App Tracking Transparency gets a new EU prompt in iOS 27.2, and five countries get no choiceApp Tracking Transparency gets a new EU prompt in iOS 27.2, and five countries get no choice

Apple announced on 16 September that iOS 27.2 and iPadOS 27.2 will offer an alternative App Tracking Transparency prompt in the European Union.

In most of the EU, developers can choose between the existing prompt and the new one. In Germany, France, Italy, Poland and Romania, Apple says only the alternative is available, citing legal requirements. The new prompt has different formatting and wording, and can carry an optional text button labelled Additional Information that opens an explanation supplied by the app. EU users can also be asked again one year after their last answer, whether they allowed or refused, unless they have turned off the system switch that permits apps to ask. In the EU that switch is renamed Allow Apps to Request to Link Your Activity Across Companies.

Apple's developer page names two new pieces: a variant of requestTrackingAuthorization that takes an expanded-interface flag and an Additional Information action, and a new Info.plist key, NSUserTrackingMarkdownUsageDescription. Apple says the rules on when an app must ask have not changed. The Mac Observer notes that the 27.2 beta release notes carry the same five-country list, and that Apple has not published the new prompt text or a screenshot.

The change follows commitments Apple gave Germany's competition regulator in August. MacRumors reported at the time that those included removing discouraging wording and letting apps combine Apple's request with the consent that data protection law requires. Apple's 16 September post does not mention that second point, so we are not assuming it has shipped.

Who has to change what

If an app never calls the tracking API, none of this applies. For the ones that do, which in our client work means most apps with paid acquisition, the work splits into code, copy and measurement.

• Code. The new call only exists on 27.2, so the old one stays for every earlier version behind an availability check. That is two paths through the permission flow, and both need testing.
• Copy. A Markdown usage description is new text in every language you ship, and the Additional Information screen is new text you write entirely. Legal review will want to see both, and that takes longer than the code.
• Measurement. Record opt-in rates by country now, before 27.2 reaches users. Without a baseline you will not be able to tell a new prompt's effect from a seasonal change.

What the sources leave open

Apple's developer page talks about apps distributed in the five countries. The release notes, as quoted, talk about users in them. Those are not obviously the same test: a German resident on a French storefront, or a traveller, could fall either side. We would not guess. Test with devices set up both ways once the beta allows it.

Apple also does not say whether the system enforces the one-year gap or leaves it to the app. We would store the date of the last prompt ourselves either way. A re-prompt that fires too early is the kind of mistake App Review notices, and that record costs one field.

Writing the Additional Information screen

The optional button is the most useful part of the change and the easiest to misuse. For the first time, the explanation sits inside the system's own flow rather than on a pre-prompt screen before it. That is a real improvement for an honest app. It is also a screen App Review will read closely, because the guidelines already forbid manipulating people into consent or withholding features from people who decline.

Explain what is linked and with whom. Do not sell the answer.

Our rule for that screen is simple. Say what data is linked, with which kinds of company, and for what purpose, in plain language, and stop. A screen that argues for a yes is a rejection waiting to happen.

What we are telling clients

Nothing ships to users until 27.2 does, so this is planning, not an emergency. It is still worth starting the copy this month, because translation and legal review are the slow part. Apps with a pre-prompt explainer should also decide whether it still earns its place once the system prompt can explain itself. For an app with meaningful EU revenue, the yearly re-prompt is the part most likely to change the numbers.