The CMA Wants iPhone Contactless Opened to Apple Pay Rivals: What a UK Tap-to-Pay Wallet Market on iOS Could Mean for Banks, Retailers and Fintechs
This is a proposal, not a decision. In the week of 20 October 2026, the UK's Competition and Markets Authority (CMA) was reported to have set out a proposal to open iPhone contactless access to rivals of Apple Pay. It has not been finalised. Nothing in this article should be read as saying it will be implemented, in what form or when.
That caveat shapes everything below. The proposal is interesting because of what it could allow: if it is implemented, UK banks and fintechs could build tap-to-pay wallets that run on iPhones, in a market that does not currently exist on that platform. For anyone responsible for a wallet roadmap, the useful question is not "will this happen?" but "what is worth doing now that stays sensible whichever way it goes?" This commentary answers that, and is explicit about what we do and do not know.
What was reported, and what we have not seen
The reported facts are limited, and we would rather state them precisely than pad them.
- The proposer: the UK Competition and Markets Authority.
- The proposal: to open iPhone contactless, meaning near-field communication (NFC), access to Apple Pay rivals.
- The mechanisms: through both the Secure Element and host card emulation (HCE), according to the report.
- The stated possibilities: if implemented, UK fintechs and banks could ship tap-to-pay wallets and adjacent services on iPhones. The CMA, as reported, lists payment apps, digital IDs, travel passes and digital keys among those services.
- The status: a proposal only. It is not final.
Our source is a single trade report of the proposal, published on 20 October 2026, which Innovify's market intelligence rates as high confidence on the facts but which remains one source. We have not reviewed the CMA's consultation document. We therefore do not describe the proposal's detailed terms, timetable, conditions or the responses of Apple or other parties, because we cannot support them. If you are making a decision that depends on any of those, read the consultation itself.
Why contactless access matters, in plain terms
Readers who build payments products will know this, but it is worth stating for those who commission them.
When you tap a phone on a payment terminal, the phone uses NFC to talk to the terminal. Which apps are allowed to use that capability on a given phone is decided by the phone's maker. On the iPhone, our reading of the CMA's proposal, as reported, is that it would change who can use that access, extending it beyond Apple's own wallet.
A short, non-technical gloss on the two mechanisms named in the report, which is our explanation and not the CMA's wording:
- A Secure Element is, broadly, a protected area of a device used to hold sensitive payment credentials and perform secure operations.
- Host card emulation is, broadly, a software approach in which an app presents payment credentials without them being held in dedicated hardware.
The report says the proposal covers both. Why that matters, in our interpretation, is that the two routes imply different levels of control and different security and certification questions for a wallet builder. We do not know what conditions might be attached to either, and it would be a mistake to assume.
What it could enable, if it goes ahead
Here we move from reported fact to analysis. If iPhone contactless access were opened as proposed, then, in principle, three groups could have options they lack today.
Banks
A bank could offer its own tap-to-pay experience on iPhones, under its own brand, rather than relying only on a third-party wallet for contactless payment. For some banks, this could mean more control over the customer experience at the moment of payment. Whether that outweighs the cost and complexity of running a wallet is a commercial judgement each will make for itself.
Fintechs
A fintech with a payment app could, in principle, make that app the thing a customer taps with. For businesses that have built a customer relationship around an app but have had to hand over the final step to another wallet, that may be significant. The magnitude is not something we can estimate, and we do not try.
Retailers and platforms
The report names fintechs and banks. Our interpretation is that retailers and platforms are less likely to hold the necessary payment permissions themselves, and would more likely work with a licensed partner to offer tap-to-pay. That is analysis, not reported fact, and the final terms would decide it.
The adjacent services the CMA is reported to list are also worth noting: digital IDs, travel passes and digital keys. They suggest that the proposal is not only about payment. A wallet that could hold and present more than payment credentials is closer to the idea we explored in our earlier piece on digital wallets beyond payments. We stress again that the report describes these as possibilities if the proposal is implemented.
Three scenarios, and what each would ask of you
Because the outcome is open, we find it more useful to plan against scenarios than against a forecast. These are our framing, not predictions.
- The proposal proceeds broadly as reported. Access opens on iPhones for UK wallets. The practical questions become which use cases to build, which partners to work with, what the technical and certification requirements are and how quickly you can responsibly move.
- The proposal proceeds in a modified form. Access opens, but with conditions, limits or timing that differ from the report. The questions are similar, but the answers depend on the detail, which is why reading the final text matters more than any summary.
- The proposal does not proceed, or is delayed. Nothing changes on iPhones for now. Work you did on use cases, partner conversations and internal readiness still has value for the wallets you operate elsewhere, as long as you did not commit spend that only makes sense in scenario one.
The useful observation is that the first stage of preparation is the same in all three. It is thinking and conversation rather than build.
