU users for tracking permission again?

Yes, after one year. According to Apple's updated page as reported by PPC Land, an app in the EU may ask again a year after the user's last answer, whether that answer was Allow or Reject, unless the user has switched off the Settings toggle that lets apps ask.

Does the change alter when an app needs permission to track?

No. Apple's notice says the requirements for when developers must seek permission to track users remain the same; only the prompt's format, language and the re-ask rule change in the EU.

Consent changes on iOS feed straight into how campaigns are measured. If your EU app data needs to be separated and reported cleanly, Relevant Audience's GA4 and analytics service can help set that up.

Antonio Fernandez

Antonio Fernandez

Founder and CEO of Relevant Audience. With over 15 years of experience in digital marketing strategy, he leads teams across southeast Asia in delivering exceptional results for clients through performance-focused digital solutions.

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