The UK Competition and Markets Authority (CMA) opened a consultation on October 20, 2026, proposing that Apple give developers access to both secure element (SE) and host-based card emulation (HCE) for contactless services on iPhone. That could give competing services more ways to use the phone’s NFC technology, but the proposal is still under consultation.
What the CMA proposed
Near-field communication (NFC) lets a phone communicate with a nearby contactless terminal. The CMA says Apple currently offers developers access to SE in the UK. SE stores information on the device; HCE stores data off the device. The proposal would require Apple to offer access to both established standards.
The CMA proposes that access be available on fair, reasonable, transparent and non-discriminatory terms. It would set principles for determining access charges rather than a specific price. The CMA expects fees to be substantially lower than Apple’s current fees while still fairly rewarding Apple.
Apple argues that requiring the alternative approach would mean lower privacy and security protections. The CMA says evidence it reviewed suggests neither standard raises inherent security concerns.
Services that could use NFC access
The CMA says wider access could help businesses develop digital wallets and payment services, digital IDs and age-verification tools, car, hotel and workplace keys, tickets and travel passes, and loyalty or rewards services. These are potential uses of the proposal, not services the consultation itself puts into operation.
How the proposal differs from Tap to Pay
The CMA proposal concerns developers seeking NFC access for services used by iPhone owners. Apple’s Tap to Pay on iPhone is for merchants who want to accept a customer’s contactless payment using their iPhone. Apple announced the UK service in 2023; its announcement specified an iPhone XS or later, the latest iOS version and a partner-enabled app.
| Service | Who uses it | Payment direction | Status and requirements |
| CMA’s proposed NFC access | Developers building contactless services for iPhone users | The user’s iPhone would use NFC for a wallet or another contactless service | Under consultation; the proposed requirement covers access to SE and HCE |
| Apple Tap to Pay on iPhone | Participating merchants | A customer presents a card, phone or other contactless payment method to the merchant’s iPhone | Apple announced the UK service in 2023; requires iPhone XS or later, the latest iOS version and a partner-enabled app |
The distinction is the role of the phone: the CMA proposal is about services on an iPhone using NFC, while Tap to Pay turns a merchant’s iPhone into a payment-acceptance device. Apple’s UK announcement of Tap to Pay describes the merchant-facing service.
Consultation deadline
The consultation closes at 11:59 p.m. on November 17, 2026. The CMA says it will make a final decision after assessing responses. Readers can review the official consultation and submit a response.