How a brand should prepare without assuming the outcome
For a retailer, platform, bank or fintech considering a wallet, we suggest three areas of preparation. Each is designed to be low-regret: valuable whatever the CMA decides.
Use cases
Start by writing down what a wallet of your own would do for your customers that a general-purpose wallet does not. Be specific. "Tap to pay" is a feature that others offer. A reason a customer would choose yours, such as an integrated loyalty experience, a bank-account-linked flow or a travel or access credential, is a proposition.
Then be honest about whether the use case depends on iPhone access. Some do. Others work well in an app or on other platforms today. Separating the two tells you how exposed your plan is to the CMA outcome.
Permissions and obligations
You cannot work out what permissions the proposal would require, because the detail is not in our source. You can, however, map the permissions and obligations you would need for any wallet you operate: who holds the relevant regulatory authorisation, which payment providers and card schemes are involved, what security and certification your design must meet and what your risk function needs to see.
That map is the basis of a conversation with your legal and compliance advisers. It also exposes the questions you will want answered when the CMA's final position emerges. We do not give legal advice, and your advisers should lead on regulatory status.
Partners
A wallet depends on a chain of providers: issuers, processors, identity and fraud tools and the platforms that connect them. If iPhone access opens, those that are already integrated and understand your use case will be better placed to move than those starting a first conversation.
It is reasonable to begin informal conversations now with potential partners, asking how they would approach a wallet of this kind and what they would need from you. Where a partner is named in public, check that it has approved the use of its name. For a view of how brands and platforms approach the ecosystem decision, see our Embedded Finance & Digital Wallets page.
What not to do yet
Equally important is restraint. A time-sensitive topic invites over-reaction, and we would advise against four things.
- Committing build budget on the assumption of approval. A proposal can change. Spend on discovery and design is low-regret; spend on a full build tied to iPhone access is not.
- Announcing plans. Publicly promising a wallet that depends on an unfinished proposal creates risk for your brand if the proposal changes.
- Treating one report as the full picture. Read the consultation and watch for the final position.
- Ignoring the risks. A wallet is a regulated, security-sensitive product. Opening a platform does not remove the obligations that come with holding and presenting payment credentials.
A short list of questions to put to your team this month
If you do one thing after reading this, put these questions to your product, risk and partnership leads.
- Do we have a wallet use case that depends on iPhone contactless access?
- If access opened, who in our ecosystem would we work with, and have we spoken to them?
- Which regulatory permissions would we need, and who holds them today?
- What would we need to see in the CMA's final position to commit to a build?
- Who is watching the CMA's process on our behalf, and how often will they report?
Where Innovify fits
Innovify is a technology partner with deep expertise in banking, financial services, fintech and insurance, and we design compliance in from day one. We act as an implementation partner across multiple fintech platforms, which is relevant to wallet work because the ecosystem choices tend to decide how quickly a product can launch safely.
For brands, retailers and platforms thinking about a wallet, we can help with the preparation described above: use-case definition, mapping obligations and partner options and a plan that you can pick up quickly if access opens. See our Embedded Finance & Digital Wallets work for more. Let's build your next AI or financial product, starting from the evidence rather than the headline.
FAQ
What did the CMA propose about iPhone contactless?
The CMA has proposed opening iPhone contactless (NFC) access to rivals of Apple Pay, through both the Secure Element and host card emulation, according to a report on 20 October 2026. It is a proposal only and has not been finalised. We have not reviewed the consultation text, so we do not describe its detailed terms.
Could UK banks and retailers launch their own tap-to-pay wallet on iPhone?
Not on the evidence available today, because the proposal is not final. If it is implemented, the CMA is reported to see UK fintechs and banks being able to ship tap-to-pay wallets on iPhones. Whether retailers could do so directly, or would work with licensed partners, would depend on the final terms.
What other services could a wallet on iPhone offer?
The CMA is reported to list payment apps, digital IDs, travel passes and digital keys as services that could be offered if access is opened. These are described as possibilities if the proposal is implemented, not as confirmed plans. A wallet that holds more than payment credentials raises additional identity, security and compliance questions.
Is the CMA proposal final?
No. It is a proposal, and its final form, timing and conditions are not confirmed. Plan against several scenarios, including that it proceeds as reported, proceeds in modified form or does not proceed, and avoid committing build spend that only makes sense if it proceeds exactly as reported.
What should a brand do now if it wants a wallet?
Start with low-regret preparation: define the use cases that would make your wallet distinctive, map the permissions and obligations you would need and open conversations with potential partners. Take legal advice on regulatory status. Hold back on build commitments and public announcements until the CMA's position is clear.
Conclusion
The CMA's reported proposal could, if implemented, open a UK wallet market on iPhones that does not exist today. It is still only a proposal, and the right response is preparation rather than commitment: sharpen the use case, map the obligations, speak to partners and watch for the final position. Done now, that work is useful whichever way the decision falls, and it leaves you able to move quickly if the door opens.
