Apple has escalated its legal challenge against India’s antitrust authority, arguing in formal submissions dated June 25 that the Competition Commission of India (CCI) reached its conclusions by largely repeating competitors’ allegations rather than conducting independent analysis. The filings, which outline Apple’s objections to the CCI investigative report, ask the regulator to quash its findings that Apple engaged in abusive conduct on its iOS apps platform and improperly mandated use of Apple’s payment system.
According to Apple, the probe treated the company as a "minuscule player" in India - citing a market share under 6% of the country's smartphone market - and failed to verify or critically evaluate opposing parties’ claims. Apple warned that any forced changes to the App Store would disrupt its tightly integrated business design and cautioned that remedies, including behavioural requirements or penalties, could create regulatory uncertainty and chill investment into India’s digital economy.
The submission accuses the investigative team of "copy-pasting" material from rivals, detailing tables that Apple says show numerous verbatim reproductions of statements made by opposing parties. Companies named by Apple as sources that the investigation relied upon include the owner of Tinder, Match Group, India’s Paytm, and PhonePe, described in the filings as Walmart’s Indian payments app. Apple says the director general of the probe made "no effort whatsoever to independently verify or critically assess these statements, often parroting them verbatim."
Apple’s filing also challenges specific content in the investigation report, saying the CCI "blindly replicated" a graphic on global consumer spending in mobile apps and games that had featured in a 2024 EU ruling against Apple, despite different market conditions in India. The Indian report and that EU order both referenced Statista data in footnotes, a point Apple highlights as evidence of insufficient tailoring to Indian market realities.
The company is resisting both potential behavioural remedies and monetary penalties. The CCI’s penalty framework allows fines of up to 10% of turnover in the previous three years; Apple has submitted the relevant turnover figures for fiscal years 2022-24 as part of the proceedings. Apple argues that, if penalties are considered, mitigating factors should be taken into account, including what it describes as an "unblemished record" and the fact that it has exported iPhones from India valued at $51 billion over the past five years.
Apple also contends it was not afforded the chance to give oral testimony or record statements during the investigation, a procedural point the company says was not extended even once. The filings contrast that treatment with how the CCI interacted with other large firms in prior probes, noting that Google was given several opportunities to explain its business model and defend itself during the CCI’s Android case.
A legal viewpoint included in Apple’s submission cites an antitrust lawyer who notes that while oral hearings can be desirable, the investigation team is under no legal obligation to grant them if it deems its evidence conclusive. The CCI’s members will decide whether Apple should have been given the opportunity for oral evidence, according to the submission.
The watchdog has criticized Apple for slowing the process, saying the company has not responded to investigation findings for more than two years and has mounted a parallel legal challenge to India’s penalty regime. The regulator has not indicated which Apple revenues it might treat as relevant for penalties should any be imposed, though the filings show Apple provided the turnover figures required under the CCI’s procedures.
The case in India is unfolding at a time when Apple faces broader operational and supply challenges. The company is diversifying iPhone production beyond China, and its filings point to India’s rising role in Apple’s global manufacturing footprint: industry data cited in the submissions projects that India will assemble 26% of the world’s iPhones in 2026, up from 6% four years earlier. Apple emphasizes that large-scale manufacturing and exports from India form part of the context in which any regulatory measures should be assessed.
The CCI had privately concluded in 2024 that Apple engaged in abusive conduct on iOS and had improperly mandated use of its payment system. Apple disputes those conclusions and in its June 25 filing says they rest principally on the accounts of competitors rather than the CCI’s own independent analysis. The regulator has scheduled a closed-door hearing with all parties in the matter on July 21, at which senior CCI officials are expected to participate.
Several of the parties named by Apple in its submission - Match, Paytm and PhonePe - did not provide responses to requests for comment, according to the record enclosed with the filings. The CCI and the head of its investigations did not provide comment in response to requests. Apple likewise did not provide comment beyond its written submissions.
The dispute in India echoes litigation elsewhere in which large platform operators contested remedies imposed or sought by regulators. Apple’s submission refers to a 2024 European order that featured similar data visualizations, and points to an earlier Google contention that parts of a European ruling had been reproduced in an Indian investigation. At that time, the CCI dismissed the suggestion that investigators had simply copied material, saying, "We have not cut, copy and pasted."
Apple’s challenge to the CCI’s investigative approach hinges on the claim that procedural shortcomings and an over-reliance on rival submissions produced a flawed record. The company urges the regulator to revisit the draft investigation findings and to refrain from imposing measures that could, in Apple’s view, upend the integrated architecture of its App Store business and hamper investor confidence in India’s digital market.
Summary
Apple has asked Indian regulators to set aside a draft investigation report that found the company had engaged in abusive conduct on iOS. In a June 25 filing, Apple accused the CCI investigation team of largely repeating complaints made by rivals - including Match, Paytm and PhonePe - without sufficient independent verification, warned that remedies could disrupt its App Store model and noted its exports and expanding manufacturing presence in India.
Key points
- Apple claims the CCI relied extensively on rivals’ submissions and did not conduct its own critical analysis; the company requests the regulator quash the findings.
- The company warns that imposed remedies could disturb its integrated App Store model and create regulatory uncertainty that might deter digital investment.
- Procedural disputes include Apple’s contention that it was not given an opportunity for oral evidence, while the CCI says Apple delayed the process by not responding to findings and pursuing parallel legal challenges; a closed-door hearing is set for July 21.
Risks and uncertainties
- Regulatory risk for Apple - potential behavioural remedies or fines (up to 10% of relevant turnover) could affect the company’s business model and operations in India.
- Market and investment uncertainty - Apple argues that remedies could create regulatory uncertainty and deter investment in India’s digital economy, potentially impacting app developers, payments firms and platform services.
- Procedural ambiguity - disagreement over whether Apple was afforded oral hearings and whether investigative methods were sufficiently independent creates uncertainty over the conduct and outcome of the CCI process.
Tags: antitrust, Apple, India, apps, payments